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. <\/p>\n\n\n\n
.T.S. Security supports Tarleton\u2019s mission by overseeing the University\u2019s efforts to protect information and information systems with a goal to assure the availability, integrity, and confidentiality of the University\u2019s electronic information. To achieve this goal the ISO develops policies and procedures and raises security awareness within the campus community.<\/p>\n\n\n\n
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.<\/p>\n\n\n\n
To report an information security incident, please send an email to ITSecurity@tarleton.edu<\/a> or contact the Information Security Officer at (254) 968-9160<\/a>.<\/p>\n\n\n\n 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.<\/p>\n\n\n\n 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.<\/p>\n\n\n\n Tarleton State University is committed to ensuring compliance with System Policy 15.02, Export Controls Program<\/em><\/a>, Tarleton Rule 15.02.99.T1, Export Control Compliance<\/em><\/a>, 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)<\/a>, the Department of State through the International Traffic in Arms Regulations (ITAR)<\/a>, and the Department of Treasury through the Officer of Foreign Assets Control (OFAC)<\/a>.<\/p>\n\n\n\n Questions related to export controls should be directed to the Department of University Compliance as follows:<\/p>\n\n\n\n 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\u2019s these synergetic activities that invigorate fundamental scientific inquiries that ultimately enhance the innovation of our research ecosystems.<\/p>\n\n\n\n Without weakening this vigor our educational systems thrive upon, we face a unique and unparalleled paradigm in that it\u2019s equally essential to understand protecting specific U.S. interests related to our research ecosystems. Although most intentions are right, it\u2019s 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.<\/p>\n\n\n\n Protecting the interests of all involved\u2014the U.S. federal government, the university, our employees, and international collaborators\u2014is 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:<\/p>\n\n\n\n <\/p>\n\n\n\n Section 1286 of the National Defense Authorization Act directed the Secretary of Defense to \u201c\u2026establish an initiative to work with academic institutions who perform defense research and engineering activities \u2026 to limit undue influence including through foreign talent programs, by countries to exploit U.S. technology.\u201d<\/p>\n\n\n\n Issuance of a memorandum detailing disclosure requirements for all key personnel listed on research and research\u2013related educational activities supported by DoD grants and contracts.<\/p>\n\n\n\n Issuance of dear colleagues letter regarding research integrity.<\/p>\n<\/div><\/div>\n\n\n\n Issuance of a notification of DOE plans to implement a policy to mandate that \u201c\u2026federal and contractor personnel fully disclose and, as necessary, terminate affiliations with foreign government\u2013sponsored talent recruitment programs.\u201d<\/p>\n\n\n\n Issuance of order DOE O 486.1<\/p>\n\n\n\n Issuance of order DOE O 486.1A<\/p>\n<\/div><\/div>\n\n\n\n Issuance of a reminder notice of requirements for principal investigators, co\u2013investigators, and sub\u2013recipients must disclose all financial interests received from higher education or governmental institutions in countries outside the U.S.<\/p>\n\n\n\n Issuance of a memorandum stating that failure to properly disclose foreign relationships threatened to distort decision\u2013making in the use of NIH funds.<\/p>\n\n\n\n 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.<\/p>\n\n\n\n FAQs related to other support and foreign components posted.<\/p>\n<\/div><\/div>\n\n\n\n Research protection reminder issued.<\/p>\n\n\n\n Publication of the JASON Study.<\/p>\n<\/div><\/div>\n<\/div><\/div>\n\n\n\n <\/p>\n\n\n\n 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\u2019s 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.<\/p>\n<\/div><\/div>\n\n\n\n System Regulation 31.05.01<\/a> defines \u201cfaculty consulting and\/or external professional employment\u201d to include amongs the entire definition the following in regards to foreign interactions:<\/p>\n\n\n\n \u201c\u2026 The provision of scholarly or research expertise to foreign entities, whether involving compensation or not, constitutes \u2018employment\u2019 for the purposes of this regulation. The \u2018provision of scholarly or research expertise\u2019 includes, but is not limited to, participation in scholarly or scientific research projects or publications, teaching, and speeches.\u201d<\/p>\n\n\n\n As such, all activities with foreign entities must be reported in accordance with procedures provided within System Regulation 31.05.01.<\/p>\n\n\n\n System Regulation 31.05.02 <\/a>defines \u201cemployment\u201d to include among the entire definition the following in regards to foreign interactions:<\/p>\n\n\n\n \u201c\u2026 The provision of goods or services to foreign entities, whether involving compensation or not, constitutes \u2018employment\u2019 for the purposes of this regulation.\u201d<\/p>\n\n\n\n As such, all activities with foreign entities must be reported in accordance with procedures provided within System Regulation 31.05.02.<\/p>\n\n\n\n System Regulation 12.99.01 <\/a>includes the following in regards to foreign interactions in section 2.7:<\/p>\n\n\n\n \u201cCompensation, 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\u2019s export controls empowered official, in consultation with the Research Security Office, no later than 30 days prior to the date of travel. The \u2018provision of scholarly or research expertise\u2019 includes, but is not limited to, participation in scholarly or scientific research projects or publications, teaching, and speeches.\u201d<\/p>\n<\/div><\/div>\n\n\n\n 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\u2013standing policy.<\/strong><\/p>\n\n\n\nExport Controls<\/h2>\n\n\n\n
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Global Engagements<\/h2>\n\n\n\n
August 2018 (view the guidance document)<\/strong><\/a><\/h3>\n\n\n\n
March 20, 2019 (view the guidance document)<\/strong><\/a><\/h3>\n\n\n\n
October 10, 2019 (view the guidance document)<\/strong><\/a><\/h3>\n\n\n\n
February 1, 2019<\/h3>\n\n\n\n
June 7, 2019 (view the document)<\/strong><\/a><\/h3>\n\n\n\n
September 4, 2020 (view the document)<\/a><\/h3>\n\n\n\n
March 30, 2018 (view the guidance document)<\/a><\/strong><\/h3>\n\n\n\n
August 20, 2018 (view the guidance document)<\/a><\/strong><\/h3>\n\n\n\n
July 10, 2019 (view the guidance document)<\/strong><\/a><\/h3>\n\n\n\n
July 19, 2019 (view the guidance document)<\/strong><\/a><\/h3>\n\n\n\n
July 11, 2019 (view the guidance document)<\/strong><\/a><\/h3>\n\n\n\n
December 11, 2019 (view the guidance document)<\/strong><\/a><\/h3>\n\n\n\n
Disclosure Guidance<\/strong><\/em>:<\/h3>\n\n\n\n
Tarleton Rule 15.05.04.T1<\/a><\/h3>\n\n\n\n
A&M System Regulation 31.05.01<\/h1>\n\n\n\n
A&M System Regulation 31.05.02<\/h1>\n\n\n\n
A&M System Regulation 12.99.01<\/h1>\n\n\n\n