EPSRC’s Policy Framework on Research Data Management, published in 2011, takes formal effect from 1 May 2015. It has stimulated a significant level of activity across the sector since it was launched, as well as some concerns. This session will explore what the policy means in practice and provide an opportunity to ask questions within the wider context of the evolving Open Data landscape.
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UKSG Conference 2015 - EPSRC research data management requirements Ben Ryan EPSRC
1. Engineering and Physical Sciences Research Council
Research Data Management
ENGINEERING AND PHYSICAL SCIENCES RESEARCH COUNCIL
Ben Ryan
Senior Manager, Research Outcomes
2. Underpinning Philosophy
Data is a critical output of the research process
which should be shared:
to reinforce the integrity, transparency and
robustness of the research record
to increase its potential value through aggregation
to enable new research questions to be addressed
to support the wider exploitation of data
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3. RCUK Principles – an overview
Research Data…
o is a Public Good – to be made available responsibly
o has long-term value – the need for preservation
o should be Discoverable and Citeable
o is subject to legitimate constraints – it cannot all be shared
equally
Researchers should have a period of privileged access to ‘their’
data
Data users should cite their sources – and abide by terms of
access!
The Bottom Line: looking after and sharing research data is…
part of the research process
a legitimate use of research budgets
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5. Some bizzare comments…
“The nature of my work is such that it generates no data that
doesn't end up in my papers, so I'm unlikely to know about these
policies.”
“This is irrelevant to me. I deal with no sensitive data.”
“As I do not work with empirical data I am not affected by RDM.”
“I am on the point of retiring so taking less interest in these things”
“RDM sounds like a gigantic waste of time and I intend to spend
as little time on it as possible”
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6. How EPSRC Policy affects…
Research Organisations
Research Organisations have primary responsibility for ensuring that
researchers manage their data effectively.
They need established infrastructure and processes to ensure:
retained EPSRC-funded research data preserved for a minimum of 10-yrs
effective data curation provided throughout full data lifecycle
knowledge of publicly-funded research data holdings
discoverability; recording of 3rd party access requests
notice/ justification of access restrictions, e.g. ‘commercially confidential’
awareness/use of relevant law e.g. FOI
awareness/compliance with research data policies
adequate RDM resource allocation (e.g. from QR/Research Grants)
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7. How EPSRC Policy affects…
Researchers/Grant-holders
They have a responsibility to understand - and adhere to - EPSRC’s
principles and expectations for research data management. They should:
make EPSRC-funded research data freely/openly available with as few
restrictions as possible
comply with the RDM policies of their Research Organisation
have project specific RDM plans in place
have appropriate agreements, if relevant, with collaborators
ensure published research describes how to access supporting data
(also a requirement of the RCUK Policy on Open Access)
be aware/make use of relevant legislation and available exemptions as
needed to justify withholding research data
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8. How EPSRC Policy affects…
Non-Academic Partners
Non-Academic Partners in research collaborations need to be aware of:
the general principle - publicly-funded research data is expected to be
made freely and openly available with as few restrictions as possible
the relevant legal requirements such as the Freedom of Information Acts
the need to ensure issues of data ownership, confidentiality etc. are
adequately addressed in RDM plans and collaboration agreements -
before the start of a collaborative research project!
Data sharing agreements may be appropriate
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10. Clarifications
Expectation I
Research organisations will promote internal awareness of these principles
and expectations and ensure that their researchers and research students have
a general awareness of the regulatory environment and of the available
exemptions which may be used, should the need arise, to justify the withholding
of research data;
What we mean…
Promoting internal awareness is expected to be an on-going part of ‘business
as usual’ induction and refresher training
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Expectation II
Published research papers should include a short statement describing how
and on what terms any supporting research data may be accessed.
What we mean…
• Consistent with the RCUK policy on Open Access
• Applies to all papers which acknowledge EPSRC funding and are published
after 1
st
May 2015.
• Doesn’t apply to research papers which are not supported by research data
(e.g. pure maths…?)
