Research Security Information and Guidelines

Research Compliance

Subject:
Implementation of Research Security Framework aimed at maintaining research integrity, improving research security, and protecting research enterprise against foreign interference and exploitation.
Scope:
All University personnel and students involved in research.
Date Posted:
February 2024
Responsible Office:
Office of the Associate VP for Research Compliance/ Research Compliance Officer/ Research Security Officer

I. BACKGROUND

1. National Security Presidential Memorandum 33 (NSPM-33) In response to increasing concerns of foreign government interference and exploitation of federally funded research, the U.S. government issued National Security Presidential Memorandum 33 (NSPM-33) on January 14, 2021. NSPM-33 directs agencies and departments to focus on improving research security in the following areas:
   1. Enhance Awareness of Research Security Risks and Protections
   2. Strengthen Disclosure Requirements and Processes
   3. Limit Access and Participation
   4. Vetting Foreign Students and Researchers
   5. Information Sharing
   6. Research Security Training
   7. Research Security Program
   8. Promote and Protect International Collaborations  
2. Guidance for Implementing NSPM-33 from National Science and Technology Council. In January 2022 the National Science and Technology Council issued Guidance for Implementing NSPM-33 to federal departments and agencies regarding their implementation of NSPM-33, and general guidance for research institutions to establish research security programs with the following elements:
   1. Disclosure of all relevant activities and information that bear on potential conflicts of interest and commitment; standardization; electronic CVs; digital persistent identifiers.
   2. Consequences of violation of disclosure requirements.
   3. Information sharing.
   4. Research security programs: cybersecurity, foreign travel security, research security training, and export control training.
3. White House Office of Science and Technology Policy Releases Guidelines for Research Security Programs at Covered Institutions
4. S.B. 1565 “An act relating to requiring the establishment of policy frameworks for research security at public institutions of higher education.”
   The State of Texas Senate Bill 1565 Texas Legislature Online - 88(R) Text for SB 1565, effective September 1, 2023, mandates development of a Research Security Framework by every University and appointment of a Research Security Officer. The Research Security Framework must promote a culture of compliance with all applicable regulations and address protection of research enterprise from undue foreign influence.                                                                                     
5. Rule: 1092, The University of Texas System, Rules and Regulations of the Board of Regents
6. Education Code: Chapter 51, Provisions generally applicable to higher education
7. United States Attorney's Office, District of Maryland: University of Maryland, College Park Agrees to Pay $500,000 to Resolve Allegations That It Failed to Disclose Foreign Research Support in Federal Grant Proposals
8. US moves forward with plan for national research security centre
9. Research Security Framework at UT Tyler.
   The Research Security Framework is designed to protect UT Tyler’s research activities against foreign interference and exploitation.
10. University of Texas at Tyler-Policy on Safeguarding Data. Guidelines for Students who are not given a UT Tyler device and must use a personal device: Whenever feasible, Users shall store Confidential Information or other information essential to the mission of the University on a centrally managed server, rather than a local hard drive or portable device.  In cases when a user must create or store confidential or essential University data on a local hard drive or a portable device such as a laptop computer, tablet computer, or, smart phone, the User must ensure the data is encrypted in accordance with University, System's and any other applicable requirements.  University Data created and/or stored on personal computers, other devices and/or non-University data bases should be transferred to University Information Resources as soon as feasible. 
11. FY23 Lists Published in Response to Section 1286 of National Defense Authorization Act for Fiscal Year 2019 (Public Law 115-232), as amended   
12. DOD Releases Updated List of Foreign Institutions Engaging in Problematic Activities to Counter Unauthorized Technology Transfer       
13. When traveling internationally, we (UT Tyler IT) allow access to the UT Tyler network using VDI only, which also requires multifactor/dual factor authentificaiton.  VDI can be accessed using BYOD or a University owned device.   
14. The University of Texas Global Risk and Safety: Restricted Regions Criteria
15. The University of Texas at Tyler: Policy on Safeguarding Data                          

II.  RESEARCH SECURITY PROGRAM

1. Research Security Program at UT Tyler.
   The research security program implements a risk-based approach to ensuring research data security within the scope of the University’s research enterprise. Core components of the program include:
   1. Conflict of Interest and Conflict of Commitment
   2. Export Control (includes international research collaborations, international travel, vendor assessments, international shipments, and international visiting scholars)
   3. International Travel Oversight (includes travel security)
   4. Disclosures to Federal Funding Agencies
   5. Intellectual Property Disclosure and Safeguards
   6. Cybersecurity
   7. Research Data Maintenance

III. RESEARCH SECURITY OFFICER

1. Appointment of Research Security Officer (RSO) at UT Tyler.
   Dr. Calhoun appointed Dr. Anna Kurdowska as the Research Security officer for UT Tyler. She has been charged by the UTS Chief Research Security Officer with developing a framework for UT Tyler.
   The framework is intended to enable UT Tyler to promote secure research while mitigating the risk of foreign influence and intellectual property theft.
2. Duties of RSO at UT Tyler.
   RSO will be responsible for ensuring the research security program continues to meet all required federal, state, and System standards and is implemented effectively.  The RSO will:
   1. Facilitate the implementation of the federal and state requirements related to research security,
   2. Work closely with the Research Security Advisory Committee (RSAC) to ensure that investigators have the relevant information regarding the rapidly changing landscape for international activities and research security, 
   3. Conduct early risk assessments and take action to mitigate institutional risks,
   4. Develop, implement, and provide oversight of policies, procedures, and associated research security training,
   5. Attend the annual academic security and counter exploitation program educational events, including the annual conference at Texas A&M University.

IV. RESEARCH SECURITY ADVISORY COMMITTEE

1. Establishment of Research Security Advisory Committee (RSAC).
   A Research Security Advisory Committee (RSAC) has been established by the Research Security Officer to provide guidance regarding areas of risk, facilitate inter-campus collaboration, ensure that program components operate effectively, and help facilitate outreach across the institution.  Membership includes representatives from Information Security, Sponsored Programs Administration, Institutional Compliance, Human Research Protections Program, and Research Integrity.
2. RSAC Responsibilities:
   The RSAC is responsible for:
   1. Advising the RSO on matters related to research security.
   2. Environmental scanning of ongoing federal funding agency research security requirements and guidance.
   3. Reviewing current and ongoing efforts for effectiveness.
   4. Conducting risk assessments.
   5. Reviewing and recommending training opportunities.
   6. Coordinating internal monitoring and reporting incidents to  the RSO, who will in turn report relevant incidents to the UT System Chief Research Security Officer (CRSO). 

V. CONTACTS

• Contact us at research@uttyler.edu