The policy specifies how long researchers are required to retain their research data. How should data be handled at the end of the retention period?

If the data were obtained with sponsorship (funding) from a grant or contract from a U.S. federal agency, regardless of discipline or form of data, it is a requirement that all grant or contract records, including original data, must be retained, preserved and available for review for at least three years after the final financial transaction involving the grant or contract. Regardless of the funding source, Yale policy requires that research data be retained for at least three three years.

What must be retained?

The University requires that the original data be retained for a specified period: Generally, three years after publication of the findings or all required final reports (e.g., progress and financial) for the project have been submitted to the sponsor.

What exactly is owned by the University?

Research materials are physical items that are generally either purchased by the University or manufactured from materials that were purchased by the University. The items themselves are owned by the University. A researcher could not, for example, take cell lines or microscopes that the PI created, sell them, and put the money in her pocket. The PI could, of course, write about the process of creating them, and would own copyright in the written material. (And, if the materials are patentable, the Patent Policy would apply to the underlying invention).

What does it mean that the University has ownership of research data?

Yale automatically assigns the Principal Investigator (PI) as custodian of the data.  Yale researchers provide scholarly leadership and bear primary responsibility for technical, programmatic, fiscal, and administrative requirements of the project, including direct responsibility for the collection, recording, storage, retention, and disposal of data.

Does the policy apply to data and materials generated as part of educational rather than research activities, for example, by students?

No. The policy is intended to apply to data and materials used for research purposes. Data and materials generated by students in the course of their studies, designed to give students the experience of research, are generally excluded. In classroom settings, especially in a collaborative environment, the instructor determines the rules for data sharing, retention, and access. Yale supports students’ rights to their work.  The University’s patent policy may also apply.

What does the policy apply to?

Research data, is defined in the policy as the “the recorded factual information associated with the research” collected or generated in the course of the research, and which may be physical or digital. Research data “necessary for the reconstruction and evaluation of the results of research” are subject to this Policy.

What can researchers take with them when they leave the University?

To the extent provided by the policy and as long as Yale holds ownership of the original data, PIs may take copies of research data when they leave Yale. In cases where research data or materials are subjects to confidentiality or other legal restrictions, PIs are required to seek permission from the Office of the Provost before taking copies. All original research data and materials must remain at the University. Depending on the discipline, some determination may need to be made about what is a copy and what is an original. This is generally decided by the PI.

What are the reasons for the policy?

As part of its core mission, “Yale is committed to improving the world today and for future generations through outstanding research and scholarship, education, preservation, and practice.” The University’s commitment to the responsible and ethical conduct of research dictates that the stewardship of research data be handled in a thoughtful and thorough manner.

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