• We rely on researchers making informed judgements!
• Can be satisfied by including persistent links (URLs) to the data (or to data
documentation)
12. Expectation III
Each research organisation will have specific policies and associated processes to
maintain effective internal awareness of their publicly-funded research data
holdings and of requests by third parties to access such data; all of their
researchers or research students funded by EPSRC will be required to comply with
research organisation policies in this area or, in exceptional circumstances, to
provide justification of why this is not possible.
What we mean…
• Pragmatic - applies primarily to data held by the research organisation;
• Will help inform future decisions whether to keep specific datasets
• Does not apply to data deposited in an external repositories
but we believe research organisations will find such information a
valuable indicator of impact.
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13. Expectation IV
Publicly-funded research data that is not generated in digital format will be stored
in a manner to facilitate it being shared in the event of a valid request for access
to the data being received (this expectation could be satisfied by implementing a
policy to convert and store such data in digital format in a timely manner)
What we mean…
• Research data doesn’t have to be digitised,
• If it isn’t digitised it needs to be stored so that it could be accessed if necessary
– valid requests shouldn’t be rejected ‘because it’s physically too awkward’ to
share.
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Expectation V
Research organisations will ensure that appropriately structured metadata
describing the research data they hold is published (normally within 12 months of
the data being generated) and made freely accessible on the internet; in each case
the metadata must be sufficient to allow others to understand what research data
exists, why, when and how it was generated, and how to access it. Where the
research data referred to in the metadata is a digital object it is expected that the
metadata will include use of a robust digital object identifier (For example as
available through the DataCite organisation - http://datacite.org).
What we mean…
• Focus on making data discoverable and accessible, ‘normally within 12 months of
the data being generated’
• Some flexibility of timing – justify exceptions, otherwise:
• Not more than 12 months after end of grant
• Not later than any publication which depends on the data
• For data underpinning a publication, can be satisfied by a resolvable citation to
the data.
• Flexible on standards – use what is most appropriate to achieve the object.
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Expectation VI
Where access to the data is restricted the published metadata should also give the
reason and summarise the conditions which must be satisfied for access to be
granted. For example ‘commercially confidential’ data, in which a business
organisation has a legitimate interest, might be made available to others subject to
a suitable legally enforceable non-disclosure agreement.
What we mean…
• Protect 3
rd
-party data, subject to consent.
• Personal/sensitive data – take extra care / precautions!
• Consider IP protection for commercially valuable data (publication delay may be
justified while protection put in place)
• All, including collaborators, should recognise the responsibility to ensure that
publicly funded research findings can be scrutinised and if necessary validated by
others.
16. Expectation VII
Research organisations will ensure that EPSRC-funded research data is securely
preserved for a minimum of 10-years from the date that any researcher ‘privileged
access’ period expires or, if others have accessed the data, from last date on which
access to the data was requested by a third party; all reasonable steps will be
taken to ensure that publicly-funded data is not held in any jurisdiction where the
available legal safeguards provide lower levels of protection than are available in
the UK.
What we mean…
• Pragmatic about ‘access’ – the point is to keep data that’s proving useful to
others; data citations/other metrics could demonstrate value...
• Not expected to keep data that has attracted no interest for more than 10 years.
• Provided published research findings can still be validated, it may be more cost
effective to preserve the means to recreate data instead of preserving the data
themselves
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What we mean:
• If in doubt about ‘how’, seek Digital Curation Centre (www.dcc.ac.uk) advice.
Expectation VIII
Research organisations will ensure that effective data curation is provided
throughout the full data lifecycle, with ‘data curation’ and ‘data lifecycle’ being as
defined by the Digital Curation Centre. The full range of responsibilities associated
with data curation over the data lifecycle will be clearly allocated within the
research organisation, and where research data is subject to restricted access the
research organisation will implement and manage appropriate security controls;
research organisations will particularly ensure that the quality assurance of their
data curation processes is a specifically assigned responsibility.
