Submission – ARC FAIR data policy

The Australian Academy of Science welcomes the opportunity to comment on the Australian Research Council’s (ARC) draft FAIR data policy which would apply to future National Competitive Grants Program (NCGP) schemes.

As a signatory to the FAIR (Findable, Accessible, Interoperable, Reusable) access policy statement, the Academy has a direct interest in seeing the ARC's policy succeed in practice. Implementing the FAIR principles across Australia’s research system is important to enhance the impact and longevity of research data, and support collaboration through effective data stewardship.

This submission draws on consultation through the Academy’s National Committees for Data in Science (NCDiS) whose remit spans both the advancement of the FAIR and CARE (Collective benefit, Authority to control, Responsibility, Ethics) data principles. This dual perspective has informed several of the recommendations below, particularly on managing sensitive data and Indigenous data sovereignty.

The Academy recommends the ARC strengthen the FAIR data policy by:

• clarifying assessment mechanisms in Section 4 – in particular how FAIR compliance will be measured
• narrowing the definition of 'Research Data', particularly for third-party and licensed data
• expanding metadata requirements to include organisational identifiers, creators versus contributors, versions, conditions of use, schemas and controlled vocabularies
• providing guidance on data versioning, including for dynamic and continuously updated datasets
• clarifying management of sensitive data and Indigenous data sovereignty, including which framework takes precedence in conflicts
• addressing reproducibility, including how it will be supported alongside data reusability.