The National Institutes of Health (NIH) Data Management and Sharing Policy provides flexibility for temporary restrictions on data sharing, such as embargo periods or exclusive use periods, to balance the goals of open science with practical, legal, and ethical considerations. The NIH’s Data Management and Sharing Policy mandates that 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.
Researchers are encouraged to consider relevant requirements and expectations (e.g., data repository policies, award record retention requirements, journal policies) as guidance for the minimum time frame that scientific data should be made available, which researchers may extend.
Researchers must clearly outline any anticipated restrictions or delays in their DMS Plans, providing justification for temporary restrictions. The DMS Plan must specify when and how data will become openly accessible, ensuring transparency in the process.
The NIH supports the use of repositories that can implement tiered or controlled access to datasets, providing access only to authorized users during periods of restriction.