18. Expectation IX
Research organisations will ensure adequate resources are provided to support the
curation of publicly-funded research data; these resources will be allocated from
within their existing public funding streams, whether received from Research
Councils as direct or indirect support for specific projects or from higher education
Funding Councils as block grants.
What we mean:
Subject to two simple rules, all costs associated with RDM are eligible expenditure
of research grant funds. Further guidance available at http://bit.ly/1hhXu0u
The rules:
1. No expenditure can be ‘double funded’ (a central service funded from indirect
costs cannot also be charged as a direct cost)
2. All directly incurred expenditure of a grant must be incurred before the end date
of the grant.
Research offices are advised to ensure DMPs exist and appropriate resource for
RDM is requested in all research proposals
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19. Compliance Monitoring
Before Summer Break: Pro-VCs (Research) to complete
‘light-touch’ questionnaire
After Summer Break: dip-stick checking data availability
for publications (published after 1st May)
Follow up of any complaints that an organisation we fund
is failing to manage data in line with our expectations.
Longer term – formal self-assessment and dipstick
checking by RC Audit & Assurance Services Group
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20. Currently, in RCUK…
The RCUK Research Outputs Network (RCUK-RON)
is actively developing shared guidance on interpreting
the RCUK Principles
– individual council policies still stand.
No major philosophical differences identified – it’s the
nature of the data itself that is most often behind
differences in policy wording/approach
Common position on funding for RDM already
adopted
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21. N.B. a ‘recent’ development…
The 2014 Intellectual Property Bill amended the Freedom of
Information Act 2000:
“Information obtained in the course of, or derived from, a programme of research
is exempt information if—
(a) the programme is continuing with a view to the publication… …of a report of
the research (whether or not including a statement of that information), and
(b) disclosure of the information… …before the date of publication would, or
would be likely to, prejudice—
(i) the programme,
(ii) the interests of any individual participating in the programme,
(iii) the interests of the authority which holds the information, or
(iv) the interests of the authority mentioned in paragraph (a) (if it is a
different authority from that which holds the information).”
‘Public Interest’ test still applies
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22. Thank You
Find the full policy and expectations on EPSRC website:
Ben Ryan
Senior Manager, Research Outcomes, EPSRC
ben.ryan@epsrc.ac.uk
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EPSRC Policy Framework on Research Data
Notes de l'éditeur
Stress that researchers should find out what their organisations are doing in RDM – many have online resources available and/or run local training sessions
If they are not satisfied they should press for more!
Policy Announced May 2011
EPSRC acknowledged significant changes/investment might be required, including some over the medium-long term.
Full compliance expected by 1st May 2015 - over 70% of organisations holding EPSRC grants, including all our Framework and Strategic Partners, have confirmed they expect to be able to comply by the 2015 deadline
EPSRC will monitor compliance on a case by case basis. In cases of non-compliance, and in particular if it appears that proper sharing of research data is being obstructed, EPSRC reserves the right to impose appropriate sanctions.
Discrimination is important – ultimately we consider researchers best placed to decide what to keep, including in relation to published research.
Contrary to some suggestions, there is no obligation to keep everything indefinitely.
The landscape has evolved since EPSRC policy was published in 2011 – Government’s ‘Open Data’ white paper and the Royal Soc. report ‘Science as an Open Enterprise’ both published in June 2012.
We recognise there are challenges in meeting our May 2015 deadline – ‘new ground’ is being broken – e.g. standards for metadata to describe research data and associated supporting systems are still being developed, and new long-term storage options are appearing in the market.
A lot of training has still to be done…. More later after the next slide
Data sharing agreements can cover
the parties to whom, and purposes for which, data are released;
the conditions (including ethics committee approvals) of use of the data;
any specific confidentiality/security obligations;
arrangements for transferring, and support with using, the data;
any costs that may need to be met;
the handling of intellectual property, publication, authorship and acknowledgement;
the return of any cleaned or derived variables, and when data destruction or secure archiving are to be carried out.
Nuances between ‘data behind the paper’ and ‘data due for release’, and data originating from 3rd parties which may require access consent or be restricted.