Retention schedules and research records: Necessary challenges

This post is the second in a series on research data management presented by the Records Management Roundtable. 

Submitted on behalf of Anita Vannucci, Records Manager at Emory University.

In the fall of 2015, I began a review and update to the research data portion of my institution’s retention schedule. The catalyst for this work came from a campus task force looking at the evolution of research data at academic institutions and anticipating increased interest following the February 2013 White House Office of Science and Technology Policy memo. One recommendation the task force made was to revise the retention schedule.

The 30 series retention schedule was last updated in 2008, long before my arrival. Several challenges became clear when I started my review. Some series were based on federal statutes that had been repealed, or cited code that had no clear connection to the series. Some “series” were actually record types. For clinical records, a records series existed for each stage of research (Phase I, Phase II, Phase III, Phase IV) rather than a single series based on the point the research closed.

I began researching federal and state code, best practices, and the policies of peer institutions. Federal guidance varied from agency to agency, so many of the institutions I surveyed relied on contract language, rather than a centralized retention schedule, to set requirements.

Another challenge was identifying a focus group of subject matter experts. In fiscal year 2015, my institution received 2,923 sponsored awards. While I spoke to people doing research and managing the information created from it, it was impossible to get a representative sample, so I chose to talk to their central monitoring department, the Office of Compliance. It was Compliance who helped me solidify the information I’d gathered into concrete series based on four types of research: behavioral, treatment, FDA-regulated, and non-FDA regulated. Unfortunately, the retention requirements aren’t as straight forward as that finite group of series would lead you to believe.

I began meeting monthly with the deputy chief compliance officer, working through my draft of the schedule. He provided feedback and insight along the way, while I learned about everything from the differences between dangerous drugs and controlled substances to retention requirements around sealed versus non-sealed sponsored study contracts. In the process, we tackled two major challenges:

  1. Can we create big buckets? Risk analysis is a big part of creating a big bucket schedule. We discussed when keeping information longer than required through a simplified schedule posed a greater risk than the value gained by making the schedule easier to use. For example, alleged misconduct investigations involving federally-funded research must be retained for seven years. There’s more flexibility around privately funded research, so in instances where a complaint is determined to be unfounded, there was a desire to dispose of the information sooner. By keeping misconduct investigations of privately-funded research according to the federally-funded requirements, we’d lose the ability to destroy unfounded complaints and retain spurious or potentially libelous information longer than necessary. We decided to settle this issue on a series-by-series basis after considering the volume of records involved and potential risk for each series.
  2. How simple can we make the retention requirement? Retention periods set out in code are rarely simple. (Take a look at 21 CFR 58.195 if you don’t believe me.) We discussed the value of using those retention periods word-for-word versus simplifying and risking the loss of nuances. In this instance, making the schedule user friendly won out. We decided to simplify the language but also link to each citation.

The schedule isn’t quite done yet, but it will be ready to go in time for the launch of a new fiscal year and a new round of awards.

Anita Vannucci

Records Manager

Emory University

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Research data management and University records management: Collaborative crossroads

This post is the first in a series on research data management presented by the Records Management Roundtable. 

One service area of the University Library System (ULS) I was not initially expecting to become involved with when I became University Records Manager at the University of Pittsburgh was research data management (RDM). However, my participation with a ULS specialist track focused on RDM quickly made it clear that this domain is one that records managers throughout higher education should be tuned into.

Research records and data output from various projects, studies, and trials are both created and managed by departments and disciplines across Universities in huge quantities. While RDM may conjure visions of statistical tables, sprawling spreadsheets, and raw computational models, research output is more often a hybrid of record types. Lab notebooks, clinical information and waivers, computational displays, large data sets, XML exports, artifacts, audio-visual materials, proprietary software output, field notes, and grant and administrative materials vary by discipline and format. Thus, records management is a clear fit with other RDM pursuits.

