On June 6, 2023, the National Institute of Standards and Technology (NIST), US Department of Commerce, released a request for comments on NIST’s Research Data Framework (RDaF). The Association of Research Libraries (ARL) and the Data Curation Network (DCN) are pleased to offer the following comments in a collaborative response to this request.
ARL and DCN Comments on NIST Research Data Framework (RDaF)
July 6, 2023
National Institute of Standards and Technology
100 Bureau Drive
Gaithersburg, MD 20899
Re: Request for Comment on NIST’s Research Data Framework, version 1.5 (NIST Special Publication 1500, NIST SP 1500-18r1, Document Number 2023-11916)
On behalf of the members of the Association of Research Libraries (ARL) and the members of the Data Curation Network (DCN), thank you for the opportunity to provide comments on NIST Research Data Framework (RDaF) Version 1.5. ARL and the DCN are committed to supporting and contributing to the common overarching goals of the research-data community, while recognizing and supporting the dynamic environment of research as a scientific practice. We appreciate NIST’s ability to describe the many activities involved in the research-data life cycle (NIST’s subtopics), identify cross-cutting themes pertinent to all stages of the research-data life cycle, and to highlight profiles, or roles, of particular importance in research-data management. Together our membership represents several of the profiles highlighted, including Research Organization Leaders, Curators, Providers of Data Tools, and Researchers. The recognition the RDaF brings to these roles is critical, as it highlights work not always made visible during the management of research data.
Libraries are key stakeholders on academic campuses and in other research institutions, providing services and infrastructure to support research-data collection, analysis, management, and sharing. Recent reports by COGR, AAU (Association of American Universities), and APLU (Association of Public and Land-grant Universities) acknowledge the extensive role that libraries play in providing a variety of services related to research data.[1]
We respectfully submit the following comments on the NIST RDaF.
In addition to the specific actions below, overall, we recommend that NIST:
- Create ongoing opportunities for scholarly communities and other stakeholders to provide updates and input on the RDaF. Given rapidly changing methods for conducting science and the evolving US policy environment for research data, ongoing community feedback will be critical for ensuring the relevance of the RDaF. This will also allow the RDaF to increase its comprehensiveness over time.
- Consider interactive modes of communicating the complex and overlapping activities and stakeholders who may provide activity-related services. One suggestion is to create a dashboard through which users could explore the information. We believe this approach would greatly improve the usability of the content to end users.[2]
Section 1: Completeness and Coverage of the RDaF
1.1 Are the life cycle stages and the topics comprehensive? Are any topics missing?
ARL and the DCN recommend that NIST:
- Review the Share, Use, and Reuse stage, specifically the Publishing, Modes of Dissemination, Modes of Sharing, and Access topics. As presented, these topics lead to ambiguity on how the subtopics are associated with each of them. For example, while Repository is a subtopic of Publishing, it may also be considered a subtopic of Modes of Sharing, Modes of Dissemination, and Access. We encourage NIST to consider how subtopics are grouped and the relationships among subtopics in the groupings. Further, we encourage NIST to explicitly state that the subtopics may occur in stages not specifically categorized in the RDaF (much in the same way the RDaF explicitly states that life cycle is cyclical rather than linear); this would make it clear that different subtopics can be relevant throughout various topics and life cycle stages.
1.2 Are the subtopics comprehensive? Are any subtopics missing?
ARL and the DCN recommend that NIST:
- Reconsider if comprehensiveness detracts from flexibility in using the RDaF as a tool given the rapidly changing landscape of research data policies, scientific methods, and infrastructure that result in data. The subtopics are demonstrative, which is needed to convey the complexity of research data, but they are not necessarily exhaustive.
1.3 Are the overarching themes comprehensive? Are any missing?
ARL and the DCN recommend that NIST:
- We applaud NIST for surfacing these themes in stakeholder workshops and recognize that they provide valuable context for research-data management activities. However, we recommend NIST provide additional context and clarity around the themes. For example, some themes and topics are the same and others appear to only apply to select portions of the life cycle (such as the FAIR and CARE principles). We encourage NIST to clarify the purpose of these themes in relation to each topic, state how stakeholders might consider them during each stage, and discuss them earlier in the RDaF to demonstrate their value and impact.
