Research Security

Scope

This policy applies to all students, faculty, staff, and other employees of Indiana University, as well as any person conducting research or sponsored activity under the auspices of the University. 

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Policy Statement

Indiana University is committed to fostering international scholarship and research and creating an environment on its campuses where students, faculty, and staff from every corner of the world are embraced as Hoosiers. The University is also committed to protecting its research environment from foreign government actors and others who seek to misappropriate research and development to the detriment of U.S. national security or foreign policy goals, or the intellectual property and research interests of the University. The University maintains a comprehensive research security program, led by its Research Security Office (“RSO”), to protect against such misappropriation. The University is committed to research security. This policy supports the University’s compliance with applicable laws and Funding Agency requirements related to research security. The RSO will monitor changes to applicable law and Funding Agency requirements and propose changes to this policy accordingly. 

Hyperlinks are provided in this policy for convenience and informational purposes only. The validity and enforceability of any clause in this policy shall not be affected by the inaccuracy or unavailability of any hyperlink. 

Capitalized terms used in this policy have the meanings ascribed to them either where first defined in the text of this policy or as set forth in the Definitions section, below. 

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Reason for Policy

The University is committed to securing its research environment. This policy supports the University’s compliance with applicable laws and Funding Agency requirements related to research security. 

Disclosure to University and External Funding Agencies

All persons who, under the auspices of the University, makean application, submit a report, make a certification, disclose, or otherwise provide any information to a Funding Agency shall ensure all such information is complete, accurate, and in compliance with the Funding Agency’s requirements. This includes, but is not limited to: 

• disclosures of potential conflicts of interest and commitment;
• disclosure of education and appointments in a Biographical Sketch;
• disclosure of research or other support in a Current & Pending (Other) Support document;
• disclosure of collaborators in a Collaborators and Other Affiliations document; and
• certification of non-participation in a Malign Foreign Talent Recruitment Program.

In disclosing research or other support, it is the responsibility of the discloser to disclose all resources made available to the discloser in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the University. The discloser must maintain and provide to the University copies of contracts, grants, or any other agreements specific to foreign activities, resources, or appointments involving foreign entities, employment with a foreign institution, participation in a foreign talent recruitment program, and other information reported as Current and Pending (Other) Support. 

Research Security Training

All persons identified as Senior or Key Personnel in an application for, or award of, federal funding under the auspices of the University must complete Research Security Training maintained by the RSO in the twelve (12) months prior to submission of a funding proposal and annually thereafter, or more often as may be required by federal Funding Agencies.  

Talent Recruitment Programs

University employees are prohibited from taking part in any foreign recruitment program by a Foreign Country of Concern, including, but not limited to, China’s Thousand Talents Program. This policy is required by State of Indiana Executive Order 25-64, “Protecting Critical Infrastructure and Hoosier Resources by Increasing Prohibitions on Dealing with Certain Foreign Adversaries.”  

Additionally, the CHIPS and Science Act requires federal research Funding Agencies establish a policy requiring each “covered individual” (as defined by the CHIPS and Science Act) to certify that each such individual does not participate in a Malign Foreign Talent Recruitment Program (“MFRTP”) in a research and development award proposal, and annually thereafter, for the duration of the award. Under these federal policies, the University must also certify that it has made covered individuals (as defined by the CHIPS and Science Act) employed by the University aware of this requirement and that the same have complied. 
 
The University prohibits participation in an MFTRP by all: (1) university faculty; (2) university staff; and (3) students and other individuals engaged in the performance of, or who will be engaged in the performance of, if awarded, sponsored research or activity.  

Guidance related to this policy is available on the RSO website. 

Institutional International Engagement

In accordance with 42 U.S.C. § 19039, the University may not maintain a contract or agreement with a Confucius Institute. 

