Data Management Policy FAQs

Why is the UNH policy on Ownership and Management of Research Data important to me?

The UNH policy on Ownership and Management of Research Data explains why the University of New Hampshire (UNH) and universities in general must “own” research data; and that is to comply with legal and institutional responsibilities to university members, sponsors of research, intellectual property rights, and any questions regarding research propriety and misappropriation. It sets consistent standards for research data acquisition, use, custody, maintenance, retention, access and transfer at UNH.

Whom can I contact if I have questions regarding this policy?

The Senior Vice Provost for Research.

Why does the definition of research data differ from my understanding of what data is?

Research data are not "data" or “information” in a general sense, but are the specific “recorded information necessary for the reconstruction and evaluation of reported results of research and the events and processes leading to those results, regardless of the form or the media on which it may be recorded.” i.e., specific physical records.

Why are there so many examples given of what may be research data?

It appears broad because each phrase describing research data is extracted from one or more federal regulations or published guidelines. Also, there are many different examples of research data when a broad spectrum of disciplines is represented. However, only items that meet the definition in the policy (“recorded information necessary for the reconstruction and evaluation of reported results of research and the events and processes leading to those results, regardless of the form or the media on which it may be recorded”) actually are considered research data.

Why is it difficult to understand what are research data?

The definition in the policy carefully limits research data to only recorded information necessary for the reconstruction and evaluation of reported results of research, and the events and processes leading to those results, and to exclude all other information or materials. This narrow definition is not intuitive, given the common understanding of “data.”

Aren't data generally regarded as information?

Yes, but the policy does not address "data", but rather research data, which are very narrowly and precisely defined.

How does this definition affect my record keeping and access to my data?

If your data fall under the policy’s definition of research data, then this policy applies to your record keeping and access to your data; if your data are not research data, then this policy does not apply.

If I leave the university, can I take all my notebooks and data with me?

If you are a Principal Investigator, Other Investigator, or Sponsoring Principal Investigator, per the policy you may take original research data for which you are custodian. In certain circumstances, you may take only copies, but will have access to the originals. If you are permitted to take original research data, you hold them in trust for UNH and must allow access to UNH, certain colleagues, and any sponsors of the research. If you are a Student Investigator, you may take copies of research data; you must leave original research data with your Sponsoring Principal Investigator.

What happens to research data if the Principal Investigator, Other Investigator, or Sponsoring Principal Investigator becomes incapacitated or dies?

The individual’s supervisor will take custody of that research data until such time that a plan is devised.

If I create the data, why don't I own the data?

UNH must “own” the research data (not the information, per se) to fulfill responsibilities required by external and internal regulations and/or policies. However, the policy awards custody of the data to the Principal Investigator (or Other Investigator or Sponsoring Principal Investigator) and gives that individual responsibility for physical possession of, and direct responsibility for, protecting research data, including accurate recording and proper retention, maintenance, access, sharing, and disposition of the data.

Are all written records and computer files in a research lab considered research data?

No. Only “recorded information necessary for the reconstruction and evaluation of reported results of research and the events and processes leading to those results, regardless of the form or the media on which it may be recorded” are considered research data. Records and files not involved in existing or future reported results are not research data.

Are all the data records I make research data?

No. Data records or information that are never part of reported results are not research data.

What does it mean to own data?

For the purposes of this policy, ownership concerns rights and title to the research data; it does not connote physical possession or even direct responsibility for the data. UNH requires ownership of research data to fulfill its responsibilities to University members, to meet sponsor regulations, to prevent misappropriation, and to address issues of propriety of research conduct.

If I collect data for years, does UNH own it?

Recorded original information is not research data until it is used in reporting results or was collected in anticipation of reporting results. Collection, custody, maintenance and use of recorded original data are under the control of the Principal Investigator. If data are never used in reporting results, the University does not have a responsibility toward the recorded information. If data sit unused on the Principal Investigator's shelf for ten years, UNH has no responsibility, but as soon as they are used in reporting results, the University acquires a responsibility.

What's the definition of the final project report?

“Final project report" means the last project report directly using the research data. This final project report might be a final technical report to a funding agency for a competitive research segment, or the last summary of research activities published in the open literature or provided to the public, the University, a sponsor, or other researchers based on that research data.

Is an oral presentation a report?

Only if there are written handouts or other physical records that others can take with them to rely upon.

The policy allows Principal Investigators, Other Investigators, or Sponsoring Principal Investigators to take original research data with them. This seems to conflict with the policy that the University owns the data and retains the data for 3 years or more.

The policy explicitly states, "Departing PIs, Other Investigators, and Sponsoring PIs are obligated to hold the data in trust for the University and return the data when requested to do so” and that this should be part of a written understanding specifying which parts of the research data may be copied and taken by an individual when s/he leaves the group or ceases involvement in the research project/activity. Also, that agreement may require a copy to be retained at UNH by some other Investigator, if the research data were gathered for a collaborative research effort.

Does a department chair who just arrived and started last year know where data are located from past faculty?

Research data custody is the responsibility of Principal Investigators, Other Investigators, or Sponsoring Principal Investigators, except in cases where they have left the University and the data are involved in a pending patent application or application filing, an open allegation of violation of the University Policy on Misconduct in Scholarly Activity or the Policy on Financial Conflict of Interest in Research, or the funding sponsor of the project/activity specifically requires University retention of original data. In these cases, the former chair should have left records for a new one regarding the location of data. Deans are responsible for ensuring their chairs keep adequate records.

Who is the Principal Investigator in a group?

If an individual is identified as a “Principal Investigator”, e.g., on a sponsored program that supports a group of investigators, that individual is the Principal Investigator with regard to this policy. Academic rank does not determine who is the Principal Investigator. Obviously, a sole Investigator is the Principal Investigator.

A grant has several Principal Investigators; who is the Principal Investigator in terms of this policy?

The named Principal Investigator for the overall grant is the Principal Investigator for purposes of this policy. That Principal Investigator needs the cooperation of the other investigators and works closely with them and other research personnel to ensure careful oversight of the research data involved in the entire project.

If I am Principal Investigator, must I store all the records?

As the Principal Investigator, you are responsible for the physical storage of the data. That does not necessarily mean, however, that you have to physically store all the data yourself. You are responsible for arranging for storage of the data in such a way to ensure their integrity, preservation, and security. Basically that means you need to know where they are, that the location is reasonably safe and secure, and that the environment is not inherently damaging to the media.

I have a 9-month faculty appointment. Does this policy apply to work that I do during the 3 months that I am not under contract?

It may. If you publish or present using research data collected during the summer and you list your affiliation as a faculty member at UNH, then the provisions of this policy apply. If you choose to list research activities and published materials related to your summer activities on University documents such as annual evaluations, tenure reviews, and promotion requests, then the provisions of this policy apply.

I am writing a textbook. I thought that the Intellectual Property Policy made it clear that the University does not retain any rights to this book. Does this policy change that?

No. Unless the textbook is based on results generated by your research data, this policy does not apply to that type of scholarship.

How should graduate student notebooks be handled?

Most research data generated by Student Investigators are owned by the University (see Section V.B for details). Per the policy, custody of research data generated by Student Investigators, including research notebooks, is assigned to the Sponsoring Principal Investigator (University faculty or staff advisor, instructor, or mentor).

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