Data Retention

Must all Research Records be stored on-campus to ensure University access?

In some cases, as in research that is collaborative with other institutions, electronic or other Research Records may be compiled, stored or maintained outside of Harvard systems as a requirement of receiving research funding.  It is important in these circumstances, as in other circumstances in which there is a compelling need to store Research Records outside of Harvard systems, that subcontracts, subawards and vendor agreements entered into for such research contain provisions that incorporate a reference to the Principles and FAQs and require adherence to the same, thus assuring...

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How must Research Records be stored?

Research Records normally should be maintained in the office, laboratory or department where they are created and used, or otherwise on University premises or in electronic computing systems maintained by the University[1].  Principal Investigators and other University faculty and staff who lead or administer research projects are responsible for maintaining an orderly system for recording, retaining, accessing, and storing their Research Records, and for communicating such systems and their proper use and access to the members of their research teams and other appropriate...

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How should Research Records be handled after the specified period of retention expires?

Before destroying Research Records, researchers should check the GRS for retention guidelines for administrative, financial and human resources records and consider, among other things, whether Research Records need to be retained for additional scientific or scholarly activities, whether Research Records may be needed for establishing or defending intellectual property rights, whether the Research Records may have significant future scientific or academic value, and/or whether the Research Records may have value as historical sources, including for the history of science...

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Does the 7 year retention requirement apply to confidential or third-party data subject to data use agreements that require return or destruction of data prior to the expiration of the retention period?

The terms of any data use agreement[1] for confidential or third-party data take precedence over the University’s data retention requirements. 


[1] Please note that all DUAs must be reviewed by a School’s IRB, School Security Officer and relevant Sponsored Programs Administrator (or School officials to whom this responsibility has been delegated by the cognizant  Sponsored Programs Administrator) before the DUA may be accepted and signed by the Office of Sponsored Programs, the HMS Sponsored Programs Administrator or the HSPH Sponsored Programs...

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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...

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What if the research involving children or individuals with mental incapacity is minimal risk?

Some research with children or persons with mental incapacity may be very low risk, and in those cases, the cost of retaining all Research Data and Materials for such an extended period may outweigh any theoretical  legal benefit.  In considering whether and to what extent to retain Research Data and Materials in these studies, PIs should consider the nature and intensity of research interventions and the possibility of research-related harm to subjects, presumably deciding to honor an extended retention period in cases in which such interventions are more intense, complex and/or...

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Is a longer retention period required for research involving children or individuals with mental incapacity as subjects?

A longer retention period is recommended if the research involves children or individuals with mental incapacity as subjects. PIs should consider retaining Research Data and Materials pertaining to such subjects at least until seven years after pediatric subjects have reached the age of majority or seven years after any mental incapacity has been removed. See e.g., M.G.L., c. 260 s. 7. During minority and/ or periods of mental incapacity, statutes of limitations are commonly tolled, allowing these persons, when they attain majority or capacity to file any legal claims for a period of up to...

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Are there any circumstances in which research records and data must be retained for longer than seven years?

Researchers and others may be required by the University, School or department to retain Research Records beyond the seven-year period in certain circumstances, for example:

  • In order to preserve or protect any intellectual property resulting from the research work, such as when the work is the subject of patent applications;
  • As required by an external governmental or other funding source or sponsor; or if needed in connection with pending or reasonably anticipated litigation and other proceedings related to the sponsored research, such as fact-finding for research...
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