Q. Do electronic computerized documents about research projects and electronic research data also have the same retention expectations as paper?
1. For purposes of complying with the policy, do electronic computerized documents about research projects and electronic research data also have the same retention expectations? Or can (or should) the electronic research records be deleted earlier?
2. For compliance with the general retention policy and IRB requirements, does the time after the active period begin a) when project work is actually completed, or b) when the IRB protocol expires (i.e., is terminated)?
3. Scenario: My protocol ended in 2009. But I still have some applicable files. Do I delete them now as dictated by the policy in effect in 2009? Or should I, if possible, retain them until 2017?
The media on which records are created and/or stored does not determine how long that they must be kept. It is the nature of the information contained in the records that drives the retention period. That being said sometimes in research raw data is transformed and the analysis is made upon the transformed data. As such the original data was transient and it is the transformed data that is required to be maintained. Further, several of the federal funding agencies—NSF and NIH among them—now require a data management plan and the ability to share the data which may be another reason to maintain the electronic data.
The retention period “Active” ends when the project is complete and starts the “clock ticking” on the final eight years of retention.