Research Security Program, Interim (I.A.6)

Volume I: Academic and Research Affairs
Chapter A: Education and Research
Responsible Executive: Executive Vice President for Research
Responsible Office: Research Security Office
Date Issued: January 8, 2024
Date Last Revised: N/A

TABLE OF CONTENTS

Contacts
Statement of Policy
Reason for This Policy
Individuals and Entities Affected by This Policy
Exclusions
Responsibilities
Definitions (defined terms are capitalized throughout the document)
Related Documents, Forms and Tools
Website Address for This Policy
History and Updates
Appendix

CONTACTS

STATEMENT OF POLICY

Purdue University maintains a research security program to protect intellectual capital, prevent research misappropriation, and ensure responsible management of U.S. taxpayer dollars while maintaining an open environment to foster research discoveries and innovation. The program promotes transparency and guards against conflicts of interest and commitment, provides training and information on research security, and implements processes to assess and manage potential risks associated with collaborations and data. The program includes elements of cybersecurity, foreign travel security, research security training, export control training, and annual reporting of foreign financial support.

As part of the program’s compliance with applicable laws and regulations, Covered Individuals are prohibited from participating in Foreign Talent Recruitment Programs deemed malign by the Research Security Office and must complete all disclosure, training and certification requirements prescribed by the program.

REASON FOR THIS POLICY

Purdue’s pursuit of knowledge yields innovative research and valuable partnerships with industry leaders. With these accomplishments comes the responsibility to safeguard information and technologies from exploitation. The CHIPS and Science Act of 2022 and related guidance provide a framework for those protections. This policy describes the University’s efforts to comply with applicable laws, regulations and guidelines that govern research security.

INDIVIDUALS AND ENTITIES AFFECTED BY THIS POLICY

Purdue faculty, staff, students and others involved in research-related activities.

Faculty, staff and others responsible for information technology services and systems that support Purdue research.

EXCLUSIONS

There are no exclusions to this policy.

RESPONSIBILITIES

Research Security Office

• Oversee the University’s research security program.
• Follow federal guidance for determining whether an FTRP is malign.

Covered Individuals

• Refrain from participating in malign Foreign Talent Recruitment Programs.
• Refrain from engaging with parties on U.S. government restricted entity lists.
• Fulfill disclosure, certification and training requirements as prescribed by the research security program.

DEFINITIONS

All defined terms are capitalized throughout the document. Refer to the central Policy Glossary for additional defined terms.

Covered Individual
Officers, faculty, staff and students of Purdue University who are engaged in research at or on behalf of the University and any other individuals helping to conduct research at Purdue. This term includes but is not limited to graduate students, undergraduate students, postdoctoral researchers, fellows and visiting scholars.

Foreign Talent Recruitment Program (FTRP)
Any effort to recruit science and technology professionals or students that is organized, managed or funded by a foreign government (national, provincial, or local), a foreign government instrumentality or entity, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country. Some Foreign Talent Recruitment Programs operate with the intent to import or otherwise acquire from abroad, sometimes through illicit means, proprietary technology or software, unpublished data and methods, and intellectual property to further the military modernization goals and/or economic goals of a foreign government. Many, but not all, programs aim to incentivize the targeted individual to relocate physically to the foreign state for the above purpose. Some programs allow for or encourage continued employment at United States research facilities or receipt of federal research funds while concurrently working at and/or receiving compensation from a foreign institution, and some direct participants not to disclose their participation to United States entities. Compensation could take many forms including cash, research funding, complimentary foreign travel, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or consideration, including in-kind compensation.

RELATED DOCUMENTS, FORMS AND TOOLS

Related Policies

• Conflicts of Commitment and Reportable Outside Activities (III.B.1)
• Export Controls and OFAC Regulations (I.A.2)
• Individual Financial Conflicts of Interest (III.B.2)
• Information Security and Privacy (VII.B.8)
• Travel for University Business (II.A.3)

International Trade Administration’s restricted entity lists search

National Security Presidential Memorandum 33 (NSPM-33)

National Science and Technology Council’s Guidance for Implementing National Security Presidential Memorandum 33 (NSPM-33)

National Science Foundation CHIPS and Science Act webpage

Office of Science and Technology

WEBSITE ADDRESS FOR THIS POLICY

www.purdue.edu/policies/academic-research-affairs/ia6.html

HISTORY AND UPDATES

January 8, 2024: This is the first policy to address this issue.

APPENDIX

There are no appendices to this policy.