The ULS “tracks”, or groups of specialists, are charged with specific areas of responsibility, such as instructional design or scholarly communications. The ULS’s RDM track evolved out of a working group and over the past year began forming a three-tiered service delivery model for providing RDM resources and outreach to the University research community. Consisting of digital scholarship specialists, a metadata librarian, an archivist, several liaison librarians, and myself, the RDM track’s goal is to provide guidance, resources, and instruction to researchers on how to best manage their records and data throughout the research lifecycle.

The RDM track has tailored resources surrounding some of the following topics: how to create a data management plan using DMPTool; understanding funder mandates; describing your data; choosing sustainable formats; locating data and disciplinary repositories; and open data sharing. Discussion is often framed by communicating the importance of RDM in terms of time, resources, funding agency and publisher mandates, and research integrity.

Service and outreach are conveyed through resources including a Libguide, website, and FAQS which outline service topics; consultations with faculty to better understand their needs; training sessions for ULS staff, academic departments, and research groups; advertisements throughout campus to promote said services; and a series of instructional modules focused on a specific facet of RDM, such as research records and data retention, freely available on the ULS RDM Libguide.

My involvement with the RDM track has raised important questions: where do research records and data management fit into a higher education RM program? Certainly records management principles and policies apply to research records and data. Although somewhat dated, Pitt maintains a Guidelines for Managing Research Data policy on record, in addition to general and financial retention schedules that loosely address such record types.  Furthermore, as a “state-related” University, most research conducted at the University is not subject to state or federal open record laws.

The question of just how effective records management outreach to the research community can be arises. Departments, research groups, and principle investigators often keep their research output close to the chest (read: attribution), storing it on personal websites, databases, external hard drives, or in departmental or personal storage. Management issues, migration and preservation challenges, and open data conundrums crop up. Additionally, the adoption of enterprise software like Electronic Lab Notebooks only increase issues of ownership, management, and preservation of University research content.

Researchers are advised to consider records management at all stages of the research lifecycle:

  • What types and formats of research records will be created?
  • How, and who, will manage those records throughout the course of the project?
  • Is electronic research output being generated in proprietary systems?
  • How can this data be migrated?
  • What are the applicable research records retention periods?
  • What University records retention policies should I be aware of?
  • Where will I deposit research records following the end of my study?
  • How will I preserve these records over time?

The RDM track’s mission provides the perfect platform for spotlighting how records management practices can and should positively support research data management in the research community at Pitt. As the RDM track moves forward with faculty consultations this summer, I’m interested to learn the ways (and formats) in which researchers are creating records, where they are being stored, what oversight and policies are governing their work, and how they perceive University records management affecting their workflows.

I’ll be working to determine the volume of research records – along with type and importance –that departments and research teams store at the University’s off-site storage vendor, examining how and when content should be exported from ELN’s and deposited or stored elsewhere, and potentially attempting to embed myself with a research group for a term to understand their methods, workflows, and records management considerations.

Records managers in higher education should definitely be engaged with the research community at their respective institutions. However, with limited time and resources (there is one of me!), it’s often difficult to consistently and successfully engage stakeholders. Finding collaborative commonalities with other service providers and information professionals, like the RDM track, is one way to make a records management program more visible to the research community.

Alex J. Toner

University Records Manager

University of Pittsburgh

Research Data Managment: A Scheduled Series

Research records and data output are proliferating at institutions of higher education around the world. What implications does this have for records management programs? How can university records managers and archivists position themselves as effective resources for the research community? What about the retention of and access to the research record themselves?

The Records Management Roundtable hopes to foster a dialogue on the topic through a series of research data management themed posts. Over the next four weeks The Schedule will feature posts describing collaborative efforts to address research data management, resources and outreach initiatives, incorporating research records into a retention schedule, and the question of faculty research as a public record.

We encourage comments on the posts as well as further discussion at the upcoming SAA annual conference in Atlanta. Finally, if you’re involved in research data management at your institution, we would love to hear about it on The Schedule!

– Records Management Roundtable