International Collaborations and Research Security

International Collaborations and
Research Security

UT values and encourages international research, collaboration and scholarship as a means to further knowledge and expertise. But these engagements may also present individual and institutional risks. Recognizing, understanding and dealing with such challenges and related issues will help ensure responsible, effective and productive research collaborations. There are three main areas of importance related to research collaborations and research security.

  • Disclosure requirements
  • Protecting intellectual property, research data and materials
  • Export control

The Research Security Team can provide support with any of the following issues:

  • Disclosure of foreign collaborations and relationship
  • International travel
  • Hosting visiting researchers on campus
  • Foreign government talent recruitment programs
  • Review international collaborations to assess risk from undue foreign influence

 

Disclosure Requirements

Information That Must Be Disclosed to Research Sponsors

Federal research sponsors require all foreign and domestic sources of current and pending support as well as certain collaborations and/or affiliations be disclosed in proposals and reports, including:

  • Funding supporting research activities
  • In-kind support such as research personnel, research materials or equipment, and research data
  • Foreign components involved in the conduct of research
  • Primary and secondary affiliations, including honorary titles, affiliate and part-time positions

Failure to fully disclose all such collaborations, affiliations and resources in funding applications and progress reports can have serious consequences and may jeopardize opportunities for future Federal support. When a PI submits a proposal to a Federal agency, the PI is certifying that all information in biographical sketches and current and pending support is complete and accurate to the best of his or her knowledge.

Federal agencies are working toward common disclosure requirements. Until this effort is complete, the Office of Sponsored Projects provides resource guides to agency specific requirements.

Disclosures to UT Austin

Federal agencies expect that faculty and researchers will also disclose financial interests and outside activities to UT so that the University can identify and manage conflicts of interest and conflicts of commitment. University policy requires faculty and researchers to:

  • Disclose financial interests in UTRMS-COI at least annually
  • Request prior approval for most outside professional activities

The Conflict of Interest program in ORSC provides guidance on related disclosure policies and processes.

Foreign Disclosure FAQs (PDF)

Protecting Intellectual Property, Research Data and Materials

Contracts and Agreements with Outside Entities

UT encourages employees to undertake consulting and other professional relationships with outside entities, as they may provide valuable experience for research and teaching activities. Often, the outside entity will require an agreement stipulating the terms of the engagement. Such agreements may include terms and conditions that conflict with UT policies, such as:

  • Time commitment expectations that exceed UT allowances
  • Intellectual property ownership clauses
  • Authorship affiliation requirements
  • An expectation for use of University resources

Refer to UT’s contracting guidance for details and a recommended contract addendum to help clarify obligations to UT.

Authorship of Scholarly and Scientific Publications

HOP 7-1070 articulates UT’s expectations related to authorship affiliation for faculty and researchers who hold secondary or visiting appointments at another institution or entity. UT should be identified as the primary affiliation on scholarly work except in very special circumstances that are detailed in the HOP. The policy also gives clear criteria for identifying a secondary affiliation.

When entering into outside appointment agreements, watch for a requirement to identify the secondary institution as the primary affiliation on scholarly products. Unless they have received explicit approval from their dean and the Office of Research Support and Compliance, faculty and researchers may not sign an agreement for a secondary or visiting appointment that requires them to list another institution as their first affiliation.

Aligning with the requirements in HOP 7-1070 can prevent problems, particularly when entering into agreements with foreign institutions. Some federal agencies use affiliation and acknowledgement information to ensure compliance with reporting requirements for current and pending support. Listing secondary institutions on publications as either first or second affiliations when those affiliations have not been fully disclosed to UT and federal sponsors may cause problems for researchers.

For questions or concerns about an existing agreement as it relates to this policy, please email UT’s Research Security Team for assistance.

Foreign Government-Sponsored Talent Recruitment Programs

The term “foreign government-sponsored talent recruitment program” (FGTRP) is defined by federal funding agencies as “an effort directly or indirectly organized, managed, or funded by a foreign government, or a foreign government institution or entity, to recruit science and technology professionals or students (regardless of citizenship or national origin, or whether having a full-time or part-time position)”. Many countries sponsor talent recruitment programs for legitimate purposes of attracting researchers in targeted fields, and many programs utilize legitimate means of attracting talent, including offering research fellowships and grants to incentivize researchers to physically relocate.

Some malign foreign talent recruitment programs, however, encourage or require unethical and criminal behaviors such as:

  • Prohibiting disclosure of participation in the program to UT or research sponsors
  • Carrying out research on behalf of the foreign institution that substantially overlaps with U.S. federal funding
  • Attributing awards, patents, publications and projects to the foreign institution, even if conducted with U.S. funding
  • Recruiting or training other talent recruitment plan members

UT prohibits participation in malign foreign talent recruitment programs, a policy that aligns with federal research sponsors. Read about Malign Foreign Talent Recruitment Program Indicators (PDF).

Participation in any talent recruitment program must be disclosed to UT and to federal research sponsors. Undisclosed obligations to a talent program may have serious consequences, including prohibition of an individual from participating in federally sponsored research or lasting financial damages to the faculty member’s lab or institution. If considering an invitation that may meet any of the FGTRP criteria, or with other related questions, please email UT’s Research Security Team.

