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NIH Data Management and Sharing Policy

Guidance on how to comply with the NIH Data Management and Sharing Policy (effective January 25, 2023)

NIH Data Sharing Approaches

The appropriate preservation and sharing mechanism will depend on your project and the data you generate. However, the NIH DMS Policy requires or recommends the following, which all investigators should understand and consider:

  • "Shared scientific data should be made accessible as soon as possible, and no later than the time of an associated publication, or the end of the performance period, whichever comes first."
  • NIH encourages investigators to use an established repository. Established repositories include NIH-managed repositories and biomedical and generalist repositories supported by other organizations, both public and private.
  • "Applicants must follow all applicable federal, Tribal, state, and local laws, regulations, statutes, guidance, and institutional policies that govern research involving human participants and the sharing and use of scientific data derived from human participants."

We recommend reviewing and bookmarking the NIH guidance on sharing scientific data as a first step. It will help you understand how and when NIH expects data to be shared and how to safeguard the privacy of human participants while sharing scientific data.


Selecting a Repository

Using an established, quality data repository generally improves the FAIRness (Findable, Accessible, Interoperable, and Re-usable) of data. Additionally, using an established repository can reduce risks related to accidental loss and security when relevant. 

When selecting a repository, NIH encourages and prioritizes the following:

  1. When specified for data types, institutes, or funding opportunities, researchers should use the designated data repository(ies).
  2. When no data repository is specified, researchers are encouraged to select the most appropriate repository for the data generated.
  3. Primary consideration should be given to data repositories that are discipline or data-type specific.
  4. If no appropriate discipline or data-type-specific repository is available, researchers should consider other potentially suitable data sharing options, including generalist repositories, cloud-based repositories, and supplementary material to accompany articles submitted to PubMed Central.

Infographic demonstrating decision tree for selecting a data repository

As noted in the infographic above, NLM's BMIC has a searchable and filterable list of NIH-supported data repositories. You can filter it by institute or center or search the repository descriptions via relevant key terms.

If you don’t find a repository there, you can search for and evaluate additional repositories with the tools described below. OHSU Librarians librarians are available to help you navigate these resources. Contact us to schedule a consultation

Some of the language above was adapted from Fred Hutch Biomedical Data Science Wiki.

Protecting Participant Privacy

When working with human participant data, including de-identified human data, there are additional considerations and repository characteristics that must be considered. For example, you must ensure that the consent process for data collection allows for sharing the data in the way you have planned. NIH expects that in drafting their DMS plans, researchers will attempt to maximize scientific data sharing but acknowledge that certain factors (i.e., ethical, legal, or technical) may necessitate limiting sharing to some extent. 

The NIH Scientific Data Sharing website describes some of NIH’s expectations and provides links to additional documentation. 

If a controlled access repository is not appropriate or available for your data, you can consider using the OHSU Data Catalog to create a metadata-only record of your data. For more information about the OHSU Data Catalog, please contact the OHSU Library.

Some of the language above was adapted from Fred Hutch Biomedical Data Science Wiki.