Compliance Review

Review by the Office of Research Administration & Compliance focuses on ensuring that the Terms of the Agreement do not conflict with any state laws, university policies, or other project-related agreements.

  • If the Data was collected as part of a human research subjects protocol, we will confirm that the PI has an IRB approval or exemption on record.
  • If the data will be received from or shared with a foreign country, we will confirm that doing so does not violate any Export Control Laws.

The following terms are the most common “problem points” that need to be revised/negotiated with the other party:

  • Publication rights – VCU’s investigators must have the academic freedom to publish their work. Sponsors cannot require excessive pre-publication delay or impose other limitations on publication.
  • Intellectual Property rights – In accordance with the Intellectual Properties policy, VCU cannot agree to assign its rights in a VCU investigator’s invention to a third party. Ownership of the results of an investigator’s work similarly must stay with the university.
  • Confidentiality requirements – VCU policy limits the duration of a commitment to protect confidentiality and sets certain requirements for how confidential information is identified. Also, because VCU is a public institution and is subject to the Freedom of Information Act, agreements must make allowances for legally-required disclosures, including the existence and terms of an agreement.
  • Indemnification – VCU does not have the authority to execute an indemnification agreement and cannot indemnify any third party. VCU does, however, accept responsibility for its own actions.
  • Governing Law - VCU cannot agree to be bound by the laws of another state or country.

Research Data Ownership, Retention, Access, and Security Policy