You are preparing your TUBITAK 1001 application. In the technical section of the form there is a "Data Management Plan" requirement. Or you are applying to Horizon Europe funding and a "Data Management Plan (DMP)" is required as a mandatory annex.
What is this document, why is it required, and why is it not enough to simply write "data will be kept securely"?
Why Is a DMP Now Mandatory?
Research funders request a data management plan for three reasons: to ensure the reusability of research data (the open science principle), to guarantee that personal data is processed within a legal framework, and to protect research integrity.
For medical research, these requirements are especially strict. When patient data is involved, KVKK (Turkey), GDPR (EU), and institutional ethics committee requirements all come into play at the same time.
The Areas a DMP Must Cover
A good data management plan goes far beyond a superficial "data will be kept securely" statement.
Data description: What kind of data will be collected? Images, surveys, biomarkers? What is the volume? What is the format?
Collection and standardization: How will the data be collected? If there are multiple centers, how will consistency be ensured?
KVKK compliance framework: What is the legal basis for processing personal data? How were the information notice and consent form prepared? How was the data minimization principle applied?
Storage and security: Where will the data be stored? Will encryption be used? What is the backup protocol? How will access authorization be managed?
Sharing: Will the data be shared at the end of the project? Under what conditions, on which platform? How do patient privacy constraints affect sharing?
Disposal: When and how will the data be disposed of at the end of the project? Were the legal retention periods taken into account?
Why Is a DMP Especially Difficult for Clinical Data?
Clinical research data requires an especially complex DMP for several reasons.
Multi-source data: The hospital information system, the imaging archive, the laboratory system, the survey form, each of these produces data in a different format and at a different security level.
Re-identification risk: Rare diseases, small cohorts, or a combination of unique clinical characteristics can make anonymized data re-identifiable.
Additional complexity in multi-center studies: Data processing agreements are required for data transfer between different institutions. Each institution has its own ethics committee approval and its own KVKK policy.
TUBITAK and EU Funding Expectations Differ
In TUBITAK applications, the DMP usually appears as a subheading within the technical section. The level of expectation is more flexible compared to EU funding, but it is becoming increasingly detailed.
In the Horizon Europe program, the DMP is requested as a separate document and is expected to be updated throughout the project. The FAIR principles (Findable, Accessible, Interoperable, Reusable) must be explicitly met.
Where Do People Get Stuck in This Process?
Researchers most often struggle at these points: how KVKK is reflected in the technical requirements. Striking the balance between the data sharing commitment and patient privacy. The content of data transfer agreements in multi-center studies. How the FAIR principles are applied in the context of clinical data.
To prepare a data management plan for your research project, request a 30-minute free consultation.
Where Do People Get Stuck Most in This Analysis?
- The TUBITAK form asks for a "data sharing plan," but you cannot share the data because of KVKK, and it is unclear how to justify this.
- In the data storage section you wrote "institutional server," but the technical specifications of the server are being questioned.
- The EU Horizon Europe application requires the FAIR principles, but you do not know how to apply FAIR to medical data.