Data Governance

Research Data Management Interim Policy

Effective data management is critical to protecting the integrity of Pitt's research enterprise. The University has, therefore, enacted a Research Data Management Policy. Compliance with this policy ensures that data and other research records are secured in accordance with applicable laws and regulations and that research records are available to validate the integrity of data in publications (as required by publisher mandates and federal regulations). Adherence to the policy also protects against research data misappropriation and aligns Pitt’s practices with evolving research security regulations.

• Presentation Regarding Research Data Management Policy (20 minutes)
• Slide Deck from Research Data Management Policy Presentation
• Accessing Pitt OneDrive from the UPMC Network

FREQUENTLY ASKED QUESTIONS

1. What should I consider in formulating a Data Management Plan?
   
   Answer: Data management plans may vary depending on funding source and the type of data collected.  The Office of Research Integrity of the Department of Health and Human Subjects provides this guidance on the management of data.  Examples of data management plans required by NSF are provided at this link, and those required by NIH are available at this link.
   
   At the minimum, all research team members must be aware of the information that must be collected and where and how it must be saved.
    
2. How can I get assistance in formulating a Data Management Plan?
   
   Answer: This guide was prepared by the University Library System to assist researchers in planning for the various stages of managing their research data and in preparing data management plans required with funding proposals.
   
   DMPTool helps researchers create, review, and share data management plans that meet institutional and funder requirements. You can sign on with your University of Pittsburgh e-mail address.
   
   Both the Health Sciences Library System (for researchers in the health sciences) and the University Library System (for other researchers) can provide advice on formulating a Data Management Plan.
    
3. Which University systems are appropriate for archiving digital records?
   
   Answer: Digital records such as computer files must be stored on a computer server managed through the University, such as Pitt OneDrive.  Personal or lab-maintained servers must not be used for long-term data storage. If you have any questions about whether the server used to store your data is appropriate, contact Pitt IT.
    
4. I shared my data on a public repository suggested by my funding agency.  Do I still need to maintain a copy on a University-controlled server?
   
   Answer: Yes. There is no guarantee that the public repository will maintain the data through the required retention period, and thus the University must also retain a copy. 
    
5. Must all Research Records be maintained?
   
   Answer: Sufficient Research Records must be retained to permit validation of Research Outputs such as manuscripts, and as required as part of a Sponsored Activity.  However, maintenance of Records that are not relevant for validation of Research Outputs is not required, unless the maintenance of such Records is mandated by a funding agency, laws, regulations, or other policies.  For example, if a research photograph is scanned and appropriately archived, it may not be necessary to retain the original. 
    
6. I will be performing some of my Sponsored Activities as part of a collaborative team at another institution.  Where should the Research Records for this collaborative activity be stored?
   
   Answer: Collaboration agreements executed through the Office of Sponsored Programs should specify ownership and storage of Research Records, and such agreements must be followed.
    
7. I will be leaving Pitt to take a faculty position at another institution.  How do I make arrangements to transfer Research Records?
   
   Answer: Generally, if you leave the University, you may take copies of the data to your new institution provided a data use agreement has been executed through the Office of Sponsored Programs via the MyRA system.  Research Records that cannot be duplicated may be transferred to a new institution provided an appropriate agreement has been executed between Pitt’s Office of Sponsored Programs and the other institution, including a provision to make the materials available to Pitt administration on request.
    
8. I will be leaving Pitt to take a faculty position at another institution. Who do I contact to assure that my Research Records are preserved following my departure?
   
   Answer: The University Library System provides this guidance on records management; contact your Associate Dean for Research for further information.
    
9. I am authorized to work at home, and often analyze Research Records and Research Data from my home office. What steps can I take to ensure that the materials are adequately secured?
   
   Answer: See this guidance from Pitt IT regarding security standards for remote work.  Note that specific requirements exist for Restricted Data.
    
10. My student just graduated and is starting a postdoctoral fellowship at another institution.  Can they take their thesis data with them?
    
    Answer: Generally, the student is permitted to take copies of the Research Records provided an appropriate agreement, initiated by the student’s mentor, has been executed through the Office of Sponsored Programs.  Alternatively, the student may be provided access to an electronic archive of the data held by Pitt.
     
11. My funding agency and the journal I submitted a manuscript to require that I deposit my data in a public repository as a condition of publication.  Do I need to execute an agreement prior to such Data Sharing?
    
    Answer: It depends. Typically, investigators can upload data related to a published/accepted article to a public server without an agreement, provided such sharing does not violate any policies or regulations (e.g., the data does not contain personal identifiers for human subjects). In addition, an agreement is not needed to make data available to peer reviewers as a condition for review of a manuscript. However, sharing of data with individual researchers at another institution may require the execution of an agreement between the University and the other institution. The Office of Sponsored Programs can provide guidance on whether an agreement is needed.
     
12. I maintain the data for my team on a server in my laboratory.  Is this considered to be an adequate University repository for the data?
    
    Answer: No. Contact Pitt IT for recommendations on appropriate data storage repositories.
     
13. The policy states: “Access to Research Records must be provided in compliance with applicable University policies, research agreements, funding agency directives, publisher requirements, and regulatory mandates. For privacy and data security purposes, Research Records shall be available only to those who need such access and to the minimum amount necessary.”  What does this imply with regards to data sharing?
    
    Answer: The University fully supports sharing of research data, provided this is done judiciously. Data-sharing plans submitted to funding agencies must always be executed, and publisher expectations for data-sharing must always be fulfilled.  However, some sponsored research agreements may limit data-sharing, and the funding agency requirements must be honored. Export control regulations may also prohibit sharing with some entities.  In addition, data-sharing must be in accordance with all prevailing laws and regulations. For example, for human subject data, Institutional Review Board approval must be obtained before data is shared.