180 · Representative Documents: Data Retention Policies
NORTHWESTERN UNIVERSITY
Research Data: Ownership, Retention and Access
http://www.research.northwestern.edu/policies/documents/research_data.pdf
Page 3
University, under the auspices of the University or with University resources. Although the
University as owner of the research data must meet the requirements of sponsors, good
management practice and practical considerations necessitate that the University and
researchers act in partnership to fulfill these obligations.
As custodians of research data, Principal Investigators (PIs) and other researchers are stewards
of research data. At the same time, no matter how such responsibilities are delegated, the flow
of accountability runs from the PI being responsible to the institution for the stewardship of
research data, just as the institution is ultimately responsible to the research sponsor.
Research data are to be accessible to members of the University community, external
collaborators and others as appropriate (e.g., for patent applications or journal submissions).
Where necessary to assure needed and appropriate access (e.g., for research misconduct
investigations), the University may take custody of research data in a manner specified by the
Vice President for Research.
Northwestern’s responsibilities with respect to research data include, but are not limited to:
1. complying with the terms of sponsored project agreements
2. ensuring the appropriate use of project resources, e.g., animals, human subjects,
recombinant DNA, biological agents, radioactive materials, etc.
3. protecting the rights of researchers, including, but not limited to, their rights to access to
data from research in which they participated
4. securing intellectual property rights
5. facilitating the investigation of charges, such as research misconduct or conflict of
interest
6. maintaining confidentiality of research data, where appropriate and
7. complying with applicable state and federal laws and regulations.
The PI’s responsibilities with respect to research data include, but are not limited to:
1. ensuring proper management and retention of research data in accordance with this
Policy
2. establishing and maintaining appropriate procedures for the protection of research data
and other essential records, particularly for long-term research projects
3. ensuring compliance with program requirements
4. maintaining confidentiality of research data, where appropriate and
5. complying with applicable state and federal laws and regulations.
2.0 Data Retention
Research data must be retained for a minimum of three years after the financial report for the
project period has been submitted. In addition, any of the following circumstances may justify
longer periods of retention:
1. research data must be kept for as long as may be necessary to protect any intellectual
property resulting from the work
2. if litigation or other dispute resolution, claim, financial management review or audit
related to the research project is started before the expiration of the three year period, or
commenced after the three year period but the relevant data and records have not been
destroyed, the research data and other project records must be retained until all
NORTHWESTERN UNIVERSITY
Research Data: Ownership, Retention and Access
http://www.research.northwestern.edu/policies/documents/research_data.pdf
Page 3
University, under the auspices of the University or with University resources. Although the
University as owner of the research data must meet the requirements of sponsors, good
management practice and practical considerations necessitate that the University and
researchers act in partnership to fulfill these obligations.
As custodians of research data, Principal Investigators (PIs) and other researchers are stewards
of research data. At the same time, no matter how such responsibilities are delegated, the flow
of accountability runs from the PI being responsible to the institution for the stewardship of
research data, just as the institution is ultimately responsible to the research sponsor.
Research data are to be accessible to members of the University community, external
collaborators and others as appropriate (e.g., for patent applications or journal submissions).
Where necessary to assure needed and appropriate access (e.g., for research misconduct
investigations), the University may take custody of research data in a manner specified by the
Vice President for Research.
Northwestern’s responsibilities with respect to research data include, but are not limited to:
1. complying with the terms of sponsored project agreements
2. ensuring the appropriate use of project resources, e.g., animals, human subjects,
recombinant DNA, biological agents, radioactive materials, etc.
3. protecting the rights of researchers, including, but not limited to, their rights to access to
data from research in which they participated
4. securing intellectual property rights
5. facilitating the investigation of charges, such as research misconduct or conflict of
interest
6. maintaining confidentiality of research data, where appropriate and
7. complying with applicable state and federal laws and regulations.
The PI’s responsibilities with respect to research data include, but are not limited to:
1. ensuring proper management and retention of research data in accordance with this
Policy
2. establishing and maintaining appropriate procedures for the protection of research data
and other essential records, particularly for long-term research projects
3. ensuring compliance with program requirements
4. maintaining confidentiality of research data, where appropriate and
5. complying with applicable state and federal laws and regulations.
2.0 Data Retention
Research data must be retained for a minimum of three years after the financial report for the
project period has been submitted. In addition, any of the following circumstances may justify
longer periods of retention:
1. research data must be kept for as long as may be necessary to protect any intellectual
property resulting from the work
2. if litigation or other dispute resolution, claim, financial management review or audit
related to the research project is started before the expiration of the three year period, or
commenced after the three year period but the relevant data and records have not been
destroyed, the research data and other project records must be retained until all
