The draft of the Presidential Policy on University of California Research Data is now open for a second round of systemwide review. The purposes of the policy are to 1) clarify ownership of and responsibility for research data generated during the course of University Research, 2) encourage active data management practices, and 3) provide guidance with respect to procedures when a researcher leaves the University. 

Ownership of research data by the UC Regents is a long-standing precept originally articulated in Regulation 4 (Academic Personnel Manual 020), where it states “Notebooks and other original records of the research are the property of the University.” Not since Regulation 4’s issuance in 1958, however, has any other systemwide UC policy provided further information on this stance. To provide more guidance to the UC community, the Research Policy and Analysis (RPAC) unit within Academic Affairs at the Office of the President began work in 2017 on a draft research data policy document, originally consulting with a small advisory group of representatives from UC San Diego, UCLA, UC Berkeley, the Office of General Counsel, and California Digital Library. 

The first systemwide review of the draft policy, Presidential Policy on the University of California Research Data and Tangible Research Materials, launched on December 17, 2020 and generated many thoughtful comments, which are broadly summarized as:

  • Concern that the scope of the University’s ownership of research data and tangible research materials is too broad, including by:
    • Extending into works that are already covered by the Copyright Ownership Policy, or works that are personal
    • Imposing ownership on data and materials owned by third parties
    • Overreaching into tangible artifacts (e.g., archeological material excavated out of the ground)
  • Concerns over how to implement the policy, including: 
    • Costs
    • Management plans
    • Transfer process
  • Concerns regarding unintended impact on core research facilities performing services on a fee-for-service or recharge basis
  • Concerns over the unintended impact this policy might have on relationships with tribal nations 

In response to this feedback, RPAC made the following revisions and clarifications to the draft policy:

  1. Revised and further clarified the intent of the policy, regarding ownership of and responsibility for Research Data during the course of University Research.   
  2. Revised the definition of Research Data and rewrote the text of the policy concerning ownership to clearly differentiate between those data owned by Regents and those data covered under the Copyright Ownership Policy.
  3. Noted that there are exceptions to UC’s ownership of Research Data when precluded by sponsorship or other related agreements. 
  4. Removed the inclusion of tangible research materials in this policy. 
  5. Revised the section of the policy related to procedures in the event that an investigator leaves the University.

On February 15th, 2022, the second systemwide review of the draft Presidential Policy on University of California Research Data began. The draft Presidential Policy materials are available as PDFs below. Comments may be submitted by April 18, 2022 to with the subject line “Research Data Policy Comments.” If you have any questions, please contact Agnes Balla at or (510) 987-9987.

RPAC appreciates the UC community’s thorough and thoughtful engagement with these issues, and looks forward to reviewing the next round of feedback.