The tri-agencies are implementing new standards to support RDM best practice
In 2021, Canada’s Tri-Agency introduced their Research Data Management Policy (Government of Canada 2021a), building upon an earlier 2016 Statement on Principles of Digital Data Management (Government of Canada 2021b). The objective of the policy is to support Canadian research excellence through the promotion of sound research data management (RDM) and stewardship. This policy has resulted in an immediate need to formalize RDM practices for various interest holders. We welcome the RDM Policy and feel it will help Canada keep pace with the global science policy landscape. Many other nations have adopted similar policies or strategies—such as the ESRC research data policy and the NIH Policy for Data Management and Sharing—the value of this policy on bringing transparency to RDM practices has clear implications for supporting research integrity and reproducibility (UKRI 2018; NIH 2020). The policy prompts three significant changes. Firstly, all institutions eligible to administer Tri-Agency funds are required to develop and make publicly available an institutional RDM strategy. Secondly, all grant proposals submitted to the Tri-Agencies will require methods that reflect robust RDM practices, with some calls specifically requiring a detailed data management plan (i.e., a living document describing specific handling practices for data across the research project’s lifecycle). Thirdly, grantees will be required to create a data deposit for results directly supporting their published findings.
The Tri-Agency has gradually phased in these three requirements, with DMP requirements for select grants initiated in spring 2022 (Government of Canada 2024) and institutional strategies required for posting by 1 March 2023. Here, we will focus on the final requirement, namely, data deposits. The policy specifies that “Grant recipients are required to deposit into a digital repository all digital research data, metadata, and code that directly support the research conclusions in journal publications and pre-prints that arise from agency-supported research” (Government of Canada 2021a). The RDM policy explicitly states that it is not an open data requirement, but advocates that where ethical, legal, and commercial obligations allow that data should be available for reuse by others. This flexibility in how data are deposited and/or shared is critical—it allows sensitive data that would be ill-suited to open sharing, or even restricted access sharing, to be safeguarded appropriately. Indeed, the policy also overtly and appropriately acknowledges the distinction-based approach needed when considering Indigenous data highlighting existing models related to data sovereignty and principles of OCAP® [Ownership, Control, Access, and Possession] (First Nations Information Governance Centre n.d.). We commend the Tri-Agency for creating a flexible data deposit policy requirement that will support federally funded data being “as open as possible, as closed as necessary”. The ability to access and reuse data is also an important step in tackling reproducibility concerns across research.
The next challenge for the Tri-Agency, and the broader research ecosystem, will be to bridge the gap between this strong policy towards effective implementation. There has not yet been explicit and open communication from the Tri-Agency about the intended next steps for data deposit. Since the release of the policy over three years ago, interest holders have been anticipating explicit communication from the Tri-Agency about the intended next steps for data deposit. Over the last couple of years, the Tri-Agency have been gathering evidence regarding the implementation of the data deposit requirement through various engagement sessions. Nevertheless, we are concerned that the requirement will be phased into a Canadian community ill-equipped to comply with data deposits. Indeed, when the Tri-Agency undertook consultation on their draft RDM policy from June to September in 2018, including engaging at several forums and conferences, they identified a lack of repositories with specific disciplinary needs as an issue (Government of Canada 2019). We share this concern. For example, despite acknowledging that not all data are suited for open sharing in the policy, no national infrastructure that is publicly available to researchers presently exists to actually create secure controlled access data deposits. Several of us are situated in research hospitals, in the absence of federal infrastructure, we do not see how researchers working with sensitive data, or data subject to consent permissions that do not permit open sharing, can readily comply with a data deposit mandate. Canada’s two main data repositories, Borealis (Scholars Portal n.d.) and the Federated Research Data Repository (FRDR), provide bilingual platforms to subscribing institutions that researchers can freely use to share diverse data types. However, neither currently provides user interface or security parameters, including varied access controls and data encryption, to be appropriate for sharing data in a controlled access model, or to deal with senstive data. The lack of national infrastructure would leave individual research performing organizations and researchers and staff grappling to find solutions, which we are concerned about would reduce efficiencies and create siloed nonstandardized efforts and spending. What’s more, without clear retention guidelines, specifying what data should be kept and for how long could pose a significant financial constraint on institutions for rapidly expanding storage requirements.
