Frequently Asked Questions

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The Yale Center for Clinical Investigation (YCCI) provides assistance with registration of trials and results reporting of completed trials. See also this guide for complying with NIH public access requirements.

See Policy 1306 for guidelines on Cost Sharing on Sponsored Projects, and PR.01 on Cost Sharing Projects for calculating salary cost sharing and complying with a salary and/or non-salary cost sharing commitment.

See guidelines about undergraduates and minors participating in research or clinical activities, including visiting labs.

The Yale University Library has a useful guide with information about data management planning. The DMPTool can help you create a data management plan and it includes templates for the majority of federal and many non-profit and private funding agencies. Yale is an institutional partner of the DMPTool, so you can choose Yale as your institution and sign in with your NetID and password. If you have questions or need to consult with someone, contact the research data consultation group.


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.

The policy does not apply to data owned by third parties, nor does it apply to data gathered in the course of normal instructional practices. The policy also does not pertain to records maintained by the Office of Sponsored Programs (e.g., proposals, grant award documents, and financial records), which are governed by existing policies.

Research materials, defined in the policy as, “tangible items that are the product of research or that are used to conduct research” are physical items that are generally either purchased by the University or manufactured from materials that were purchased by the University, and are also subject to this policy. Note that a Materials Transfer Agreement must be used to document the transfer of biological materials (plasmids, cell lines, mouse strains, etc.), but also may be used in the transfer of some types of non-biological material.

The policy applies to all University faculty members, staff members, post-doctoral appointees, trainees, students, consultants and any others involved in the design, conduct or reporting of research performed at or under the auspices of the University regardless of the funding source for the project.

Yes. In general, the policy clarifies expectations, ensures researcher compliance with federal and other sponsor requirements, and promotes best practices with regard to data management across all disciplines, regardless of funding source for reasons of consistency and fairness.

The policy applies to all research data and materials generated with the support of Yale resources, including research funded by organizations that do not have data management requirements. When Yale administers funding for any research, the research is conducted with “Yale resources” (see Policy definition). Some research may be precluded by the specific terms or conditions of a sponsored award or other agreement.

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.

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. Yale researchers have the right to choose the nature and the direction of their investigations, to use research data generated to pursue future research, to publish their results, and to share their findings with scientific and academic communities. Yale researchers must also carry out their custodial responsibilities in accordance with this policy.

The university owns the data.  Ownership places ultimate responsibility for the stewardship of research data and materials with the institution. The University is the legal entity accountable for ensuring that the maintenance of and access to research data and materials are in accordance with ethical, legal, institutional and professional rules, regulations, and obligations. The University is primarily responsible for meeting all obligations concerning research data, and for supporting an environment in which the objectives of its policies and principles are met.

Yale researchers are expected to work in partnership with their department, division, and University administration to manage and protect the research data and materials produced at the University. The Council on Governmental Relations (COGR), an Association of Research Universities, explains it this way:

“As the grantee and formal owner of the data, the research institution is responsible for retaining research data, materials and documentation as required by its agreements. However, it will not be practical or reasonable from the perspective of the investigator for the institution to assume primary responsibility for custody. As a result, it is common for institutions to indicate in policy that the principal investigator serves as the custodian of data, materials and other research documentation for their projects and as responsible agent for their preservation and retention.”

Yale’s legal ownership establishes that the University has a right to access or possession in some circumstances stemming from legal requirements and sound management principles:

  • Should it become necessary to evaluate the data in sufficient detail to comply with laws and regulations governing the conduct of the research and to enable appropriate responses to questions about accuracy, reproducibility, authenticity, and primacy. The University could be placed in legal jeopardy as a result of inability to grant access to research data in cases of misconduct, fraud or malpractice allegations and any reputational harm to the University can also have an impact on its researchers. The Principles & Guidance document explains how researchers can manage their research data so they can comply with this requirement.

  • Yale’s various contracting partners and the federal government expect the University to maintain ownership and access to data. For sponsored projects in particular the University, as the grantee of sponsored research, has responsibility to ensure proper expenditure of funds provided.

  • Our researchers who work collaboratively expect that in the event of a dispute, the University will retain enough authority to step in and resolve conflicts over ownership of or access to data, generally by authorizing sufficient sharing to allow research to continue and to be published. Yale ownership of the data ensures that disagreements over ownership need not impede research and that the data are available for appropriate access, release, deposit, sharing, and publication. 

  • Finally, the University is responsible for anything done on and off its premises by its employees in the course of their employment and could be held liable for the wrongful conduct of its employees.

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).

Research data are “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.

Data are the basis for many forms of scholarly writings and serve as the definitive source of facts, observations and details of methods, procedures, or analyses. Recorded and preserved data foster the norms of accuracy, replication, and reliability in scientific research, and provide the ability to understand precisely how a procedure was performed by someone else, and what was observed months or years before.