1.4 Is the concept of using profiles for implementing the RDaF clear? Is it useful?
ARL and the DCN recommend that NIST:
- Provide more context into the purpose of highlighting these specific profiles. While it is clear that the profiles are samples, end users may appreciate clarification on the significance of these roles. For example, it is unclear why AI Expert is highlighted specifically, as it may overlap with roles like IT Leader and Researcher. Similarly, we think that this information would be more useful if each profile included a definition or persona as it relates to the RDaF.
- Consider reorganizing the layout of the profiles. We recommend NIST separate each profile into its own section, with a table for that role, as this would make the generic profiles more browsable and understandable.[3]
1.6 Are the informative references comprehensive? Are any resources missing?
ARL and the DCN recommend that NIST:
- Consider identifying connections between the Informative References and References lists. Currently having the two documents separated, with similar titles, is potentially confusing for end users. We recommend NIST either consolidate the two documents or otherwise indicate which references are cited in text versus additional helpful reference materials.
1.7 What additional organizations would you add to the key organizations in Appendix D?
ARL and the DCN recommend that NIST:
- Consider adding the Data Curation Network (DCN), the Research Data Access and Preservation Association (RDAP), the Collaboratory for Indigenous Data Governance, the Global Indigenous Data Alliance (GIDA), and the HBCU Data Science Consortium to the list of key organizations. The DCN and RDAP are member-based research-community organizations that support information professionals, data curators, and research-data management leaders in providing research-data services to researchers at their institutions. Both the Collaboratory for Indigenous Data Governance and GIDA advance Indigenous data sovereignty and governance and assert Indigenous Peoples’ rights and interests in data, while the Collaboratory for Indigenous Data Governance specifically engages with institutions to develop policies and frameworks that center Indigenous Peoples’ data and resulting rights throughout the data life cycle. The HBCU Data Science Consortium is an institutional and individual membership organization that promotes diversity, equity, and inclusion in the field of data science for HBCU students, faculty, and alumni.
Section 2: RDaF Content
2.4 Are the informative references well-tailored to the topics and subtopics? Do they enable users to fully explore those topics and subtopics in greater depth?
ARL and the DCN recommend that NIST:
- Explore opportunities and mechanisms to enable users of the RDaF to interact with the Informative References. In particular, we recommend that NIST consider sorting, grouping, or otherwise providing browsing mechanisms for users to find resources on a particular topic, subtopic, or theme.
2.5 Would a glossary with definitions of granular terms such as “tools” be helpful or redundant with the existing subtopic and topic definitions?
ARL and the DCN recommend that NIST:
- Consider leveraging the Informative References section to highlight previous work done to define many of the topics and subtopics. Glossaries of research-data management topics and themes for different audiences (such as researchers) already exist and are used by their respective communities. Amplifying those resources may ease the burden on NIST while providing access to this information.
Section 3: Usage of the RDaF
3.4. Would you find a network graph tool that allows free exploration of the relationships among the various elements (e.g., topics, subtopics, and profiles) of the framework useful?
ARL and the DCN recommend that NIST:
- Explore options for providing this functionality to users. We believe that such a tool would be valuable for a variety of audiences.
We look forward to continued engagement with NIST during the refinement of the RDaF. We are happy to work with NIST to identify ARL or DCN member institutions to participate in conversations regarding any of these specific topics. With any questions about these comments, please feel free to contact us or our colleague Cynthia Hudson Vitale, Director, Science Policy and Scholarship, ARL, cvitale@arl.org.
Sincerely,
Mary Lee Kennedy, Executive Director, Association of Research Libraries
Mikala Narlock, Director, Data Curation Network
Endnotes
[1] COGR, “Data Management and Sharing (DMS) and the Cost of Compliance: Results from the COGR Survey on the Cost of Complying with the New NIH DMS Policy,” May 11, 2023, https://www.cogr.edu/sites/default/files/DMS_Cost_of_Compl_May11_2023_FINAL%20%281%29.pdf; Association of American Universities and Association of Public & Land-grant Universities, “Guide to Accelerate Public Access to Research Data,” 2021, https://www.aplu.org/wp-content/uploads/guide-to-accelerate-access-to-public-data.pdf.
[2] An example of an interactive dashboard that supports customizable results is the Data Storage Finder, developed by the Research Data Management Service Group at Cornell University.
[3] For example, the Collections as Data Personas provide context into how specific roles are associated with data activity.
