Your research group should consider the permissions you wish to use for making data available under your data management plan. There are several important factors to consider.

Permissions

Does your research project have sufficient permissions necessary to disseminate the project data?

• Did any of the data come from a third-party source?
• If so, did the project obtain permission to disseminate?
• Are there any restrictions you need to include in your permission statement?

Access

Do you need to provide access to all the data produced under a grant?

Data sharing requirements are determined by the community of interest through peer review and program management. The Federal Government in OMB Uniform Guidance Section 200.315 defines the default terms and conditions for recipients of federal funding with respect to data rights. It also provides specific guidelines on which research data are not required to be shared or archived. These include:

• Preliminary analyses
• Drafts of scientific papers
• Plans for future research
• Peer reviews or communications with colleagues
• Physical objects (e.g., laboratory samples)
• Trade secrets
• Commercial information
• Materials held confidential by a researcher until they are published or similar information which is protected under law

The Federal Government also defers data sharing compliance for data which include "personnel and medical information and similar information, the disclosure of which would constitute a clearly unwarranted invasion of personal privacy, such as information that could be used to identify a particular person in a research study."

Attribution

Will the project include a request or requirement for attribution and/or acknowledgement?

If you require attribution, you could:

• Provide a specific citation in your permission statement.
• Provide a link to a URL on your website so that users can find the most current citation.
• Ask the user to contact you in person for the appropriate information.

If you request attribution/acknowledgment, you can use the same mechanisms as above but will make compliance dependent on the user’s good will. It may help to explain why you are making the request; attribution is very important in the academic environment to building the reputation of a research team but also to understanding the provenance of the results.

In addition, it’s important to consider whether, for certain types of data, attribution requirements could present difficulties and negatively impact use.

Data Use

Will your group want to receive information regarding the use of the project data by users?

If you do require reports of use, do you want:

• To have the user specifically request access in order to receive the data?
• To have copies of publications sent to you?

Information that demonstrates use is often very important in illustrating uptake and validation of your research. Broad adoption and use can be a featured point in future grant applications and is an opportunity for your research group to grow its network and engage in relationships that might otherwise not occur.

You should seek to balance your control of access with your research group’s ability to promptly and reasonably respond to the research community. In some cases, you may only wish to request that data users provide you information regarding proposed use and send you a copy of any publication that results from use of the data.

Redistribution

Does your group need to be the sole source of the project data for quality control or other research integrity reasons (such as privacy), or would your group like to allow users to redistribute project data under certain conditions? 

Include in your data management plan whether redistribution is:

• Not allowed.
• Allowed but not for sale or commercial use.
• Allowed but limited in scope.

In some cases, certain types of data are not appropriate for all audiences. For example, drug interaction data may be complex and require users to have healthcare professional credentials to be responsibly used. This may require your research team or institution to remain the source of data distribution, and the distribution mechanism may need to be more formal to protect confidentiality or other elements of the data.

The US government understands that in some cases there may be incremental costs associated with making data available, and your research group may charge fees to recover these costs. Technology transfer services can help you with data dissemination that charges for incremental expenses.