Research Data Stewardship FAQs

Research Data Stewardship Policy

What is the Research Data Stewardship Policy?

The Research Data Stewardship Policy sets expectations and guidance for  U-M research data stewardship, focusing on issues of ownership, sharing and retention.  A procedures guide for policy implementation is also available.

Why was this policy developed?

Making research data publicly available has numerous benefits, including contributing to the transparency, rigor and public value of research and scholarship. Within the research community, enabling the use and reuse of existing research data extends the impact and accessibility of University research, consistent with the University’s public mission. Research funders and other stakeholders are also increasing their expectations on more deliberate and intentional management of research data. The Research Data Stewardship Policy was therefore developed to outline expectations and provide guidance for the U-M research community regarding the stewardship of these data, putting us in line with best practices at peer institutions as well as expectations from research funders.

Who does this policy apply to?

The Research Data Stewardship Policy applies to anyone collecting Research Data as part of their employment, including faculty members, staff, or students acting as employees or research assistants (e.g., graduate or undergraduate student researchers). It generally does not apply to undergraduate or graduate students performing research and scholarship solely as a part of their coursework (e.g., research for a term paper or senior thesis). Similarly, graduate students are generally the primary copyright holder of their dissertations, but the data contained therein are subject to the terms of the policy.

How was this policy developed?

The Research Data Stewardship Initiative’s working group spent nearly 18 months developing this policy and received extensive feedback from a wide range of University groups and subject matter experts, peer institutions, research funders, and other stakeholders.

What do I do if the University policy conflicts with my ability to meet funder or publisher requirements?
  1. The University’s policy should not supplant any existing grant, contract or other agreements, and is intended to provide a minimum level of expectations for data management. Some agreements may dictate longer requirements for data retention, for example, and the PI is responsible for complying with the terms of that agreement. 
What resources are available to help implement this policy?

The procedural guidance document provides key word definitions and guidelines on how to navigate the Research Data Stewardship Policy.

Where do Research Data need to be stored to satisfy the policy requirement?

Research Data must be stored and curated internally for a minimum of seven years after final closeout of a project or publication of the data, whichever occurs later. This requirement can be satisfied through a number of data storage solutions available at U-M.

Who’s responsible for storing data across the duration of the retention period if/when a researcher leaves the university?

The researcher’s home unit is responsible for retaining the research data over this time period. The ITS data storage finder is regularly updated to provide options for research data storage solutions based on data types, sharing requirements and access needs. Contact information for all data storage options can be found on the site as well.

How do domain repositories (e.g., ICPSR, Genbank), U-M’s institutional repository (Deep Blue Data), or researcher-directed (e.g., ITS storage solutions) help satisfy the storage requirements of the new policy?
  • The recommended repository or other storage solution will differ depending on the storage need. Storing research data internally does not necessarily mean the data are publicly available. Alternatively, making data available publicly does not obviate the need to retain the data internally for the defined retention period. 
  • Data storage should be achieved through university systems whenever possible but in rare cases when this is not possible or becomes cost-prohibitive for the entire seven-year period (e.g., for very large datasets), the Principal Investigator or their delegate must work with their unit and/or Information Technology Services to identify alternative storage or archiving solutions.
Who do I contact if I have questions about the University’s new policy?

General Questions

This initiative generally seems focused primarily on STEM fields that have quantitative data. What about the humanities or arts?

Research data spans virtually all disciplines. Most federal agencies now require data management plans, including the National Endowment for the Humanities Office of Digital Humanities. The National Endowment for the Arts is also embracing public access initiatives, including supporting the National Archive of Data on Arts and Culture. In the coming year every single federal agency will have defined expectations on public access federally funded research.

What does “research data” mean and how is this different from “scholarly works”?
  1. “Research data” can mean a lot of things depending on the research context and discipline. According to U-M’s new Research Data Stewardship Policy, research data means the recorded material commonly accepted in research communities as necessary or useful to validate, reconstruct, evaluate, replicate, and/or generate findings. Supporting information required to interpret research data, such as computer code, metadata, and observational records including laboratory notebooks or other forms of documentation are included, but preliminary data (as defined in the procedures guide), analyses, drafts of publications, plans for future research, peer reviews, communications with colleagues, and scholarly works as defined in SPG 601.28 (Copyright) are not covered because faculty own the copyright, whereas research data themselves are not copyrightable. This definition does not apply to non-research clinical data, or to patents, inventions, copyrights, or other administrative data or property governed by separate University policies.
  2. If you have questions about what constitutes research data in your field/project, or wonder what types of data should be shared (i.e. raw vs treated) in your specific context, contact your department’s librarian or the library’s Research Data Services at 
Are materials or other physical samples considered research data? How do I make those publicly available?