The University may not enter into any contractual agreements or transactions with, or disburse funds to, parties appearing on the Specially Designated Nationals List, BIS Entity List, BIS Unverified List, Military End User List, or the §1286 List, unless: (1) the disbursement of funds, transaction, or contractual agreement is lawful; (2) all required governmental licenses or approvals have been obtained; and (3) the University’s President (or designee) or the Vice President for Research (or designee) have expressly approved in writing. Requests for such approvals shall be directed to the RSO at rsohelp@iu.edu or through processes agreed between university units and the RSO. The university utilizes screening software to screen individuals and entities against these lists. Contact the RSO for access to the screening software. 

No agreements of any kind, whether binding or non-binding, with a Foreign Entity of Concern may be made or entered into by the University without the express written approval of the University’s President (or designee) or the Vice President for Research (or designee). Requests for such approvals shall be directed to the RSO at rsohelp@iu.edu or through processes agreed between university units and the RSO. 

Any contractual agreement proposed by university units, administrators, and/or faculty members for cross-border activity or affiliation with an institution of higher education or entity in another country is also governed by university policy INT-01, Agreements with Overseas Institutions and Cross-Border Activities. These agreements are vetted by the Office of the Vice President for International Affairs (“OVPIA”) and RSO. 

Any contractual agreement proposed by university units, administrators, and/or faculty members related to Education Abroad Programs, including, but not limited to logistics, travel arrangements, guest speakers, and related activity in support of student-related Education Abroad Programs does not require approval of the President or Vice President, provided that (1) none of the parties to the agreement appear on the Specially Designated Nationals List, BIS Entity List, BIS Unverified List, Military End User List, or the §1286 List; (2) none of the parties to the agreement are, and none of the activities under the agreement support, Foreign Terrorist Organizations or State Sponsors of Terror; and (3) the underlying activities have been approved by OVPIA via the Overseas Study Advisory Council. 

Pursuant to Indiana law, specifically IC 21-49-2.7, the University and its units may not use state funds or resources to: (1) engage or contract with an individual associated with a Foreign Terrorist Organization or a State Sponsor of Terror; or (2) support the activities of a Foreign Terrorist Organization or a State Sponsor of Terror. 

Sensitive Research Materials to/from Foreign Entity of Concern (FEOC)

Persons conducting research under the auspices of the University may not transmit Sensitive Research Materials to, or receive Sensitive Research Materials from, an FEOC without a written material transfer agreement or other appropriate agreement between the University and the provider or recipient (as the case may be) of the Sensitive Research Materials. In accordance with other provisions of this policy, such agreements require express written approval of the University’s President (or designee) or the Vice President for Research (or designee). 

Protecting Research Data and Intellectual Property

The University is committed to safeguarding its digital infrastructure and ensuring the confidentiality, integrity, and availability of data through robust information security practices. See IT-12, Security of Information Technology Resources and DM-01, Management of Institutional Data. This commitment is especially vital in the context of protecting Critical and Emerging Technologies, export-controlled information, and Intellectual Property (“IP”), which are central to national security and innovation.

In addition to the information security practices laid out in IT-12, the University is committed to protecting export-controlled information, which may require additional information security measures. All University personnel must contact RSO before engaging in a transaction that may involve export control concerns. See RP-11-009, Export Control.

Pursuant to Indiana law, specifically IC 21-36-5 (HEA1179-2024), the University prohibits the transfer, licensing, or sublicensing of Intellectual Property created with Indiana University resources to “prohibited persons.” See UA-23, Intellectual Property: Copyrightable Works and UA-24, Inventions and Patents.

Campus-Specific Procedures

Chancellors may institute campus-specific research security procedures that extend directly from this policy and/or require more stringent requirements, provided that 1) those procedures clearly reference this policy and do not conflict with this policy and 2) the RSO is notified of such procedures for purposes of coordination and implementation. 

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Definitions

§1286 List – means a list of foreign institutions that have been confirmed as engaging in “problematic activity” as described in §1286(c)(8)(A) of the FY 2019 National Defense Authorization Act. This list is subject to change. As noted by the Department of Defense, caution is advised for any researcher or institution engaging with institutions on this list.

Biographical Sketch – often called a “Biosketch” means a document required by Funding Agencies that documents an individual’s qualifications and experience for a specific role in a project.

