The University is the recipient of the grant funds and as such is the formal owner of the data. Federal funding sponsors generally describe the institution as responsible for the retention of data, but in practice at the University of Chicago the Principal Investigator is charged with custodial responsibility for his/her own research data in accordance with Office of Management & Budget (OMB) Federal Regulations, which requires financial records, supporting documents, statistical records and all other records shall be retained for a period of 3 years (with some exceptions – see OMB Federal Regulations). Specific agencies may have different retention requirements and thus is it essential to review the agency specific guidance.
Grantees generally must retain financial and programmatic records, supporting documents, statistical records, and all other records that are required by the terms of a grant, or may reasonably be considered pertinent to a grant, for a period of 3 years from the date the annual FSR is submitted. For awards under SNAP (other than those to foreign organizations and Federal institutions), the 3-year retention period will be calculated from the date the FSR for the entire competitive segment is submitted. Those grantees must retain the records pertinent to the entire competitive segment for 3 years from the date the FSR is submitted to NIH.
Longer periods of retention may be recommended when the data is in support of a patent or other protected intellectual property. It is suggested the retention period be extended at least through the life of the patent.
If there are any ongoing allegations of misconduct, conflict of interest, the data should be maintained until the case is closed or resolved.
If the data relates to a student research project, the data should be retained until at least the student’s degree is awarded or the student leaves the institution (abandons the project).
If a faculty member leaves the university, there should be a formal agreement on the dispensation of the research data. It may be that the data is maintained in a departmental resource or that the PI will provide the University with reasonable access to the original data if there is a need.