The answer varies depending on the context. In some disciplines, agencies or journals will expect the permanent archiving of physical specimens and/or biological samples. U-M has a central biorepository and a number of world-class museums across the natural sciences that can assist researchers with depositing specimens into collections. Other repositories or practices may be commonplace in other disciplines. Be sure to consult with funder or journal policies to confirm expectations.  

What should I do if I suspect research misconduct has taken place and resulted in compromised integrity of research data?

You should report your concerns to U-M’s research integrity office in the Office of the Vice President for Research ( In cases when research integrity allegations arise, the University may request original research data and other research records as evidence when those allegations are being reviewed. 

Do policies or guidance differ for members of the research community depending on their role or rank?
  1. In general, stewardship of research data is a shared responsibility of all researchers, regardless of their title. Students, trainees and staff should work with their advisor or the principal investigator (PI) on the project to determine best practices for individual projects or research groups. PIs have additional responsibilities as outlined in the procedural guidelines for SPG 303.06. If a PI chooses to delegate responsibility (e.g., within a research group), the PI will remain accountable for the proper stewardship of research data as described above.

A data management plan is a useful document for specifying a project’s or research group’s data practices, including who is responsible for which aspects of the data and its care.

A data management plan is a useful document for specifying a project’s or research group’s data practices, including who is responsible for which aspects of the data and its care.

Does U-M have formal policy relating to Research Data or administrative data?
  1. As announced in June 2023, U-M will now have a Research Data Stewardship Policy (SPG 303.06) that outlines expectations for management, ownership, retention, and sharing of research data. For additional questions about the development of the policy itself, see the Research Data Stewardship Policy section above.

Additionally, SPG 601.12 addresses “institutional data,” which are data that may be relevant to planning, managing, operating, controlling, or auditing administrative functions of an administrative or academic unit of the University, among other things.

How is U-M working with other academic institutions on topics related to research data?

U-M has been actively engaging in research data stewardship issues with member organizations like the Association of American Universities (AAU), the Association of Public and Land Grant Universities (APLU), and the Association of Research Libraries (ARL). U-M participated in several workshops and discussions facilitated by APLU and AAU on accelerating public access to research data, and also was a founding member of the Higher Education Leadership Initiative for Open Scholarship (HELIOS).

Data Sharing

What is the difference between “open access” and “public access”?

Open access generally describes datasets or publications that are freely available to users/readers with no restrictions on accessibility, (re)use, and redistribution. Public access generally refers to data or information that is readily discoverable and accessible to other researchers and people outside of the research project, but may also have some restrictions on accessibility, reuse, or redistribution. The U-M Library has a research guide on open access publishing.


Are there new expectations for making publications freely available or publishing in open access journals too?

There is no federal or U-M policy requiring researchers to publish in open access journals. However, some federal agencies and private funders have requirements for making publications open and/or available. Depositing pre-publication (accepted or submitted) versions of publications into preprint servers or other repositories (like NIH’s PubMed Central or U-M’s Deep Blue Documents) often satisfy these requirements. The U-M Library has a research guide on open access publishing.

For researchers wishing to explore more options for publishing their work in open access journals, the U-M Library now has agreements in place with several publishers to provide discounted publishing fees to U-M researchers.

How does software and/or code fit into public access requirements?
  1. U-M’s new Research Data Stewardship Policy defines research data to include supporting information required to interpret research data, such as computer code, metadata, and observational records including laboratory notebooks or other forms of documentation. The U-M policy does not mandate public access of this supporting information, but funder policies are evolving and may require this now or in the future. 
  2. Many journals now require software and/or code for an analysis to be made available at the time of publication, alongside data. Consult these best practices for additional guidance and resources.Researchers should understand a journal’s public access policy prior to submission so that any intellectual property concerns related to inventions and associated code, models and frameworks can be addressed ahead of time. Contact U-M Innovation Partnerships with any related questions about releasing code or open source software. 
How am I supposed to share all of my data if I also am expected to protect it for various reasons (e.g., it potentially contains sensitive or personally identifiable material)?

Researchers must balance making data publicly available, while also providing necessary protections or restrictions on potentially sensitive research data. These restrictions are in place to protect human participants, data technologies subject to export control, and controlled unclassified information. Whenever possible sensitivities exist, refer to any standing data use agreements, IRB protocols, or other guidance related to your specific data needs. Failure to maintain protections or restrictions could expose the researchers, institution, and participants to significant legal, reputational, and security risks.

