FAQ for Data Sharing for NOAA Grants PD

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Q What is meant by "environmental data"?

A: Environmental data are recorded and derived observations and measurements of the physical, chemical, biological, geological, and geophysical properties and conditions of the oceans, atmosphere, space environment, sun, and solid earth, as well as correlative data, such as socio-economic data, related documentation, and metadata. Media, including voice recordings and photographs, may be included.

Q What is meant by “sharing”?

A: Sharing data refers to making data visible, accessible, and independently understandable to users in a timely manner at minimal cost, except where limited by law, regulation, policy or by security requirements. NOAA facilities that archive data and make the data openly available should be considered for the disposition of the data.

Q What is considered "timely" data sharing?

A: *In general, unless otherwise indicated in the FFO, data must be shared no later than time of publication of a research paper based on the data, or no later than 2 years after data collection is complete, or no later than 2 years after the original end date of the grant (not including extensions), whichever is earliest. Documentation and metadata should clearly indicate the status of the dataset (initial raw data, draft data with only rudimentary quality controls, partial dataset, final data, etc). Specific requirements may depend on the program awarding the grant or cooperative agreement, and the nature of the research project conducted. Time requirements for data sharing will generally be spelled out in the Federal Funding Opportunity (FFO) announcement.

  • In general, data that have potential usefulness to others are expected to be made available as soon as possible consistent with logistical considerations. Data from small studies can be analyzed and ready for publication and sharing relatively quickly. If data from large studies are collected over several discrete time periods or waves, data should be released in waves as they become available or main findings from waves of the data are published.
  • NOAA recognizes that the investigators who collected the data have a legitimate interest in benefiting from their investment of time and effort. NOAA continues to expect that the initial investigators may benefit from being the first user of the data, but not from prolonged or indefinite exclusive use.

Q: How are funding recipients, especially small or poorly-funded ones, supposed to share their data?

A: There are several options, including submitting data for archiving and access to NOAA NCEI (which may charge a fee depending on size or complexity of the data), using a web hosting service operated by the recipient's institution, using a project-specific web server, or using one of the Data Repositories now being established in various domains, such as:

Q: What is the difference between the Data Management Guidance and the Data Management Plan?

A: The Data Management Guidance is written by the NOAA Program and included or referenced in the FFO Announcement or Contract Solicitation. The Data Management Plan is written by the author of a submitted proposal, and should be responsive to the recommendations provided in the Data Management Guidance.

Q: Will training be available to NOAA personnel responsible for implementing this directive?

A: Yes. Briefing materials will be provided on the EDMC web site; to arrange for a briefing contact your EDMC representative listed at https://www.nosc.noaa.gov/EDMC/edmc-membership.php.

Q: Does this Directive only apply to research awards?

A: No, as stated in §II this Directive applies both to research awards and to any other awards that fund the production of environmental data or peer-reviewed publications.

Q: How do we evaluate or check the data prior to making it publicly available? Who decides what data is appropriate to post or not?

A: We (NOAA) do not necessarily check the data or make it available -- it is incumbent on the award recipient to make the data available. Funding recipients should use their professional discretion and follow their institutional and domain guidelines regarding how to disseminate data. NOAA Programs may choose to support the evaluation or distribution of data.

Q: Is it acceptable to post only summarized data and products?

A: In general, no, it is not acceptable to post only summarized data. Data are to be made available in a form that would permit further analysis or reuse. In particular, all data that are used to support the conclusions of a peer-reviewed publication must be made available in a form that permits verification and reproducibility of the results. However, in some circumstances (e.g., to remove personally-identifiable information) some level of summarization may be necessary.

Q: What are some of the valid reasons for permitting a funding recipient not to share their data?

A: Data sharing could be limited by law, regulation, policy, security requirements, commercial or international agreements, or valid technical considerations.

Q: Who decides what data is worthy of long-term preservation?

A: Generally speaking, all quality-controlled observations, and all data used to support the conclusions of a peer-reviewed publication, should be archived for long-term preservation. In practice, this decision is based on a combination of factors, including the NOAA Program's assessment of the data's potential value, the funding recipient's assessment based on successful project execution, and NCEI based on the NOAA Procedure for Scientific Records Appraisal and Archive Approval.

