Undergraduate and Taught Postgraduate Programmes - Research Assignments Data Retention Guidance

Section 8.9 of UCC’s Code of Research Conduct states: “the University expects data and records to be stored securely for a minimum period of ten years after the completion of a research project, in line with general audit requirements, as well as any additional retention requirements”.

A footnote to this statement adds the following: “Outputs from undergraduate research projects and taught postgraduate programmes are generally considered as assessment records for records management purposes and, subject to review by the relevant Programme Director/Supervisor/PI, may be retained for a shorter period”.

The Research Records Guidance states that where “records are created primarily for pedagogical and assessment purposes and not as part of a programme of research in the university” they can be “regarded as subject to the same retention and disposal requirements as assessment records”. This retention period is 13 months with some exceptions which are detailed in the Research Records Guidance.

When considering how this guidance relates to undergraduate and taught postgraduate modules with research components, the following should be taken into account:

• In many cases students own the data they generate during their research projects and can only be requested to submit the data; see Annex C of the Intellectual Property Policy.
• Not all student research projects require the submission of the underlying data for assessment purposes. If data has not been submitted in the past and unless the data is needed for assessment purposes, there is no need to request the data from students, rather they can be advised on how to store their data safely until they delete it. Where the research data includes personal data, this should be done in accordance with the principles of the EU General Data Protection Regulation as set out in UCC’s Data Protection Policy.
• Data submitted by the students could be limited to what is required to assess the research project. For instance, it need not include all the records of the research such as un-anonymised raw data or research records such as signed consent forms if this is analogous to the data required for examination.
• Students should be advised on best practice in data retention and deletion of their own research data and records in line with the Research Records Guidance.
• Prior to the conduct of the research, students should be advised on the inclusion of information about data retention and deletion in recruitment leaflets / posters and information sheets, consent forms, etc.
• During active research, students should be advised on best practice in active data management and storage.
• All students engaging in a research project should be encouraged to devise and implement a data management plan from the outset of the project. Information used to recruit research participants, information sheets, consent forms etc. should be informed by the data management plan. For instance, research participants need to know what data is being gathered and how it is being gathered; for what purpose; how it will be safely stored and for how long, before it will be deleted. The data management template recommended by the Research Data Service in UCC Library is the Science Europe Guidelines.
• For advice on incorporating research data management information and principles into your module content or student research projects please contact the Research Data Service in UCC Library or Research Data Coordinator aoife.coffey@ucc.ie. A Canvas unit on research data management plans is available for import into your own modules.
• If one of the exceptions detailed in the Research Records Guidance applies, this should be discussed and agreed with the student at the earliest opportunity. Arrangements should be agreed with the student on the retention of the data post-project. Also see the UCC Code of Research Conduct Clause 8 and consider consulting the Research Data Service in this instance.

Here are some examples of how the retention of student research data can be administered in line with the Research Records Guidance for undergraduate and taught postgraduate students. This list is not exhaustive and module coordinators, departments, schools or units may already have alternative solutions in place that comply with relevant UCC policies and guidance:

• If the data collected is not required for assessment purposes or to verify that the work has been carried out by the student, then it is not necessary to request the student submit it. The student [as the owner of the data] agrees to safely store the data for the required data retention period and takes responsibility to destroy the data when the data retention period expires.
• Data can be added as an appendix to the student’s thesis submission through Canvas. Data is retained within Canvas along with the thesis. If Turnitin is used, this means data will be retained along with the thesis by Turnitin indefinitely.
• Data can be submitted as a separate file in parallel to the thesis submission through Canvas. Data is retained within Canvas and can be deleted, once the 13-month retention period has expired.
• Alternatively, student data can be collected by module coordinators, departments, or schools and stored in Teams (SharePoint), SharePoint or Google Drive under the UCC tenancy and deleted once the 13- month retention period has expired.
• If one of the exceptions applies to the data produced by a student and the longer retention period of 10 years applies, then the PI or supervisor should in discussion with the student agree on how the data is to be retained and maintain a record of the agreement. See section 2 the Research Records Guidance document and the UCC Code of Research Conduct.

In this instance if required, advice can be sought from the Research Data Service and the Research Data Coordinator aoife.coffey@ucc.ie.