Printed on: 05/20/2018. Please go to http://policy.umn.edu for the most current version of the Policy or related document.

ADMINISTRATIVE PROCEDURE

Transferring Research Data

Transferring Research Data refers to the process of moving data to and from another organization in cases where a PI leaves or joins the University or the PI responsibility of a project is moved to or from another institution. It does not refer to the common practice of sharing research data or their products with collaborators or other researchers as part of the normal scientific or scholarly process of conducting research, which may require other agreements, such as the Data Use Agreement for protected health information or Material Transfer Agreements to protect intellectual property rights.

In cases where a PI leaves or joins the University or a project is moved to or from another institution, the PI may request that a copy of the research data be transferred. This procedure provides the details on how to request a transfer.

Requesting a Transfer of Research Data

Unless prohibited by specific terms of the sponsorship, other agreements, or University policy, a PI may request transferring a copy of research data to or from a legal entity outside of the University of Minnesota. The request must be initiated by the PI. Unless specifically agreed upon by both the sending and the receiving organization, it is understood that the primary research data will be retained at the organization that transfers the research data, and only a copy of the research data will be transferred.

The University will reserve the right to continued ownership of University-owned research data when a copy of the research data is sent to a different organization, and will acknowledge the right of an organization to ownership of research data when the University receives a copy of the research data from that organization. If the University selects to continue ownership of the data after the PI left the University, the college where the PI resided must designate a person responsible for preserving the data and destroying the data at the agreed-upon time.

If the data were acquired through a sponsored project and the administering unit of the project is different from the college where the PI resided, the administering unit is responsible for designating a person to preserve the data and destroy the data at the agreed-upon time. If the research data are part of a sponsored project that is being transferred and the transfer agreement addresses the transfer of a copy of the research data, no further written agreements will be required.

In all other cases, a PI must contact the dean of the college or school or the chancellor of the system campus, wherever the administering unit for the project of the research data under consideration is located. The dean of the college or school or the chancellor of the system campus, or their designee, has the authority to decide whether a written approval is required.
In addition, it is the responsibility of the PI to obtain any other authorization that is required to transfer the research data, for instance, if the research data are owned by a consortium.

Human Subject Research Requirements

If research data about human subjects that is identifiable is proposed to be transferred, the PI must notify the Institutional Review Board (IRB) and obtain authorization for transfer from IRB prior to the transfer.

How to Submit a Written Request to Send a Copy of Research Data to a Different Organization

If written approval is required to send a copy of research data to a different organization, the PI must obtain in writing an agreement with the receiving organization prior to seeking approval from the University of Minnesota. This agreement must contain, at a minimum, the following items:

  • adoption by the receiving organization of all custodial responsibilities for the research data, including acceptance of all University of Minnesota and federal security requirements for restricted data that is transferred; and
  • formal recognition of University of Minnesota's continued ownership of the research data by the receiving organization.

Once the agreement with the receiving organization is obtained, the PI requests in writing the transfer of a copy of the research data to the receiving organization from the appropriate dean of the college or school or chancellor of the system campus. The dean of the college or school or the chancellor of the system campus, or their designee, must then inform and seek consent from:    

  • other colleges, schools, or system campuses that were involved in the generation of the research data;
  • the Vice President for Health Sciences if the research data are health related; and
  • the Associate Vice President for Sponsored Projects Administration if the research data were generated as part of a sponsored project, unless the research data are part of a sponsored project that is being transferred and the transfer agreement already addresses the transfer of research data.

The PI must provide the reason for transferring the research data and include the written agreement from the receiving organization when submitting the request. The PI must also provide a contact at the receiving organization.

How to Submit a Written Request to Receive a Copy from a Different Organization

If written approval is required to receive a copy of research data from a different organization, the PI must obtain in writing an agreement with the sending organization that clarifies the expectations of the University of Minnesota's custodial and other responsibilities with respect to the research data prior to seeking approval to transfer a copy of the research data from a different organization to the University of Minnesota.

Once the agreement with the sending organization is obtained, the PI requests the transfer of a copy of research data from the sending organization in writing from the dean of the college or school or the chancellor of the system campus where the administering unit for the project of the data under consideration will be. The dean of the college or school or the chancellor of the system campus must inform and seek consent from

  • the Vice President for Health Sciences if the research data are health related; and
  • the Associate Vice President for Sponsored Projects Administration if the research data are part of a sponsored project that is transferred to the University of Minnesota, unless the transfer agreement of the sponsored project already addresses the transfer of research data.

The PI must provide the reason for transferring the research data and include the written agreement from the sending organization when submitting the request. The PI must also provide a contact at the sending organization.

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