What are the differences in requirements between Cornell University and the new NIH Data Management and Sharing Policies?
NIH policy requirements:
The NIH policy requires investigators to share any scientific data to replicate or validate findings.
These do NOT include the following:
NIH recommens keeping data at least three years after grant closeout, but this is different for a contract. The data should include methodology and procedures (including software) used to collect data, data labels, definitions of the variables, and any other information to reproduce and understand the data. NIH also advise the use of naming conventions resulting in unique identifiers, favor the use of Common Data Elements, and suggest advance thought about data storage format and its impact on the research budget, about version control, and the back-up of generated data.
Cornell University policy requirements:
The CU policy requires investigators to record the location of the following data in WIDRR:
IMPORTANT: to be compliant with the CU policy, investigators must retain any data that cannot be shared in WIDRR. For data that need to be shared according to NIH policy and according to submitted DMP plans, investigators should use a NIH-approved repository and create a record in WIDRR to indicate the location of their dataset.
If I have followed the steps above, have I complied with the NIH data sharing policy effective January 25, 2023?
Yes for publications and grant close-outs if your data is in a repository that supports sharing.
But, for those who want to initiate grants after January 25, 2023, you must also a Data Management and Sharing (DMS) plan.
Please remember the term Scientific Data is defined in the NIH policy as "The recorded factual material commonly accepted in the scientific community as of sufficient quality to validate and replicate research findings, regardless of whether the data are used to support scholarly publications. Scientific data do not include laboratory notebooks, preliminary analyses, completed case report forms, drafts of scientific papers, plans for future research, peer reviews, communications with colleagues, or physical objects, such as laboratory specimens."
Where should I deposit my data? Which data repository should I use?
Remember that any repositories you choose must also be able to share your data.
1. Does your funding agency or your journal require you to use a specified data repository?
Yes: Deposit data in the specified repository
No: Do researchers who work with similar data share their data in a specific repository?
Yes: Deposit in the repository used by your research community
No: Contact the Wood Library for guidance on using a generalist repository. You can also use this NIH resource to help you choose an appropriate repository: NIH-Supported Data Sharing Resources.
Please remember: Once the data are deposited in a repository (that allows sharing if the data need to be shared), do not forget to create a record in the data retention tool to indicate the location of your dataset(s).
Creating a record of data retention in WIDRR alone without depositing data in a NIH-recommended repository will not meet the NIH sharing requirements for dataset(s) that need to be shared.
If data are removed from the public repository, this will jeopardize compliance with both NIH and Cornell University policies. Any changes in data deposition must be versioned.
How long does the CU Policy require that I retain my data?
According to CU policy, when do I have to create a WCM Institutional Data Repository for Research (WIDRR) entry for my data?
1. Are your research data referenced in a publication?
Yes: Create a data retention record in the data retention tool upon publication (60 days after publication at the latest)
No: No action required
2. Are your research data a result of a grant that has just ended?
Yes: Create a record for your dataset in the data retention tool after grant closure (60 days after closure at the latest)
No: No action required
3. Are you leaving WCM or retiring?
Yes: Create a record for your dataset in the data retention tool before leaving (60 days before departure at the latest)
No: No action required
Who is the custodian of the research data and responsible for answering the following questions?
The Principal Investigator.
The Cornell University Policy 4.21 on Research Data Retention specifies that principal investigators are the custodians of their research data and responsible for the proper use, access, security, and control of any research data under their management or supervision, including the data used in scholarly publications or presentations.
As described by the National Institute of Standards and Technology (NIST), “it is widely recognized that data, specifically research data, are of growing importance and impact to the economy and society”. The NIST diagram below illustrates the stages of the data lifecycle – from planning to managing to retaining & archiving.
What is the start date of the DMS Policy?
The DMS Policy applies to proposals submitted on or after January 25, 2023.
For contract implementation, the NIH Document Generation System (DGS) language regarding the policy shall be included in all solicitations released as of July 1, 2022, with an original proposal receipt date of January 25, 2023, or after. The Policy will not apply to solicitation amendments that result in proposal receipt extensions resulting in proposal submission to NIH on or after January 25, 2023 or beyond.
The NIH Data Sharing Policy, dated February 26, 2003, will remain applicable to proposals received prior to January 25, 2023, and contracts resulting from those proposals.
Adapted from: NIH DMS Plan FAQ