Q: By sharing all publications generated through NOAA research awards, are we violating copyright rules? If the publisher charges for access to the article, how can we provide access to the same article for free?

A: NOAA will make available, after a one-year embargo, only a copy of the final pre-publication manuscript, along with a link to the publisher's copyrighted version of record.

Q: Who enforces submission of manuscripts to Institutional Repository, NOAA Library or the funding Program?

A: Programs are responsible for enforcing compliance by grant or contract recipients. NOAA Library will report on compliance but cannot enforce compliance. NOAA Library will enable Programs to see what manuscripts have been submitted.

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Q What is meant by “independently understandable”?

A: The data must be accompanied with documentation, metadata and, if needed, tools to read the data that allow a user to interpret the data properly. If there are concerns with understandability, they can be reported to NOAA, who will do an independent check.

Q Who will determine if my data are visible, accessible and independently understandable?

A: The person generating the data will have first responsibility for determining this. Common data quality standards in your scientific discipline may help you decide if the data are understandable. Ultimately, others who use your data will know whether they are visible, accessible and understandable to them. If there are concerns with data access or understandability, they can be reported to NOAA, who will do an independent check.

Q What are examples of law, regulation, policies or security requirements that may limit my ability to share data?

A: Policies applicable to protection of personally identifiable information, critical infrastructure information or proprietary trade information as well as regulations related to export control may impact your ability to share data, among other items.

Q Why share data?

A: The greater the availability of the data, the more quickly and effectively user communities can develop innovative practical applications for public benefit. In many cases these applications will be in areas not originally anticipated by the principal investigator. In addition, NOT making data available that supports scientific findings may provide reason to doubt the validity of the findings and limit their usefulness. More information about data sharing concerns are in a 2007 GAO Report, “Climate Change Research: Agencies Have Data-Sharing Policies but Could Do More to Enhance the Availability of Data from Federally Funded Research.” The GAO report specifically recommends NOAA consider evaluating data sharing plans as part of the grant review process.

  • Data sharing is widely accepted as a good practice. National scientific organizations have made a commitment to the sharing and archiving of data through their ethical codes (e.g., the American Sociological Association) or publication policies (e.g., the American Psychological Association). More than 15 years ago, the National Academy of Sciences described the benefits of sharing data. For many years, the National Science Foundation (NSF) Economics Program has required data underlying an article arising from an NSF grant to be placed in a public archive. Similar expectations exist at the National Institute of Health, and the National Institute of Justice. Moreover, many scientific journals require that authors make available the data included in their publications.

Q How must data be shared?

A: This depends on the nature of the project and the data, and will be proposed by the investigator himself. Grant and cooperative agreement proposals will need to include a Data Sharing Plan as part of the Project Narrative. A typical plan may include descriptions of the types of environmental data created during the course of the project; the standards to be used for data format and content; policies addressing data stewardship and preservation; and timelines and procedures for providing access, sharing, and security. Data sharing can be accomplished through:

  1. Data Archive: place where data are acquired, manipulated, documented, and distributed. NOAA facilities that archive data and make the data openly available should be considered.
  2. Data Enclave: controlled, secure environment in which eligible researchers can perform analyses using data resources
  3. Publishing: articles in scientific publications
  4. Researcher’s Efforts: investigator responds directly to data requests (e.g., posting data on a Web site)
  • Environmental data and information made available to the public by the grantee must include the following statement: These environmental data have not been formally disseminated by NOAA, and does not represent and should not be construed to represent any agency determination, view, or policy. In order to remove this disclaimer NOAA must verify that the data meets NOAA Information Quality Act guidelines and approve the dissemination of the data to the public.

Q Who benefits from data sharing?

A: Everyone benefits, including investigators, funding agencies, the scientific community, and, most importantly, the public. Data sharing provides more effective use of NOAA resources by avoiding unnecessary duplication of data collection. It also conserves research funds to support more investigators. The initial investigator benefits, because as the data are used and published more broadly, the initial investigator's reputation grows.

