Research Data Management Policy : University of Dayton, Ohio

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Research Data Management Policy

Purpose

The University of Dayton’s (UD or University) responsibility for stewardship of research data, including access to data, derives from Uniform Guidance, Section 200.333. While this regulatory authority applies specifically to federally funded activities, the principle that it espouses informs good management practices with respect to all research activities undertaken at UD. Further, an increasing number of sponsors (e.g., National Science Foundation [NSF], National Institutes of Health [NIH]) have requirements for sharing research data and disseminating research results. Therefore, the University has developed this policy to help ensure UD investigators protect the integrity of research data generated under the auspices of the University.

Scope

Faculty, staff, and students involved in the administration, collection and/or generation of research data as part of a research activity at the University of Dayton.

Policy History

I. Effective Date: May 18, 2026

II. Approval: May 18, 2026

III. History:

Approved in its original form: May 18, 2026

IV. Maintenance of Policy: Vice President for Academic Research, Office for Academic Research

Definitions

Principal Investigator: The individual designated by UD, the grantee, and approved by the sponsoring agency, who holds primary responsibility for the design, conduct, management, and reporting of a research project, grant or sponsored program within a university or research institution.

Research Data: recorded factual material commonly accepted in the scientific or scholarly community as necessary to validate research findings, excluding preliminary analyses, drafts of scholarly or scientific work, plans for future research, peer reviews, and communications with colleagues and physical objects, such as laboratory samples. Research data may be in either hard-copy form (including research notes, laboratory notebooks, or photographs) or in electronic form, such as computer software, computer storage/backup, or digital images.

Research data are not limited to raw experimental results and instrument outputs; they encompass associated protocols, numbers, graphs, tables, and charts used to collect and reconstruct the data. Research data include numbers; field notes or observations; procedures for data analysis and/or reduction; data obtained from interviews, surveys, computer files and databases; research notebooks or laboratory journals; slides; audio/video recordings; and/or photographs.

Research data do not include unreported preliminary analyses of data, drafts of scientific papers, future research plans, peer reviews, or communications with colleagues; trade secrets, commercial information, materials necessary to be held confidential by a researcher until they are published, or similar information protected under law; and personnel, medical, and similar information, the disclosure of which would constitute a clearly unwarranted invasion of personal privacy. (See Uniform Guidance, 2 CFR 200.315(e)(3))

Research Materials: tangible physical objects from which data are obtained, such as environmental samples, biological specimens, cell lines, derived reagents, drilling core samples, or genetically-altered microorganisms. While these are not considered to be research data, they should be retained consistent with disciplinary standards.

Policy

Collection and generation of research data are integral aspects of research activity at the University of Dayton whether the data are primary in nature, compiled, assembled, or otherwise derived. These data have several purposes: to serve as a record of the investigation, to form the basis on which conclusions are made, and to enable the reconstruction of procedures and protocols. In keeping with the University’s commitment to promote integrity in the scholarly process, UD's research data management practices should provide open or timely secured access to, whichever is required, and secured sharing of research data. Access, secured sharing, and retention are especially vital with respect to questions about compliance with legal or regulatory requirements governing the conduct of research, accuracy or authenticity of data, primacy of findings, and reproducibility of results.

Management of research data is a shared responsibility among the Office of Academic Research, UDit, the academic units, units collecting research data, and the Principal Investigator (PI). The University Libraries provides consultative support on research data management practices, offering guidance and support as appropriate. PIs 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 within academic communities. The exercise of these rights, however, is subject to compliance with laws and regulations, as well as contractual obligations and University policies governing the conduct of research. In conducting research as part of the UD community, PIs are obligated to assist UD in fulfilling its responsibilities of complying with applicable federal, state, and local laws and meeting sponsor requirements governing the conduct of research, including the management and sharing of research data.

I. RIGHTS AND RESPONSIBILITIES

Vice President for Academic Research (VPOAR) and Vice President and Chief Information Officer (VPCIO) have joint responsibility to:

Meet research data management needs and regulatory obligations, including preservation and long-term accessibility, for critical, high-value research data, and operational considerations with respect to the various types of research data are captured;
Evaluate existing research data management solutions across the University;
Determine future research data management requirements;
Determine the information technology strategy for the University, which shall include a strategy for research data storage, archival, and information security;
Facilitate accessibility and preservation of research data through curation, metadata, repositories, and other access and retrieval mechanisms to meet federal, state, sponsor, and University requirements.

Office of Academic Research (OAR) will:

Confirm research data management practices meet state and federal regulations, sponsor requirements, and University policies, and do not conflict with other University policies or interests, such as the protection of research subjects, national security interests, intellectual property, or technology transfer;
Identify and track sponsor requirements for research data management, including security and retention needs that go beyond standard requirements;
Communicate exceptional sponsor requirements for research data management to the PI and the administering unit of the grant or contract, and if needed, to other units, such as the University Libraries;
Train and support researchers in the creation and implementation of data management plans, collaborating with University Libraries as appropriate; and
Obtain the original or substantially equivalent copies of all research records pertinent to an allegation of research misconduct or other compelling reason.

