Does the 7 year retention requirement apply to documents subject to IRB destruction or de-identification mandates?

IRB destruction or de-identification mandates take precedence over the University’s data retention requirements for Research Data and Materials.  When considering proposed study protocols or amendments thereto, IRBs may direct investigators to destroy Research Data and Materials that identify research participants in order to safeguard the anonymity of the participants.  Such destruction of records may, for example, be indicated in some survey research, in which there may be no need to retain participant identities.  In such cases, investigators should, in the first instance, adhere to any information or document destruction procedures contained in an IRB-approved protocol, and respect this policy and the GRS schedule in regard to all other Research Records.

See also: Data Retention