Visiting Researchers and Scholars

Nonemployee Research Affiliates (NERA), also known as visiting scholars or researchers, are individuals who are typically, but not always, affiliated with an outside university, institution, business or government and seek to be temporarily in residence at UT for 10 or more days to collaborate with faculty, learn research techniques or use specialized facilities. NERA are not appointed as employees of the University and generally do not receive financial support or compensation from UT.

NERA visiting from both international and domestic locations require review by OVPR prior to being appointed. See the Nonemployee Research Affiliate page for the different NERA categories, specific criteria for NERA consideration, the nomination process and all approval steps necessary for granting facilities access to both domestic and international visitors.

If NERA will contribute to federally sponsored research, this support may need to be disclosed as Current and Pending Support. Please review this summary table identifying pre- and post-award disclosure requirements and email UT's Research Security Team at sas@austin.utexas.edu for assistance.

Most NERA visit UT to further professional collaborations and scholarly advancements. The U.S. federal government, however, has expressed concerns that some visitors affiliated with foreign governments seek to influence, interfere with and, in some cases, steal scientific research and intellectual property.

The following is a list of suspicious behaviors to look for when hosting visitors on campus:

  • Insists on working in private
  • Volunteers to help on classified or sensitive projects
  • Misuses computer or information systems
  • Lacks concern for or violates security protocols
  • Attempts to gain access to labs or information outside of approved scope
  • Unnecessarily photographs or copies materials, information or other items
  • Shows unusual interest in information outside of approved environment

Send questions about the NERA approval process or report suspicious behavior to the Research Security Team.

International Travel Security

UT faculty and research staff must protect their persons, staff and collaborators, equipment, data and materials when they travel abroad. The preventative steps that need to be taken vary depending on the risks they may encounter. International travelers should:

  • Register international travel with Texas Global. This site includes the Restricted Regions List of locations worldwide that pose a heightened travel risk and the process for requesting travel to these locations.
  • Verify whether Export Control restrictions apply to the travel destination or to the equipment, research specimens, research materials or data one brings on the trip.
  • Review UT’s Information Security Office Foreign Travel Security Briefing to help secure data and research materials.

UT’s Research Security Team offers pre-trip briefings and post-trip debriefings to help train researchers on what to look for and be aware of before travel, with an avenue to report any suspicions upon return. Contact the Research Security Team to request a travel brief/debrief or for:

  • Known or suspected theft of IP or other sensitive info
  • Requests from persons or entities known to be on the Denied Person List    
  • Persistent unsolicited emails or contacts from individuals or companies deemed suspicious
  • Requests for advanced and/or controlled technologies from individuals or companies known or suspected of being from a foreign government

Researchers who meet the following criteria should be extra vigilant when traveling, as they are more likely to be a target for information:

  • Conduct or are affiliated with U.S. Government- or DoD-funded research
  • Have a Technology Control Plan (TCP)
  • Work with ITAR or other restricted technologies
  • Work in a lab/area that has any of the above

IT and Data Security

U.S. universities receive large numbers of unsolicited requests for information and millions of hits on their web servers each day. Computer hackers, especially those funded by a foreign government, are capable of breaching firewalls and exploiting vulnerabilities in software. They are also skilled at deceiving trusting or unassuming individuals through scams.

Follow UT’s Information Security Office guidance for protecting sensitive digital research data to help safeguard the confidentiality and integrity of sensitive digital research data.

Among the various resources available for protecting digital research data, the following are offered at UT and should be strongly considered:

Texas Advanced Computing Center (TACC)

TACC has a comprehensive set of cloud services designed for researchers who need large-scale resources, but prefer a virtualized, on-demand environment – allowing them to efficiently perform modeling and simulations, visualizations, data analytics and management from any location.

Secure Research Environment (SRE)

UT’s Defense Research Advancement within OVPR has built out the SRE for Department of Defense-related research that requires higher levels of information assurance.  Located at the JJ Pickle campus, SRE’s resources include dedicated lab space for U.S. persons only, IT infrastructure, including the ability to use virtual machines, and program management support. They can be contacted at DRA_Research@austin.utexas.edu for more information.

Information Security Office (ISO)

UT’s Information Security Office provides tools and services that can help researchers implement security practices essential for protecting campus networks and research data. For specific questions, email the Information Security Office at security@utexas.edu.

Data and Materials Sharing

Sharing data and materials is an essential component of research collaborations. Before sharing data and/or materials, the following agreements may be required:

  • Data Use Agreement when sharing data outside of UT
  • Material Transfer Agreement before receiving or sending biological or chemical samples

Such agreements, except those covered by an industry-sponsored research agreement, are processed by the Office of Sponsored Projects through the UTRMS-Agreements module.

Export Control

Researchers should be aware of export restrictions applicable to any ideas, information or equipment they intend to share with international collaborators, whether they are overseas or visiting the U.S. Several key steps to avoiding export compliance concerns include:

  • Shipping—Before shipping controlled items, information or software overseas, consult with Export Control on the need for an export license.
  • Restricted parties—Do a visual compliance check to screen conference sponsors, international collaborators and entities to ensure they are not on a restricted parties list.
  • Financial transactions—Do a visual compliance check before accepting payments from international entities or sending payments to vendors, collaborators or research participants.

See Export Control for more information or contact UT’s Export Control Officer at orsc@uts.cc.utexas.edu with specific questions.

Questions?

Email sas@austin.utexas.edu