Research Security
Tarleton State University follows guidance from the Texas A&M University System Research Security Office on administering research security policies, procedures and technology to enable Tarleton State University employees to comply with Federal guidelines for handling all levels of U.S. Government information. Research security is an interdisciplinary program handled by departments in IT, University Compliance, and the Office of Research Compliance. The primary foci of research security are: information security, export controls, and global engagements.
Information Security
.T.S. Security supports Tarleton’s mission by overseeing the University’s efforts to protect information and information systems with a goal to assure the availability, integrity, and confidentiality of the University’s electronic information. To achieve this goal the ISO develops policies and procedures and raises security awareness within the campus community.
The Information Security Office ensures that the University is in compliance with Texas Administrative Code Chapter 202, as well as other State and Federal laws dealing with Information Security.
To report an information security incident, please send an email to [email protected] or contact the Information Security Officer at (254) 968-9160.
Export Controls
United States Export Control laws and regulations establish the conditions under which controlled information and items can be transmitted to anyone outside the United States and to foreign persons and entities in the United States. They also restrict or prohibit the transaction of business with certain countries, persons and entities that have been sanctioned by federal agencies as a threat to important U.S. interests. All Tarleton employees and students must be aware of and are responsible for the export control implications of their work and must ensure that their activities conform to export control laws and regulations.
Severe institutional and individual sanctions for violations of export control laws include the loss of research funding, loss of export privileges, as well as civil and criminal penalties including imprisonment. Although many university activities could be excluded from export control laws, some activities may be restricted. The application of export control laws involves a fact-specific analysis. While most exports do not require specific approval from the federal government, certain exports require a license and others are prohibited.
Tarleton State University is committed to ensuring compliance with System Policy 15.02, Export Controls Program, Tarleton Rule 15.02.99.T1, Export Control Compliance, and all United States export control laws and regulations, including but not limited to those implemented by the Department of Commerce through the Export Administration Regulations (EAR), the Department of State through the International Traffic in Arms Regulations (ITAR), and the Department of Treasury through the Officer of Foreign Assets Control (OFAC).
Questions related to export controls should be directed to the Department of University Compliance as follows:
- By phone at 254-968-9415;
- By email at [email protected]; or
- In person at the University Compliance Office located in Room 106 of the Administration Annex I Building on the Stephenville campus
Global Engagements
Tarleton State University is committed to upholding the highest standards of integrity in all aspects of ethics and compliance. We are equally committed to protecting our research ecosystem, while also recognizing the importance of maintaining an open research environment that welcomes the participation of individuals from around the world. It’s these synergetic activities that invigorate fundamental scientific inquiries that ultimately enhance the innovation of our research ecosystems.
Without weakening this vigor our educational systems thrive upon, we face a unique and unparalleled paradigm in that it’s equally essential to understand protecting specific U.S. interests related to our research ecosystems. Although most intentions are right, it’s crucial to be able to identify when reciprocity is not a goal of both parties involved in collaborative environments. Mitigating potential risks, whether connected to undue foreign influence, conflicts of commitment, or export controls, is considered a priority. At the same time, we continue to recognize the strengths of our fundamental global collaborations.
Protecting the interests of all involved—the U.S. federal government, the university, our employees, and international collaborators—is of utmost importance. International relationships and collaborations should not only be disclosed, but also fully vetted in determining compliance risks with conflicts in commitment, financial conflicts of interest, duplication of effort in research, potential export control violations, or possible loss of intellectual property. Several U.S. federal entities require principal investigators, co-investigators, and sub-recipients to disclose research interests in countries outside the U.S. Following are brief narratives of U.S. governmental entities implementing policies and requirements in attempts to mitigate undue foreign risks:
August 2018 (view the guidance document)
Section 1286 of the National Defense Authorization Act directed the Secretary of Defense to “…establish an initiative to work with academic institutions who perform defense research and engineering activities … to limit undue influence including through foreign talent programs, by countries to exploit U.S. technology.”
March 20, 2019 (view the guidance document)
Issuance of a memorandum detailing disclosure requirements for all key personnel listed on research and research–related educational activities supported by DoD grants and contracts.