Accurate and authenticated data records are critical for the documentation of inventions and the defense of patents. Recorded data are also critical in resolving challenges to data or conclusions, including formal allegations of research misconduct that may arise long after the primary researcher has moved on to another project or institution.

Researchers must follow Yale policy, laws and regulations, and contractual obligations with respect to research data and materials. Researchers must generally retain data and materials for sponsored projects, or that resulted in a publication, for three years.

Researchers can generally take copies of data when they leave the University, or transfer ownership to a new institution.

Researchers are encouraged to share data to the extent feasible while taking into account legal, contractual, and other restrictions on data sharing.

As legal owner, Yale is required to meet relevant legislative, regulatory, research sponsor, and contractual requirements concerning research data and materials, and is committed to developing and supporting an environment in which the objectives of its policies and principles can be achieved. Please refer to Research  Data Management Principles and Guidance.

The policy clarifies the University’s position on ownership, retention, and access to research data. The Policy complements existing Yale policies and the Faculty Handbook (especially section XX. University Policies Concerning Teaching and Research) and codifies research-related practices already in place by Yale researchers. The policy is meant to provide simple answers to questions such as “who owns these data?” and “how long do I need to keep the data?” The Policy is aligned very closely with both the current policies of major research sponsors as well as those in place at many other prominent research institutions.

This policy is designed to put in place a structure that ensures that the interests of all stakeholders of research data and materials – the University, members of the research team, research participants, and funding sources – are protected. The University works in partnership with researchers to implement best practices and meet relevant legislative, research sponsor, and regulatory requirements, and to facilitate researchers’ ability to fulfill their role as primary custodians of research data and materials.

The policy does not change the fact that Principal Investigators (PIs) and other researchers have the academic freedom to make decisions about data they use in the course of doing research. Researchers continue to determine the course, publication, and copyright of any research, subject to legal requirements, Yale policy, and the terms and conditions of sponsored awards.

This policy is designed to complement, not supersede, other policies related (but not limited) the protection of human subjects, HIPAA, FERPA, intellectual property, financial management, and record retention.

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. Given that multiple individuals, offices, and groups are integral to ensuring thoughtful and thorough stewardship, this policy was created to facilitate clarity and consistency among all stakeholders who collect, analyze, maintain or otherwise access research data and to ensure that access to research data is achieved in ways that are appropriate and consistent with the core values of the University. Good research practices, including proper data management, should and do apply to all research conducted at Yale.

As a federally funded research institution, the University has to assert ownership over research data for projects conducted at the University, under the auspices of the University or with University resources in order to meet the requirements of research sponsors. The policy sets forth that the flow of accountability is such that researchers, as custodians of the data, are responsible to the institution for the stewardship of research data and the University is ultimately responsible to its research sponsors. The University and its researchers need to act in partnership to fulfill obligations to funders.

In addition, the policy ensures that appropriate stewardship of research data is carried out so that researchers’ rights (see Policy Section 1: Roles and Responsibilities) are protected and the University has authority to resolve disputes and can carry out investigations in the event of allegations of research misconduct.

Data Retention

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.

The determination that data are “original” is simple in cases where data are physical objects, such as lab notebooks, paper surveys, telescope images, or specimen and is often discipline specific Different disciplines may also have a different understanding of what constitutes data and original data (or source materials). In cases where data are digital and copies considered identical, the distinction is less important.

It is the responsibility of the PI or the researcher to determine what needs to be retained under this policy. Optimal retention strategies may depend on the discipline. For example, some retention strategies may include retaining software necessary to generate the data or specialized documentation describing explicitly how data were collected. Examples of guidance about what should be retained include, the National Institutes of Health; the US Department of Health and Human Services; the National Science Foundation.

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. It is the responsibility of the Principal Investigator or faculty mentor to ensure that original data are retained and accessible.

Retention of data beyond the required retention period as specified in this policy may be required by Yale policy, publishers, sponsors, and applicable law, and is otherwise at the discretion of the PI. Practical standards for data retention and archiving vary among disciplines and data types. PIs are advised to consult with the Research Data Consultation Group or ITS Research Technologies regarding long term retention options.

PIs are advised not to destroy research data until the PI has confirmed that there are no circumstances that dictate otherwise, including ongoing inquiries or investigations, ongoing use of the data by students, or current patents or other claims to intellectual property. Researchers are advised to consult with ITS Research Technologies and Information Security about the proper way to destroy data should that be deemed necessary and to remove data prior to redeployment, donation, or selling of any computer or peripheral in accordance with Policy 1609 Media Control and related Procedure 1609 PR.01: Disposal of Media Containing Confidential or Protected Health Information.  Researchers should consult their department or school regarding policies and procedures in place for destroying research materials.

Some research sponsors require formal data management plans when applying for a grant.