When writing a data management or sharing plan, be sure to provide details about any protections that will be in place to secure the data during your research project, and any restrictions that may limit your ability to share the data more broadly.

Are there different expectations for researchers sharing research data internally with other researchers at U-M and sharing it externally?

Data should be made available to all members of a collaborative team or project, contingent upon necessary training or approvals. Otherwise, there is no additional expectation that researchers can/should make their data more or less accessible to other researchers at U-M any differently than researchers at other institutions. 

I’m concerned about my research being “scooped” if I’m required to share research data more openly. What can I do to prevent this?

Someone else claiming priority to a research idea, or reusing data for subsequent analyses/publications without credit, is regularly brought up as a reason not to share data. However, sharing data through a trusted repository provides several ways to alleviate this concern. First, journals increasingly expect that the data that underlie research findings are shared concurrently with the publication of the findings, and publishing your data at that time eliminates the possibility of being scooped by someone else. Second, even if the data need to be shared before the research findings are published, most repositories offer the option of embargoing the data for a specified amount of time. Embargoing the data demonstrates compliance through creating a record of the data while withholding direct access to the data for a reasonable amount of time. Third, depositing data into a repository provides a means to register it, through providing a timestamp indicating when the data were available, as well as identifiers to enable others to cite the data appropriately. In the rare case that a question should arise about the reuse of the data, the owners of the original deposited data can use this information to demonstrate attribution for its generation or provenance by others. 


Data Ownership & Retention

What should I do with my research data if I am planning to leave U-M?
  1. It is the responsibility of the schools/colleges/units to develop exit plans in accordance with U-M’s new Research Data Stewardship Policy when determining how research data and supporting records must be retained at U-M. Plans must take into account the needs and rights of those researchers who remain at the University, the need to maintain the integrity and regulatory oversight of continuing or ongoing research, the need to comply with terms and conditions in sponsored research agreements or any other applicable agreements or protocols, and the needs of the departing PI to complete the research project if applicable.  
  2. When seeking to transfer copies of the original data from the University to a new institution, the PI must complete a data use agreement (DUA) through their home unit and the Office of Research and Sponsored Projects (ORSP) at the time of offboarding. The University, in its sole discretion, has the right to agree to transfer only copies of research data and/or supporting documentation and records, or to refuse transfer of any research data. IRB review and approval to use the data may also be needed from the institution to which the data will be transferred.
Who owns the research data I collected while working at U-M?
  1. The University owns research data and materials generated for or by projects conducted at the University. Principal Investigators or their delegates are responsible for the management and stewardship of Research Data on behalf of the University, including the curation, analysis, or dissemination of Research Data in accordance with the terms of this Policy.
  2. This is distinct from scholarly, academic, and artistic works, for which the university places copyright with the creators (see question below). 
  3. For additional information see SPG 303.06 and the associated procedures guide.
Do I hold the copyright to my research data?

No. The simplest way to think of the issue is that research data themselves are not copyrightable. Faculty own the copyright in Scholarly Works (defined in SPG 601.28) and have at least some right to use data in Scholarly Works, though the University retains ownership to research data and materials, as described in a prior FAQ. 

More specifically, copyright, a form of intellectual property law, protects original works of authorship including literary, dramatic, musical, and artistic works, such as poetry, novels, movies, songs, computer software, and architecture.  Copyright protects expression, and not ideas, procedures, methods, systems, processes, concepts, principles, or discoveries.  To be protectable by copyright, a work must have “modicum” of creativity, and facts by themselves are not protected by copyright.  Therefore, data, as a collection of facts, is not protected by U.S. copyright law.  Databases as a whole can be protected by copyright as a compilation, as can some manners of presentation of data, but only under certain conditions.  

How long must I keep a copy of my research data?

Per SPG 303.06, Research Data must be stored and curated internally for a minimum of seven years after final closeout of a project or publication of the data, whichever occurs later. Allowable exceptions include when an applicable sponsor or data use agreement, contract, or grant requires a shorter or longer period of time. In rare cases when Research Data storage using available University systems is not possible or becomes cost-prohibitive for the entire seven-year period (e.g., for very large datasets), the Principal Investigator or their delegate must work with their unit and/or Information Technology Services to identify alternative storage or archiving solutions. 

Who will pay for the cost of the research data storage required by this policy?

Paying for the costs of storing research data is shared across the units, research funders (which are increasingly providing funding to the costs of data management) and the university (e.g., through storage solutions provided by Information Technology Services or the U-M Library). If storing data as a condition of the new U-M Research Data Stewardship Policy becomes cost-prohibitive, the Principal Investigator or their delegate must work with their unit and/or Information Technology Services to identify alternative storage or archiving solutions.