Research data retention and disposal

In accordance with the Australian Code for the Responsible Conduct of Research and UOW’s Research Data Management Policy, researchers must decide whether to retain, archive, and/or dispose of their research data with the following considerations in mind:

• Compliance with relevant legislation, policies and guidelines;
• Existing agreements with funders, collaborators or in ethics protocols;
• Longevity and reuse of the data including facilitating access (where appropriate);
• Optimal use of storage resources (we should only retain what we must/need); and
• Research data records or “metadata” must be clear, accurate, secure and complete, to maintain transparency and reproducibility of results.

Please refer to the Information Sheet for Research Retention Requirements for information on retention periods for various types of data. Contact the Information Compliance Unit for further advice.

Data may be retained in the short term for transparency or compliance, ethical, legislative and contractual requirements prior to archiving. It may also be retained when there is a secondary use or a potential for re-use (in accordance with approved ethics protocols). This type of data is sometimes referred to as “active” or “working” data.

For example, researchers may have conducted a clinical trial and need to keep the data as per the ethical requirements for the research. However, they may also revisit the data at a future date if participants have consented to do so and conduct secondary analyses to answer additional questions.

• Original trial: doi: 10.1038/ejcn.2014.39
• Secondary use of data: doi: 10.1038/ejcn.2015.45 

“Completed” data should be archived for longevity and permanency to ensure compliance with legislative, ethical or contractual obligations including the FAIR principles and to enable research and conclusions to be reproducible over the long term. This type of data may remain untouched for many years.

For example, Indigenous data may need to be retained indefinitely according to Indigenous Data Sovereignty arrangements. Indigenous data refers to information, in any format, that is about Indigenous Peoples, knowledge systems, customs, resources or territories or that impacts Indigenous lives at the collective and/or individual level. Indigenous Data Sovereignty is the right of Indigenous Peoples to own, control, access and possess data that derive from them, and which pertain to their members, knowledge systems, customs, resources or territories.

In another example, atmospheric chemistry researchers at UOW maintain long-term records of measurements of atmospheric composition, which cannot be re-collected, as the state of the environment continually changes. As analysis techniques improve, the archived data can also be re-analysed to provide better data and new understanding. E.g. data that contribute to the Total Carbon Column Observing Network, where there are new data releases from the same primary data, reflecting methodological and analysis developments:

• Original Version (2014)
• Updated version 2020
  
  

Once the compliance obligations for the retention of data have been met (e.g. State Records, Ethics, commercial, funding obligations), disposal of the data must be considered, to:

1. meet any associated obligations and/or
2. minimise unnecessary storage and/or
3. reduce risks associated with over-retention of data such as potential unauthorised access, loss or disclosure.

In accordance with privacy laws, an individual’s personal or health information must not be kept if it is no longer required for the purpose for which it was collected and used.

For example, a research project involving collection and handling of personal information is usually accompanied by a notice to the individual explaining the purpose of the collection and use and the retention period. Once that purpose has been met and associated retention periods have been satisfied, the University has an obligation to dispose of the personal or health information. Where data may have ongoing value, consideration must be given to removing identifiers unless participants have provided consent for their data to be used for subsequent analysis (this should be considered at the point of initial collection - refer to UOW Human Ethics for further information).

Due to costs and storage capacity limitations, consider disposing of data where there is no compliance or business need to retain. 

Researchers complete a Research Data Management Plan (RDMP) at the start of a research project using ReDBox. The system prompts the researcher to consider what will happen with research data in the long-term requiring the researcher to think through the considerations.

Researchers should review their RDMP regularly and update the details if anything changes. During the project, researchers should consider long term re-use, reproducibility, replicability and interoperability and ensure intuitive file naming and file organisation practices. The Good Data Practices resource from the ARDC and the Research Data Management Guidelines provide useful information.  

At the end of a project there can be both published and unpublished research datasets.

Published research data is stored in repositories for datasets. In a repository, the datasets can be made open access or have mediated access with permission from the researcher and with ethical approval. These have a DOI associated with them which is included in the research output.