Q Does data sharing pertain only to published data?

A: No. Data-sharing plans should encompass all data from funded research that can be shared without compromising individual subjects' rights and privacy, regardless of whether the data have been used in a publication. Furthermore, data sharing prior to the publication of major results is encouraged in many instances, for example, when data are collected to provide a resource for the scientific community (as in the case of many large surveys).

Q Is data sharing the same as data archiving?

A: No, an archive is one way to share data but not the only way (see “How must data be shared?” above). For more information about archiving at NOAA refer to the “NOAA Procedure for Scientific Records Appraisal and Archive Approval.”

Q Data from my studies are generated from a very small number of experimental samples, and I publish the final data. Am I expected to provide these data to other investigators as well?

A: Publishing these final data can constitute an acceptable mechanism for sharing data. If only some of the final data are published, however, you would need another mechanism to share the remaining data.

Q Can I get an exemption?

A: If you determine it is impractical or not possible to share data according to NOAA policy you may include a request for an exemption of this requirement in your original proposal to collect/create data. If your proposal is funded verify the special award conditions indicate you are exempt from the data sharing requirement prior to accepting the award. If you determine post-award you require an exemption you may submit a request with an explanation as a post-award action request to the NOAA Federal Program Officer for consideration. You do not need to request an exemption when data sharing is limited by law, regulation, policy or security requirements. You do need to request an exemption if you are holding onto data until publication well after the project end date.

Q What if I don't want to share my data?

A: Data sharing plans will become a part of every new research grant and cooperative agreement proposal to NOAA. By accepting a grant award, you are agreeing to perform the work proposed, including the data sharing. If you fail to share your data as you proposed, you could be subject to a number of sanctions, including denial of future grant awards, freezing of funds in your current award, or in extreme cases even being forced to repay the grant award to the government.

Q Can I share data with colleagues under my own auspices?

A: Yes. Your data-sharing plans should indicate the criteria for deciding who can receive your data and whether or not you will place any conditions on their use. Data should be made as widely and freely available as possible while safeguarding the confidentiality of the data and privacy of participants. You should not place limits on the questions or methods others might pursue nor should you require co-authorship as a condition for receiving the data.

Q I'm a busy investigator. I don't have time to process requests for my data. What should I do?

A: In addition to publishing small datasets, there are several alternatives to responding to each separate request to share data (e.g., putting data in an archive or restricted access facility, and setting up a web site for data access). Archives and data enclaves provide technical assistance for users with questions or problems and may spare busy investigators time.

Q Can I get additional funding to share my data?

A: Unless otherwise noted in the federal funding announcement, funding to address data sharing must be requested as part of the proposal to collect/create data. The data sharing plans and related funds requested should consider the anticipated benefit of the data, the likely number of interested users of the data and the priorities of the program as outlined in the solicitation.

Q I am the PI of a large [Cooperative Institute|Sea Grant/similar] program funded by an omnibus grant which in turn manages a number of individual research projects. Must every individual project have its own data sharing plan, or can I develop a program-wide data sharing plan?

A: As the omnibus grant recipient, you have a responsibility to see that data sharing plans are followed for all research projects under your program. This may be done with a single Program-wide data sharing plan, individual plans for individual projects, or something in between, as long as all the relevant data generated is covered under some data sharing plan.

Q What web resources are available to help me do this and obtain more information?

A: There is information available at the NOAA Environmental Data Management Committee website reachable from www.nosc.noaa.gov. In general considering data sharing requirements prior to finalizing the methods for collecting/creating/storing the data will save time and effort later on. Unless otherwise noted in the federal funding announcement there is no specific data sharing plan template required.

Q My question wasn’t on this list, is there a person I can call or email?

A: Questions about specific sharing plans, grants, or RFPs should go to your Federal Program Officer or the contact listed in the specific Federal Funding Opportunity announcement of interest. More general questions can go to members of the NOAA Environmental Data Management Committee. Specifically the chair or deputy chair will take your general questions and work to answer them and add them to this list.