BIS Entity List – means the list of entities found at Supplement No. 4 to Part 744 of the Export Administration Regulations, as from time-to-time amended.

BIS Unverified List – means the list of parties found at Supplement No. 6 to Part 744 of the Export Administration Regulations, as from time-to-time-amended, whose bona fides the U.S. Department of Commerce, Bureau of Industry and Security has been unable to verify.

CHIPS and Science Act – means The Creating Helpful Incentives to Produce Semiconductors and Science Act of 2022, Public Law 117-167.

Collaborators and Other Affiliations – means a document required by Funding Agencies that contains a table or list of an individual’s collaborators, such as their advisors, co-authors, and students.

Confucius Institute - means a cultural institute established as a partnership between a United States institution of higher education and a Chinese institution of higher education to promote and teach Chinese language and culture that is funded, directly or indirectly, by the Government of the People’s Republic of China (See 42 U.S.C. § 19039 (a)).

Critical and Emerging Technologies (CET) - Critical and emerging technologies are a subset of advanced technologies that are potentially significant to U.S. national security published by the U.S. National Science and Technology Council.

Current and Pending (Other) Support – means a document required by Funding Agencies that documents all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies with for the current proposal or award.

Education Abroad Program – means any university-sponsored or university-administered program that involves travel by minors or university students outside the United States, whose program arrangements and logistics are developed under the supervision of a university faculty or staff member. See: Policy INT-03, Education Abroad Program Development. 

Foreign Country of Concern (FCOC) - means China (including Hong Kong and Macau), North Korea, Russia, Iran, Venezuela, Cuba, or any other country determined to be a country of concern by the Secretary of State (See: 42 USC § 19237(2)) or a threat to critical infrastructure by the Indiana governor pursuant to Indiana Code § 1-1-16-8(b). See: Indiana Executive Order 25-64.

Foreign Entity of Concern (FEOC) – means an entity that is owned by, controlled by, or subject to the jurisdiction or direction of a government of an FCOC. For illustration, and without limiting the foregoing, the following are FEOCs:

• a company or entity organized under the laws of an FCOC;
• a company or entity headquartered in an FCOC;
• a university located in an FCOC; and
• any governmental entity of an FCOC.

Foreign Terrorist Organization – means an organization designated by the U.S. Secretary of State as a foreign terrorist organization under 8 U.S.C. 1189. See: https://www.state.gov/foreign-terrorist-organizations/.

Funding Agency – means any sponsor of research or sponsored activity, including the University (for internal funding opportunities), and any external sponsor, including, but not limited to, state, federal, foundation, non-profit, private, or industry sponsors.

Intellectual Property (IP) – means all original data, findings, or other products of the mind or intellect commonly associated with claims, interests, and rights that are protected under trade secret, patent, trademark, copyright, or unfair competition law. (IC 21-36-1-1.5)

Malign Foreign Talent Recruitment Program or MFTRP shall have the definition as set out in § 10638 (4) of the CHIPS and Science Act (42 U.S.C. § 19234 (4)).

Military End-User List – means the list of foreign parties found at Supplement No. 7 to Part 744 of the Export Administration Regulations, as from time-to-time amended, identified as military end users.

Sensitive Research Materials – means any tangible biological or chemical materials, including, but not limited to, animals or other organisms (whether living or dead), cells, pathogens, tissues, plasmids, chemicals, or any other tangible item used for research purposes which could cause harm to persons or otherwise pose a threat to national security.

Specially Designated Nationals List (SDN) – means a list maintained by the Office of Foreign Assets Control of parties owned or controlled by, or acting for or on behalf of, targeted countries. This list also includes individuals, groups, and entities, such as terrorists and narcotics traffickers.

State Sponsor of Terror – means a country determined by the U.S. Secretary of State to have repeatedly provided support for acts of international terrorism. See https://www.state.gov/state-sponsors-of-terrorism/.

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Sanctions

Violations of this policy result in disciplinary actions, up to and including termination from the University and/or criminal prosecution.

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History

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