October 10, 2019 (view the guidance document)
Issuance of dear colleagues letter regarding research integrity.
February 1, 2019
Issuance of a notification of DOE plans to implement a policy to mandate that “…federal and contractor personnel fully disclose and, as necessary, terminate affiliations with foreign government–sponsored talent recruitment programs.”
June 7, 2019 (view the document)
Issuance of order DOE O 486.1
September 4, 2020 (view the document)
Issuance of order DOE O 486.1A
March 30, 2018 (view the guidance document)
Issuance of a reminder notice of requirements for principal investigators, co–investigators, and sub–recipients must disclose all financial interests received from higher education or governmental institutions in countries outside the U.S.
August 20, 2018 (view the guidance document)
Issuance of a memorandum stating that failure to properly disclose foreign relationships threatened to distort decision–making in the use of NIH funds.
July 10, 2019 (view the guidance document)
Issuance of a reminder memorandum in regards to the need to report foreign activities through documentation of other support, foreign components, and financial conflict of interest to prevent scientific, budgetary, or commitment overlap.
July 19, 2019 (view the guidance document)
FAQs related to other support and foreign components posted.
July 11, 2019 (view the guidance document)
Research protection reminder issued.
December 11, 2019 (view the guidance document)
Publication of the JASON Study.
Disclosure Guidance:
Tarleton Rule 15.05.04.T1
University administrators, departments/units, and employees must submit all Global Engagements and International Collaborations to Compliance for export control compliance review. Compliance will monitor the System RSO’s quarterly list of Countries of Concern and submit High Risk Global Engagements and High Risk International Collaborations identified through the export control compliance program to the VPRIED for Executive Leadership Management Council review and approval process.
A&M System Regulation 31.05.01
System Regulation 31.05.01 defines “faculty consulting and/or external professional employment” to include amongs the entire definition the following in regards to foreign interactions:
“… The provision of scholarly or research expertise to foreign entities, whether involving compensation or not, constitutes ‘employment’ for the purposes of this regulation. The ‘provision of scholarly or research expertise’ includes, but is not limited to, participation in scholarly or scientific research projects or publications, teaching, and speeches.”
As such, all activities with foreign entities must be reported in accordance with procedures provided within System Regulation 31.05.01.
A&M System Regulation 31.05.02
System Regulation 31.05.02 defines “employment” to include among the entire definition the following in regards to foreign interactions:
“… The provision of goods or services to foreign entities, whether involving compensation or not, constitutes ‘employment’ for the purposes of this regulation.”
As such, all activities with foreign entities must be reported in accordance with procedures provided within System Regulation 31.05.02.
A&M System Regulation 12.99.01
System Regulation 12.99.01 includes the following in regards to foreign interactions in section 2.7:
“Compensation, funding, or any item of value received from any foreign entity, or the provision of scholarly or research expertise to a foreign entity, whether or not compensation is received, cannot be accepted by the faculty member unless first approved by the academic institution’s export controls empowered official, in consultation with the Research Security Office, no later than 30 days prior to the date of travel. The ‘provision of scholarly or research expertise’ includes, but is not limited to, participation in scholarly or scientific research projects or publications, teaching, and speeches.”
Pursuant to a letter dated October 10, 2019, DOD reiterated the necessity of research personnel to fully disclose any conflicts of interests and commitments. Specifically, the requirement includes disclosure of all current and pending projects, time commitments to other projects, and funding sources at the time of the application. This is not a new requirement, but rather a long–standing policy.
Disclosing Foreign Components and Other Support | ||
What | Where | When |
Outside appointments (paid or unpaid) | Bio–sketch | Proposal |
Related Sources of Support | Other Support | Proposal |
Pursuant to a directive published June 7, 2019, DOE prohibits both its employees and contractors from participating in foreign talent recruitment programs from certain countries. DOE views such participation as a conflict of interest that necessitates reporting.
On July 10, 2019, NIH reminded the extramural community regarding the need to report foreign activities through documentation of other support, foreign components, and financial conflict of interest. This is not a new requirement, but rather a long–standing policy of full transparency for all research activities both domestic and foreign.
