Policies & Compliance

Award Management

Records Retention

Accurate, complete, and accessible research records are essential to the integrity, reproducibility, and oversight of sponsored research. The University and the Principal Investigator (PI) share responsibilities for the creation, stewardship, access, use, and retention of research records generated under sponsored projects, regardless of sponsor or funding source.

Unless restricted by the terms of a specific sponsored agreement, all tangible research records and materials - including scientific data and associated documentation created by University faculty, staff, or trainees using University resources - are the property of the University.

Research Data
Research Data includes laboratory notebooks and all other records, in any format or medium, that are necessary to reconstruct and evaluate reported research findings, as well as the processes, methods, and events that produced those findings.

9.9.1 University Ownership and Responsibilities

The University of Utah retains institutional ownership and stewardship of research data and project records generated at the University or through the use of University personnel, facilities, or resources. This stewardship responsibility is grounded in federal requirements (including the Uniform Guidance), sponsor expectations, and sound research administration practices.

The University's responsibilities include:

Ensuring compliance with all terms and conditions of sponsored agreements;
Overseeing the appropriate and ethical use of human subjects, animals, recombinant DNA, biohazards, radioactive materials, and other regulated research components;
Protecting the rights of students, postdoctoral fellows, and staff, including access to research data and the ability to publish research results;
Safeguarding intellectual property rights arising from research activities;
Supporting inquiries into scientific misconduct, conflicts of interest, and other compliance matters;
Responding to sponsor audits and reporting requirements; and
Managing responses to public-records requests under the Utah Governmental Records and Access Management Act (GRAMA) or the Freedom of Information Act (FOIA) in coordination with the Office of General Counsel (OGC).

9.9.2 Principal Investigator Responsibilities

The Principal Investigator (PI) is responsible for the collection, organization, retention, and protection of research data generated under a project. Research data must be maintained in sufficient detail, for an adequate duration, and in a manner that supports verification, reproducibility, privacy protection, and compliance with applicable laws, regulations, and sponsor requirements.

PIs are expected to:

Identify which research records must be retained to meet sponsor, regulatory, and institutional requirements;
Maintain a clear and well-communicated system for organizing research data and ensure that all members of the research team understand and follow it; and
Establish and maintain appropriate safeguards - particularly for long-term, high-impact, or sensitive projects - to protect essential records from loss, damage, or unauthorized access, including contingency planning for emergencies or disasters.

9.9.3 Duration of Retention of Data

Research data must be retained for a minimum of three (3) years following final project closeout, unless a longer retention period is required by the sponsor, applicable regulations, or project-specific conditions. Wherever possible, original research data should be preserved.

Extended retention is required in circumstances including, but not limited to:

Research data associated with intellectual property, which must be retained until patenting, licensing, or related actions are fully resolved;
Data related to an allegation, inquiry, or investigation involving research misconduct, conflicts of interest, allowability, allocability, or other compliance matters, which must be retained until all issues are fully resolved;
Data deposited in research repositories (e.g., institutional or discipline-specific repositories), for which on-campus copies must still be retained for at least three years to support audit and public-records compliance; and
Projects involving students, for which data must be retained until the student has completed the degree or it has been confirmed that the student has permanently discontinued work on the project.

9.9.4 Access to Records

Research records are normally maintained within the department or unit where they were generated. Records must remain on University of Utah property or in University-approved or University-leased facilities unless explicit written authorization is granted by the Vice President for Research or the Director of the Office of Sponsored Projects.

PIs must establish and maintain procedures for archiving, maintaining, and tracking research records. Permanently bound laboratory notebooks (e.g., sewn bindings) are required where necessary to protect intellectual property or support patent filings.

When necessary to protect the interests of the University or a sponsor, the University may assume custody of research data in accordance with institutional policy.

9.9.5 Transfer of Data or Records When a Researcher Leaves the University

Researchers leaving the University may generally retain copies of research data they participated in generating, unless restricted by sponsor terms, confidentiality obligations, or institutional policy. Original research records must remain with the University of Utah.

When a PI departs, and a project is transferred to another institution:

Ownership of research data may be transferred only with sponsor approval and authorization from the Vice President for Research;
The PI's department must retain copies of all records generated at the University of Utah to satisfy audit, reporting, and compliance obligations; and
The receiving institution must accept custodial responsibility for the data and agree to provide the University with access to original records upon request.

If a PI departs and the project remains at the University, a new PI will be appointed, and custody and responsibility for all original research records will transfer to that individual.

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