| Effective Date: |
June 10, 2025
|
|---|---|
| Applies To: |
Classified Staff, Appointed Personnel, University Staff
|
| Responsible Units: | |
| Responsible Unit Email: | |
| Status: |
Active
|
Purpose and Summary
The University of Arizona (University) is committed to strengthening its protections of research and development against foreign government interference and exploitation while maintaining an open environment to foster research discoveries and innovation that benefit the nation and the world, consistent with the National Security Presidential Memorandum-33 (NSPM-33) and relevant laws and regulations.
Scope
This Policy applies to all Employees, Designated Campus Colleagues (DCCs), and Covered Individuals.
Definitions
Conducting Research means the design, development, testing, evaluation, conduct, reporting, review, and oversight of a program of scientific inquiry.
Countries of Concern means the following countries:
- China, including Hong Kong and Macau but excluding Taiwan
- Iran
- North Korea
- Russia
- Cuba
- Venezuela
- Other countries so designated pursuant to U.S. law
The Office of Research & Partnerships Countries of Concern webpage provides an updated list and additional information on designated Countries of Concern.
Covered Individuals means all research Investigators and contributors to a University research and development project who are designated as covered individuals by a federal research agency.
Designated Campus Colleagues (DCCs) means affiliates, associates, volunteers, and interns who are granted DCC status by the University, who contribute their time, services, and expertise to help the University accomplish its mission of teaching, research, and service.
Employee means all University employees, including faculty, staff, graduate assistants/associates, and student workers, whether their employment is full-time, part-time, permanent, or temporary.
Foreign Entity means (1) a government of a foreign country; (2) a foreign political party; or (3) a partnership, association, corporation, or other business organization organized under the laws of, or having its principal place of business in, a foreign country.
Foreign Individual means (1) a citizen or resident of a foreign country; (2) a person controlled by, or subject to the jurisdiction or direction of, a Foreign Entity; or (3) a person who acts as an agent, representative, or employee of a Foreign Entity.
Policy
Cybersecurity Program
The University must implement cybersecurity programs consistent with Presidential Memorandum on U.S. Government-Supported Research and Development National Security Policy (NSPM-33), its implementation guidance, and/or federal regulations identified by the University’s Research Security Program.
Foreign Travel Security
Covered Individuals must complete foreign travel security training as required by the Research Security Program.
The University must implement a travel reporting program that is consistent with federal requirements identified by the Research Security Program.
Research Security Training
Covered Individuals must complete research security training as required by the Research Security Program.
Export Control Training
Covered Individuals who are or will be Conducting Research involving export-controlled technologies must complete training on U.S. export control and compliance requirements as directed by the University’s Export Control Program and/or the Research Security Program.
The following activities or items must be submitted to the Research Security Program for approval:
Research collaborations, proposals, and subawards that involve (i) a Foreign Individual from a Country of Concern who is not an Employee or DCC, (ii) a Foreign Entity of a Country of Concern, or (iii) a Foreign Component in a Country of Concern.
A contract, agreement, or memorandum of understanding that involves a (i) Foreign Individual from a Country of Concern who is not an Employee or DCC or (ii) a Foreign Entity of a Country of Concern.
An official University purchase from a Foreign Individual or Foreign Entity from a Country of Concern.
DCC affiliations for Foreign Individuals from a Country of Concern.
Employment offers to Foreign Individuals from a Country of Concern.
International travel by Employees, DCCs, and Covered Individuals to a Country of Concern as directed by the Research Security Program.
Visa sponsorships for a person who is a Foreign Individual from a Country of Concern.
Material Transfer Agreements (agreements to allow sharing of research materials between organizations) and Intellectual Property licensing agreements that involve (i) a Foreign Individual from a Country of Concern or (ii) a Foreign Entity of a Country of Concern.
Other items as identified by the Research Security Program.
Employees, DCCs, and Covered Individuals must not have any interactions with any Chinese universities known as the Seven Sons of National Defense, including with faculty, researchers, or students associated with those universities. Interactions include, but are not limited to, speaking engagements, visits, research collaborations, faculty appointments, professional staff, or administrators.
Employees and Covered Individuals must report research security concerns, including known or suspected violations of this Research Security Policy, to the Research Security Program.
Employees and Covered Individuals must remove unpublished University research data from any device taken to a foreign country unless approved by the Research Security Program. The Research Security Program is not responsible if unpublished research data is taken to a foreign country.
Employees and Covered Individuals must be aware of and comply with additional research security requirements as identified by the Research Security Program.
Compliance
The Research Security Program is responsible for overseeing compliance with this Policy.