Disclosing Foreign Components and Other Support | ||
What | Where | When |
Outside appointments (paid or unpaid) | Bio–sketch | Proposal, Just In Time Requests, and Research Performance Progress Reports |
International collaborations with activities performed outside the U.S., regardless of monetary value or location of the resource | Foreign Component | Proposal, Just In Time Requests, or Prior Approval for Existing Projects |
All resources available to the PI or key personnel in support of and/or related to all research endeavors, regardless of monetary value or location of resources | Other Support | Proposal, Just In Time Requests, and Research Performance Progress Reports |
International visiting scholars, students, or collaborators in your facilities that support your research (not key personnel) | Other Support | Proposal, Just In Time Requests, and Research Performance Progress Reports |
On July 11, 2019, NSF issued a letter clarifying steps the agency is taking to mitigate risks associated with undue foreign influence. Additionally, the agency has proposed clarification of disclosure requirements to both current and pending support as well as professional appointments, which are included in NSF 20-1. Since 1978, NSF has required senior project personnel to disclose all sources of funding on proposals. This is not a new policy.
Disclosing Foreign Components and Other Support | ||
What | Where | When |
Outside appoints (paid and unpaid) | Bio–sketch | Proposal, Progress Report |
Research, training, and/or education carried out with international counterparts (whether located abroad or using virtual technologies) | Cover Sheet (countries listed) and Project Description | Proposal |
Funding of a foreign organization including subawards or consultant agreements as part of the award | Cover Sheet and Project Description | Proposal or Requires Prior Approval |
Unfounded substantial international collaborations | Facilities, Equipment, and Other Resources; and Letter of Collaboration; Organizations that have been involved as partners (with full details). | Proposal and Progress Report |
All resources (including in-kind contributions) made available in support of and related to their research efforts, regardless of monetary value | Current and Pending Support | Proposal and Progress Report |
In-kind Contributions made available to an individual in direct support of the project, regardless of monetary value | Current and Pending Support | Proposal and Progress Report |
For all other federal agencies, there are no reporting requirements at this time. However, the RSO recommends reporting be made to the contracting officer as well as the agency’s inspector general if it is discovered that personnel are members of a foreign talent recruitment program.
NSF Research Security Training
The Division of Research, Innovation, and Economic Development encourages all Tarleton researchers to take advantage of the training provided by the U.S. National Science Foundation ‘s newly launched interactive online research security training modules. These modules are designed to facilitate principled international collaboration in an open, transparent and secure environment that safeguards the nation’s research ecosystem.
Fueled by the “CHIPS and Science Act of 2022,” these training modules signify a major first step in reconciling the needs of the research, law enforcement and intelligence communities to pursue trusted relationships in the global research community while minimizing economic and security risks. They provide researchers with clear guidelines and effective strategies to protect against existing and emerging research security threats. The modules also reinforce NSF’s commitment to strengthen protections of U.S. government-supported research as outlined in the National Security Presidential Memorandum – 33.
The following list identifies and summarizes the four training modules:
Module 1: Introduction to Research Security
This training module covers the key concepts of research security and how to recognize situations that may indicate undue foreign influence. By understanding the regulatory landscape that shapes research security, researchers will be empowered with the tools to protect their own work and safeguard the core values that underpin U.S. academic research.
Module 2: The Importance of Disclosure
This training module explains federal funding agency disclosure requirements, including types of information that must be disclosed, how that information is used and why such disclosures are fundamental to safeguarding the U.S. research enterprise from foreign government interference and exploitation.
Module 3: Manage and Mitigate Risk
This training module identifies types of international collaborative research and professional activities, associated potential risks, and strategies and best practices for managing and mitigating such risk. Learner experience will be customized based on their role as either a researcher or administrator.
Module 4: The Importance of International Collaboration
This training module emphasizes the role of principled international collaboration in U.S. science, innovation and economic competitiveness. The training will provide strategies on how to balance principled international collaboration with research security concerns, as well as how to foster an open, welcoming research environment that fulfills research security needs.