Before beginning any research, researchers should plan how data will be recorded to ensure completeness and accuracy, where data will be stored, how the data will be managed and who will have access, and how to ensure that data are preserved for future reference. Graduate students and postdocs should have a formal discussion with their advisor or advisory committee to ensure that together they have a proper plan.

The Research Data Consultation Group is a source of information about data management planning and resources.

Collaboration with Non-Yale Partners

Ownership is often defined by the primary funding source of the project. In all cases, but especially when collaborating, it is recommended that ownership is established at the start of a project. Data management plans, increasingly required by funders and strongly recommended by the University, provide an opportunity to establish clear roles and responsibilities.

It is the responsibility of the PI or the researcher to determine what data are appropriate to share under this policy. In all cases, but especially when collaborating, it is recommended that roles and responsibilities are established at the start of a project so that rights and obligations are clear.

The policy shall be consulted regarding research data ownership and sharing in the first instance. In the event disagreements about ownership among collaborators, the Office of the Provost will become involved and attempt to resolve the dispute.

With respect to research materials, a Material Transfer Agreement (MTA) between Yale and other institutions or companies is needed in cases involving the exchange, sharing, or transfer of such materials.

Data Access and Sharing

The University must have access to research data and materials to fulfill its stewardship responsibilities. The University has an option to take possession of research data and materials in order to meet its obligations and protect its rights.

In general, individuals retain access to data resulting from research projects they themselves have initiated, and to data acquired by processes for which they were primarily responsible. However, researchers previously given access to research data in connection with a course of study, degree program, or contract may be denied such access at the discretion of the PI or other responsible University official for reasonable cause. Concerns or disputes concerning access to data will be handled by the Office of the Provost.

Faculty, staff, student or person involved in the creation of research data may have the right to review that portion of the research data that he or she created. It is recommended best practice that PIs oversee the creation of a detailed data management plan for research teams involved with a research project, especially when they involve multiple PIs and/or multiple institutions.

In some instances, a research sponsor has a legal right of access or access may be requested through the sponsoring agency under the federal Freedom of Information Act (FOIA).

No. The policy is consistent with the principles and requirements of open access to research data. Ownership in and of itself does not prevent or restrict sharing. However, there is a delicate balance between an investigator’s willingness to share data in order to facilitate scientific progress, and legislative, regulatory, contractual, ethical or other obligations to preserve and protect data. The policy enables the University to ensure that access to research data is achieved in ways that are appropriate and consistent with the core values of the University.

Yale schools and departments are encouraged to develop or revise guidelines to help their researchers follow this policy.

Data Security

Yale researchers must comply with relevant policies concerning research data and materials security. With respect to research data, Yale ITS policy on Security and Confidentiality states that, “appropriate protections (security controls) for the confidentiality, integrity and availability of data must be implemented to comply with regulations, contracts and other agreements.”

More information about data and information classification is available via Yale ITS .

Researchers should consult their department or school regarding policies and procedures in place for safeguarding research materials.

Data and Rights

The University cedes copyright on scholarly works to the authors in the Copyright policy. Generally, there is no copyright in data, because copyright attaches to words, pictures, etc. that contain inherent creativity and directly embody the thoughts of the author. So the creator of the data may be entitled to authorship, and to copyright ownership, in articles describing the substantial contributions to conception and design, or acquisition of data, or analysis and interpretation of data. Data, in contrast, are themselves noncreative, but their collection is often the result of a creative intellectual process. They are controlled by contract or regulation. The process itself might be protectable by patent and written descriptions of the process are protected by copyright.

The University has an ownership interest in all inventions or discoveries made under the auspices of the University. It holds that intellectual property rights that may exist in research data and related materials shall remain with the University, and that any dissemination and commercialization of knowledge resulting from research conducted by Yale researchers shall be done in accordance with University policy. Refer to Yale Patent policy. Data may need to be retained for longer than the period specified in the policy if the University has not made a determination whether to file a patent for which the data are pertinent at the end of the retention period.


The policy defines “Research” as, “a systematic study intended to increase knowledge or understanding of the subject studied; a systematic study specifically directed toward applying new knowledge to meet a recognized need; or a systematic application of knowledge to the production of useful materials, devices, and systems or methods”.

This definition is based on the HHS definition of research, also used by NIH.

Leaving Yale

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. A PI may request transfer of the original research data or materials to their new institution.

If a researcher leaves the University and the project itself is being transferred to another institution, original data and ownership of the data can be transferred to the new institution, per the policy. The University is committed to the continuity of research even when researchers leave Yale. The University has a responsibility to ensure that no obligations or rights have been overlooked in these situations. Most U.S. universities have similar requirements (for example, especially “May Research Records be transferred to a new institution upon the departure of a Principal Investigator?”).

For research materials, transfer requires execution of a material transfer agreement (MTA)  executed by Yale and the recipient institution prior to the removal of the materials or equipment from the University premises.

Updated September 14, 2017