Academic and Other Administrative/Operational Units Conducting Research will:

Work with VPOAR and VPCIO to identify and track their research data management needs, including future capacity needs, and inform the VPOAR and Provost about those needs; and
Maintain any research data for any remaining retention period for a PI who has left the University.

Principal Investigator (PI) will:

Record research data consistent with the standard practices of their discipline and the parameters set forth in this policy;
Ensure that critical, high-value research data under their stewardship are preserved;
Educate all participants in the research project about their obligations regarding research data;
Manage access to research data, including developing a written data management plan as set forth in this policy;
Determine what research data need to be retained in sufficient detail to enable appropriate responses to questions about accuracy, authenticity, primacy, and compliance with laws and regulations governing the conduct of research;
Follow the UD’s Record Retention Policy and other departmental or unit procedures for the proper duration of research data retention. Data may be retained beyond UD’s Record Retention Policy and procedures if required by any law, regulation, or other agreement;
Select the vehicle for publication or presentation of the data;
Share data consistent with industry practices, scholarly norms, and research practices, as consistent with this Policy, unless prohibited by specific terms of sponsorship or other agreements governing this right;
Alert Office of Academic Research if a grant or contract may require management of research data that goes beyond standard requirements;
Destroy research data on or before deadlines required by law, regulation, or other agreements, and follow the applicable process for destroying research data as well as UD’s Record Retention Policy;
Archive research according to the procedure in Appendix A; and
Comply with the procedures included in or referenced by this policy.

If applicable the PI:

May appeal the University’s decision to seize data as detailed in Appendix A.
Must notify their Department Chair if they intend to leave UD, prior to any destruction of any research records. After a PI leaves the University, the responsibility for data management transfers to the respective department chair.
May request that the University transfer research data to a new institution, in accordance with the procedure outlined in Appendix A.

University Libraries will:

Facilitate accessibility and preservation of research data deposited in the institutional repository by providing metadata and other access support.
Provide consultative guidance to researchers on identification of appropriate discipline-specific data repositories and collaborate with OAR on researcher training and support for data management planning, as appropriate.

II. DATA MAINTENANCE AND RETENTION REQUIREMENTS

The Pl must create a data management plan prior to the initiation of a research project/activity which identifies the following items: project personnel and their responsibilities for data management; the types of data to be generated by the research project; data formats and contextual details (metadata) necessary to make the data meaningful to the project team and others; the level of access to/sharing of data including privacy or restrictions; data storage tasks and preservation needs; and potential costs for data management. Data management plans must adhere to UD's Information Security policy and all other federal or state requirements concerning data security.

Research data shall be recorded in a manner consistent with the standard practices of their discipline. In the absence of such standards, UD's minimum standard is that research records are written/recorded, dated, and identified by the project title and name(s) of the individual(s) conducting the activity, experiment(s), or other investigation(s). Whatever the institutional system used, the PI should ensure that all personnel involved with the research project/activity, including any key administrative personnel, understand and adhere to the system.

Research data and associated materials/correspondence must be retained in sufficient detail and duration to allow appropriate response to questions about research accuracy, authenticity, primacy, and compliance with laws and regulations governing the conduct of research.

Research data shall be securely managed and stored during collection and retention periods, consistent with the standard practices of the applicable discipline, applicable regulatory requirements, and/or the terms of a sponsored agreement. Of particular importance are issues involving confidentiality and general management of data obtained from human subjects, security of research data against theft or loss, and maintenance of backup or archival copies of research data that may be needed in the event of a disaster, as well as any software. Adherence to the University's Information Security policy and all other applicable regulatory requirements concerning data security are required.

When existing research data are relevant to an allegation of misconduct in scholarly activity or of financial conflict of interest, records must be retained until seven (7) years after the end of the investigation before they can be destroyed. If relevant to an open case of litigation, claim, or audit, records should be maintained until all litigation, claims or audit findings involving the records have been resolved and final action taken, then destroyed.

Special data maintenance requirements:

a) For students doing research for a PI, research data must be retained in an authorized manner until the pertinent controlling period has elapsed, the student's degree is awarded, or the research project/activity is closed or completed, whichever is longer. In addition, if the student's department requires a longer retention period, the latter would prevail.

b) Data relevant to intellectual property interests must be retained for as long as may be necessary to protect those interests, at minimum for the (above) controlling period.

c) Data subject to specific federal, state, or local regulation must be retained for the period indicated by the regulation, or the controlling period (above), whichever is longer.

d) When records are transferred to or maintained by the federal awarding agency, the retention requirement is not applicable to the award recipient.

