Maintaining accurate and appropriate records with respect to original Research Data is an essential component of any research project. It is necessary to support and substantiate findings, to protect intellectual property rights, to facilitate management of the research program of Columbia University, to enable data sharing and to ensure compliance with federal regulations, University policies and sponsor requirements. (1)
(1) Columbia University Guidance on Retention of Research Data
Retention of Research Data
Research Data should be retained, generally, for three years after the end of a research project, or if longer, the period required by the applicable sponsor, with original Data retained wherever possible. Individual schools, departments or centers may establish a longer, but not a shorter, period of retention.
A research project should be regarded as having ended after the latest of:
- final reporting to the research sponsor;
- final financial close-out of a sponsored research award;
- final publication of research results; or
- cessation of an academic or research project, regardless of whether its results are published.
Data that must be kept for as long as necessary to protect intellectual property and complete patenting and licensing procedures for inventions resulting from University Research;
If any charges regarding the research arise, such as allegations of scientific misconduct or improper charging of costs, data must be retained at least until such charges are fully resolved or for such other period as may be required by University policy or regulation; and
If a student is involved in the research, data must be retained for at least three years afterl the student’s degree is awarded or it is clear that the student has abandoned work on the project.
Retention of Data Responsibilities
The University has the following general responsibilities with respect to the retention of Research Data:
- Complying with regulatory requirements with respect to the retention of Research Data to support grant or contract payments;
- Complying with the terms of sponsored project awards or agreements;
- Protecting the ability of students, postdoctoral appointees, staff and other collaborators to access data from research in which they participated;
- Securing the University’s intellectual property rights; and
- Sequestering or otherwise obtaining access to Research Data for a required investigation pursuant to University policy and/or regulatory or sponsor requirements.
The PI has the following responsibilities with respect to the retention of Research Data:
- Identifying, collecting, managing and retaining Research Data as custodian for the University;
- Ensuring that sufficient records are kept to document the experimental methods and accuracy of data collection as well as the methods and accuracy of data interpretation;
- Adopting an orderly and dated system of Research Data organization;
- Communicating the chosen system of data organization to all members of his/her research team, including appropriate administrative personnel;
- Complying with sponsor requirements regarding data access and retention; and
- Complying with the University’s rules on the ownership of data associated with inventions or tangible research property that the University wishes to commercialize.
 Investigators must also document the administrative and financial management of research as set forth in the SPA Records Retention Policy.
Selected Regulations and Policies Applicable to Research Data Retention
45 CFR 46: Federal Policy for the Protection of Human Subjects (The Common Rule)
21 CFR 312.57 and 312.62: FDA Regulations: Retention of IND Records
45 CFR.164: HIPAA Regulations on Retention of Protected Health Information
Columbia University Sanitization and Disposal of Information Resources Policy
Columbia University Statement of Policy on Proprietary Rights in the Intellectual Products of Faculty Activity