May Research Records be transferred to a new institution upon the departure of a Principal Investigator?

The Principles and this guidance are not intended to alter Harvard’s longstanding institutional practice of assisting, within reasonable parameters, faculty who wish to move from Harvard and to continue ongoing scholarship and research at another   academic institution.  However, other institutional values also must be respected, even as Schools and the University seek to facilitate the transition of a departing faculty member’s ongoing research and scholarship.  For example, when Principal  Investigators who have been or are involved in sponsored research leave Harvard, Schools should have a process that allows the departing PI to take with him or her aliquots of specimens and/or copies of Research Data and Materials that  the PI has gathered or produced, as long as:  (1) when appropriate, originals of the relevant Research Data and Materials remain at Harvard, (2) the removal of aliquots or copies of Research Data and Materials does not conflict with Harvard’s Intellectual Property Policy, (3) the removal of aliquots or copies does not  harm the integrity of an ongoing collaborative research project, or (4) the removal of aliquots or copies does not contravene agreements between Harvard and third parties.  In most cases, conflicts can be avoided simply through the renegotiation of agreements transferring institutional responsibilities to the new institution. [1]  It is the responsibility of the Schools to develop an exit process  through which a School can  sort through what research records and materials, if any, must be retained on-campus as originals or copies, taking into account the needs and rights of those researchers who remain at the University, the need to maintain the integrity of any ongoing research, and the need to comply with sponsored research terms and conditions, as well as the needs of the departing Principal Investigator to continue his or her research.  This process should be developed by each School , in consultation with faculty members and the Office for Technology Development.

Research Records that are not Research Data and Materials, such as financial, administrative and human resource records, may not be removed from Harvard, either in original form or as copies.

[1] For example, if a PI wishes to take a biological material that had been obtained from a third party under a material transfer agreement (MTA), the Office of Technology Development can assist in terminating the existing MTA and informing the new institution of its need to enter into a new MTA with the provider of the material. 

See also: Data Retention