III. ACCESSING RESEARCH DATA

Reasonable access to research data should normally be available to any member of the research group in which the data were collected, when such access is not limited otherwise by written agreement, policy, or regulation.

There may be instances in which it is necessary for UD to access research data in situations including, but not limited to, sponsor requests, patent disputes, allegations of data misuse, or subpoenas. To facilitate necessary, timely, and appropriate access to research data, UD reserves the right to take physical possession of such data. Responses to subpoenas shall be coordinated with the Office of Legal Affairs.

If there is a need for the University administration to take physical possession of research data in situations not covered by existing UD policies (such as the Intellectual Property Policy, or the Integrity in Research and Scholarship Policy), the procedure detailed in Appendix A will be followed.

IV. SHARING RESEARCH DATA

Certain external sponsors (e.g., the National Science Foundation and the U.S. Public Health Service) require that data gathered in the course of research supported with their funds be shared broadly in a timely manner after the associated research results have been published or provided to the sponsor. When data sharing is not governed otherwise by another written agreement or an applicable policy or regulation, research data created by PIs may be shared in a manner consistent with standard practices of their discipline. Tangible research materials (e.g., cell lines, technical data, manufactures of matter, or any unique material) shall be shared only by specific agreement with persons or entities outside UD (or vice-versa). Such specific agreements may include but are not limited to Material Transfer Agreements, License Agreements, Grants, and Contracts.

Reference Documents

Appendix A- Procedures

University to Access Research Data

The VPOAR will notify the PI, the department chair, and the dean or equivalent in writing of the need to access or take physical possession of specific research data. The VPOAR's request will describe the data sought and set forth the legitimate official need(s) sufficient to justify the request.

The PI may appeal the request to the UD Provost. Any such appeal must be in writing and submitted to the Provost within 20 working days of the VPOAR's request. The Provost shall review the appeal, make any further inquiry deemed appropriate, determine whether there is sufficient legitimate official need, and inform the PI of the decision in writing within 20 working days of receipt of the appeal. The Provost's decision shall be final.

If the VPOAR determines it would be impractical (e.g., deceased Investigator) or would be contrary to UD's interests (e.g., PI has violated a UD contractual obligation) to notify the Pl that the VPOAR intends to take physical possession of the research data, the VPOAR will present the written request and justification to the UD Provost. The Provost will determine whether to grant the request, and the decision shall be final. If the request is granted, the UD Provost will communicate this decision to the Pl, the department chair, and the dean or non-academic equivalent after the research data have been secured by the VPOAR.

Archiving Research Data

The PI should determine if an agency that funded any research for the research data has a requirement for archiving and dissemination of the project data. The PI should organize the research documents and data, decide on file naming conventions and file format selection ensure the usability of the research data and support the long-term preservation of research records. The University Libraries can offer consultative support to researchers in planning aspects of data management, and can provide information and tools to assist with the development and implementation of data management plans that meet federal, state and local laws and sponsor requirements.

Records selected to document a research project or for preservation should be originals for all analog formats. Records should be selected based on their information content, not their format. Records are likely to fall into one of three general categories: short term records that will be destroyed at the end of their retention period, records for which public access is needed, and records to be preserved for long term use. However, not all data generated during the lifecycle of a project requires long-term preservation. Researchers are encouraged to prioritize data necessary for the validation of research fundings or data with significant historical value. Digital files identified for public access must not contain private, confidential, or restricted information; however, pre-publication articles can be embargoed. Consult the Data Support Librarian for assistance with selecting and curating data for deposit in UD’s institutional repository, as well as for questions about identifying alternative repositories, open access licensing, publishing with embargoes, or minting digital object identifiers (DOIs) for research datasets. UDit is available to assist with technical questions related to data or file preparation, file transfer methods and data storage.

Transfer of Research Data to a PI that has left the University

If or when a PI permanently leaves UD, they may normally take original research data for which they are the steward. If so, they must notify their department chair and Dean/Director of the location of such data.

However, original research data must remain at UD when any of the following are applicable:

(a) the data have been used for a patent application filed or pending filing by UD;

(b) the research data are relevant to an ongoing inquiry/investigation under UD's Integrity in Research and Scholarship Policy;

(d) UD is otherwise required to maintain the original research data.

Upon departure from UD, a student may take a copy of UD-owned data related to their research project/activity, including thesis or dissertation, and otherwise consistent with this procedure, if not prohibited by a funding agreement. However, they must leave the original research data, including laboratory notebooks, with the Sponsoring Pl.

Destroying Research Data

A Pl must destroy research data when required by laws, regulations, or other agreements, on or before a specified deadline, and follow the applicable process for destroying research data, as well as UD’s Record Retention Schedule.