The Council on Governmental Relations (COGR), representing 187 U.S. research universities and institutions, submitted this letter in response to the Office of Research Integrity's (ORI) Request for Information about the sequestration of digital data in research misconduct investigations. The letter highlights the inherent challenges of managing and securing digital data—such as its ease of modification, dispersion across diverse devices and platforms, technological obsolescence, and complications with metadata retention—making compliance with federal sequestration regulations complex and resource-intensive. COGR notes that sequestering digital evidence often requires significant investment in technical expertise, specialized equipment, and administrative policies, and that outside consultants may not always possess the contextual knowledge necessary for effective sequestration in academic research environments.
The communication discusses both administrative and technical strategies for improving data management and sequestration, recommending robust institutional policies defining ownership and access rights, standardized practices for data retention, and electronic laboratory notebook systems. COGR emphasizes the need for flexible, non-prescriptive federal guidance that accommodates institutional differences in resources and capabilities, rather than imposing rigid mandates that could increase costs and procedural delays. The letter further suggests including a requirement for respondent cooperation in identifying and securing data during misconduct proceedings. Ultimately, COGR advocates for increased grant funding for data management, underscoring that successful sequestration depends significantly on promoting a culture of research integrity and consistent responsible conduct of research practices at the institutional and laboratory levels.
