Policy pre-amble

Through the 2013 memo from the Office of Science and Technology Policy, US federal funders were directed to institute policies to make broadly available with the fewest possible restrictions data, code and other research outputs. In alignment with these public access mandates, as well as commitments from ABOR universities towards the open access of scholarly articles, ABOR is committed to increasing access to research data for the people of Arizona and the world. Separately, ABOR recognizes that good data stewardship is needed not only to support these efforts, but also for compliance with data retention and security regulations. ABOR requires Arizona’s public universities to create and implement the necessary local processes and standards to effectively govern research data, as defined in this policy.

Each institution shall:

Designate an appropriate office responsible for the policy (e.g., the research office, office of the vice-president for research, etc.). The responsible office will designate an advisory group consisting of at least the institutional units/offices ultimately responsible for supporting compliance with this policy. The advisory group will develop and review the policy in consultation with other relevant stakeholders at an interval of no more than 3 years.
1. Build upon or reference existing policies and regulations where possible (e.g. The ABOR Intellectual Property Policy, institutional data retention policies, etc.)
1. Aim to ensure robust, trustworthy, and ethical data stewardship practices while fostering a culture that encourages and guides researchers toward making data “as open as possible and as closed as necessary.”
1. Implement mechanisms (e.g. data management plans, process controls) that allow tracking compliance with the policy to the extent that is practicable.

Comments received

Tracking compliance and and enfocement of the policy are quite different. What is done when there is not compliance?

this is all very bureaucratic and legalistic, which is a start. But what does it mean in practice?

ABOR is proposing a lot but is not dedicating funding. It is also citing a 10-year-old policy. Update with newer references.

Funding should be made available to assist in offsetting Open access costs.

Often these types of policies are devised when thinking solely of quantitative data. My concern is that often policies that are crafted do not recognize the sensitive nature of qualitative data and the ease with which respondents (for example, in interview data) can be easily identified if this data is collected. Often these policies seem to exist without any recognition of the IRB process.

The lawyers have overdone themselves. This section is obvious, and does not need to be in the “plan.” It is an implementation procedure and not part of the data retention plan.

I collect data for “a project” but often go back and reanalyzed the same data set using a new theoretical framework or with a different focus. Sometimes I work with data older than 10 years. While there is a chance that I do such reanalysis, I do not want to make the data public because someone else can do a similar analysis and publish using my data. Under this policy, at what point do I have to make the data publically available? When the data collection completes? When I publish the first article based on data? When I am all done with the data (i.e., finish publishing all I think i can publish based on data, which may be never)?