Research Security Program (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: July 1, 2024

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. This includes coordination with process owners whose functions support one or more aspects of the program to ensure their internal processes are aligned.
• Follow federal guidance for determining whether an FTRP is malign.
• Ensure that training on the University’s research security program meets applicable regulatory requirements.
• Provide information and guidance to Covered Individuals and department/unit heads on meeting the requirements of the research security program.

Covered Individuals

• Disclose participation or affiliation with any Foreign Talent Recruitment Program (FTRP). If an FTRP is deemed malign by the Research Security Office, follow recommendations for corrective action.
• Refrain from engaging with parties on U.S. government restricted entity lists.
• Fulfill all disclosure, certification and training requirements as prescribed by the research security program.

Department/Unit Heads

• Consult with the Research Security Office, Outside Activities Officer (as defined in the Conflicts of Commitment and Reportable Outside Activities (III.B.1) policy), or Responsible Official (as defined in the Individual Financial Conflicts of Interest (III.B.2) policy) when reviewing requests or proposals that involve foreign entities. This includes, but is not limited to, proposal submissions, research or sabbatical leaves, reportable outside activity forms, conflicts of interest disclosures, etc.

Process Owners

• Consult with the Research Security Office to ensure internal procedures align with the program. This refers to offices or units that oversee a process or system that supports one or more aspects of the research security program (e.g., conflicts of commitment, conflicts of interest, IT, sponsored programs, global travel support).

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 program, position or activity that includes compensation from:

1. a foreign country at any level (national, provincial, or local) or their designee, or
2. an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country.

The compensation may or may not be stated in the arrangement, contract or document at issue and includes:

1. cash,
2. in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, honorific titles, career advancement opportunities, or
3. other types of remuneration or consideration.

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

July 1, 2024: Responsibilities for Research Security Office expanded. Responsibilities for Covered Individuals clarified. Added responsibilities for department/unit heads and process owners. Updated the definition of FTRP. Removed the interim status.

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

APPENDIX

There are no appendices to this policy.