Researchers should consider the below in relation to publishing data:

• Publishing data in a data repository. Further information can be found in the Library Guide and in UOW’s Open Access Principles
• Prior to publishing data openly consider the points outlined in “What to consider when evaluating and archiving research data”.
• Update the associated RDMP with DOI
• Certain classifications of data are not published as outlined in the Data Governance Procedure. Where the classification of data prevents the data from being published, metadata (that is, data held within the RDMP which describes the data – where it is stored and who has access) should be published.
• The metadata for non-digital data can be also published. For non-digital data an RDMP can be created which holds information describing the non-digital data (for example: where it is stored and how to access)

Unpublished research data (“active” or “working” data and analysed datasets) that are to be retained or archived:

• Must be stored in UOW supported research data storage platforms as outlined in the Research Data Management Policy and Guidelines.
• The Research Data Management Plan must be updated with information on how long it will be retained or archived. Please refer to the UOW Information Sheet Research Retention Requirements (Intranet only – students to contact supervisors to download this document).

Any research data that is to be disposed of must have a disposal record created using this ICU Records Disposal form  (Intranet only – students to contact supervisors to download this document).

When a researcher archives or retains research data the Research Data Management Plan (RDMP) is updated with a date of review. At the time of review, researchers should consider if disposal or extended archiving or retention is required. The extended date should be updated in the RDMP.

It is important to update any changes in the RDMP. For example: when the research data custodian is leaving, or if the storage location changes.

If the research data will continue to be used after departure from UOW, (including by students graduating, transferring or withdrawing from their course):

• UOW retains the master copy of research data
• To access the research data external collaborative access can be set up or the researcher can take a copy of the data. If taking a copy of the research data, you must ensure that an equivalent or higher level of security is in place in the new storage location. The metadata record in your RDMP must be updated to indicate if data is moved or copied or the access has changed (i.e.: if external access is in place). Please refer to the Research Data Management Policy and Guidelines for further information.
• A UOW custodian for the research data must be nominated in the RDMP. The custodian should be the supervisor(s) or another UOW researcher (e.g. the Associate Dean of Research (ADR) or Head of School for a researcher). Refer to the Research Data Management Policy and Authorship Policy for further information.
• As per the Research Data Management Policy and Authorship Policy, prior to departing UOW, supervisors and students should discuss the ongoing reuse potential of the research data. Discussions should be documented in writing and maintained on the project file.

UOW’s policies and procedures have been designed to consider legislative, ethical and contractual obligations as well as what is deemed to be responsible research practice.

The most relevant UOW policies and procedures providing statements and direction on archiving, retention and disposal of research data include:

• Code of Practice – Responsible Conduct of Research - provides an overarching framework for research integrity at the University to ensure trust and confidence in the quality of its research outputs
• Research Data Management Policy - explains the University’s expectations in relation to the collection and management of research data and primary materials
• Research Data Management Guidelines - supports the practical implementation of the Research Data Management Policy and sets out a framework for best practice research data management
• Data Governance Procedure - Helps define the classification of research data
• Intellectual Property Policy - presents the definitions, principles and practices for the ownership and management of IP by UOW
• Records Management Policy - sets out UOW’s obligations under recordkeeping legislation ie. the NSW State Records Act 1998
• Privacy Policy- sets out UOW’s obligations under privacy legislation ie. the NSW Privacy and Personal Information Protection Act 1998 and the Health Records and Information Privacy Act 2002. It also covers obligations under the Cth Privacy Act, as it applies to UOW in specific circumstances
• Data Breach Policy – sets out UOW’s obligations under the NSW Privacy and Personal Information Protection Act 1998 in response to a data breach involving personal information
• Authorship Policy - outlines the principles for determining authorship of research publications  undertaken at UOW

• ICU forms - visit the ICU Resource library for details about retention rules, information sheets relating to privacy and information management
• Library guides
• Ethics guides
• Retention, Archiving and Disposal Checklist (DOCX: 132 KB)
• Legislation

• Australian Research Data Commons (ARDC) resources