Introduction
This article provides guidance on data retention and answers some of the frequently asked questions related to the migration activities.
This guidance is general information and does not replace project-specific sponsor, IRB, contractual, legal, regulatory, or records-retention requirements.
Frequently Asked Question(s)
1. Where should I store the data?
Virginia Tech Policy 2000, Management of University Records requires that one copy of the research data be designated and maintained as the ‘official copy of record’. The storage location must provide protections appropriate to the data’s risk classification and any sponsor, contractual, legal, or regulatory requirements. Per Policy 13015, Ownership and Control of Research Data, Results, and Related Materials, Virginia Tech owns the research data, and the PI is responsible for knowing where the official copy of record is stored and ensuring that it is stored securely.
Possible secure storage locations include, but aren’t limited to:
- A VT-managed SharePoint site configured with appropriate access controls;
- A secure department server with protections appropriate to the data; or
- Qualtrics, when the project is being migrated and Qualtrics is an appropriate system for the data.
Additional working or convenience copies may be retained as needed, but they should not be treated as the official copy of record. Do not rely on the retiring survey platform, an individual account, a personal device, or an individual researcher’s email as the only copy.
Department IT teams and the Privacy and Research Data Protection Program (prdp@vt.edu) are available to answer questions about resources for securely storing research data.
Virginia Tech Standards for securing data:
2. How long should I retain the data?
As a baseline, retain the official copy of record for five years after the last action, in accordance with the Library of Virginia GS-111 Records Retention Schedule.
A longer retention period may be required based on sponsor requirements, applicable laws or regulations, publication or repository requirements, or intellectual-property considerations. When multiple requirements apply, retain the official copy of record for the longest applicable period.
Convenience copies of the data are not subject to the standard retention period for the official copy of record and may be deleted when they are no longer needed, provided they are not subject to a legal hold or other preservation requirement.
3. Should I delete research records when I leave Virginia Tech?
Do not delete the official copy of record of research data or supporting documentation. Before deleting local files, or other copies, confirm that the official copy of record has been transferred to an approved university storage location, that the PI or designated data steward can access it, and that all applicable retention, confidentiality, contractual, and preservation requirements have been addressed.
After an authorized official copy of record is preserved, routine duplicate or transitory copies may be deleted when they are no longer needed and are not subject to a legal hold or other preservation requirement. Do not retain university research data in personal accounts or unmanaged local storage after departure.
When a researcher leaves Virginia Tech, ownership and stewardship responsibilities remain with the university. The departing PI and department should ensure that research data and necessary supporting materials remain accessible to the assigned data steward that remains at Virginia Tech.
To transfer the ownership of a survey from a departing PI/Survey owner to someone else at the university, please use the following RITM to create a request:
4. Whom should I contact with questions?
Questions about research data retention, stewardship, or disposition may be directed to the Privacy and Research Data Protection Program at prdp@vt.edu.
Questions involving a legal hold, litigation, an investigation, an audit, or a public-records request should be directed to the Office of University Legal Counsel before data are deleted or transferred.
For migration, export, or Qualtrics access questions, contact the survey platform team using the following RITM: Survey Platform (Qualtrics)