Research Security

Promoting International Research and Safeguarding Science

Resources on this page are provided to support your international research and to ensure compliance with Federal and state requirements, as well as OSU policies.

Commitment to Global Research and Compliance

Global research is an essential part of OSU’s mission, and international collaborations are critical to making the big discoveries that drive big solutions. OSU is required by Federal funding agencies to ensure that all OSU research is conducted safely, ethically, and in compliance with U.S. policies, regulations, and terms of awards.

What is the issue?

The Federal government has raised concerns about efforts of certain countries to inappropriately influence the U.S. research enterprise or gain access to sensitive research information or intellectual property. Research security refers to potential national security concerns that can arise when conducting research with global partners. Some foreign governments have sought to inappropriately obtain confidential, sensitive or proprietary research information from U.S. researchers in an effort to gain an economic or national security advantage. Such efforts can result in the inappropriate sharing of information, data breaches, contract noncompliance, ethics issues, and even national security concerns. U.S. Federal funding agencies are taking a significantly greater interest in the international interests and collaborations of their awardees.

Disclosing Outside Interests

Checklist coming soon!

It is important that researchers disclose international affiliations and sources of support in funding applications to federal agencies and in OSU’s annual Conflict of Interest disclosure form. Examples of items to disclose include international research collaborations, outside financial interests, sources of support, paid travel, and positions and appointments (paid and unpaid). Disclosing outside interests protects researchers and allows OSU and Federal agencies to manage any potential conflicts and risks. Detailed guidance is found in the links below.

The United States government has grown increasingly concerned about foreign government efforts to obtain innovative technology and technical data from U.S. researchers and their institutions. As such, when the CHIPS and Sciences Act of 2022 was released, it included a provision prohibiting participation in Malign Foreign Talent Recruitment Programs (MFTRPs, or foreign talent programs) by individuals involved in research and development awards from federal funding agencies.

OSU researchers are encouraged to collaborate with international colleagues, institutions and companies. But OSU researchers may not participate in malign foreign talent recruitment programs, as defined by the U.S government.

OSU researchers are to report participation in any foreign talent program in their relevant research proposal documentation (e.g. current and pending dupport documents) and at least annually in a research COI disclosure.

What is a malign foreign talent recruitment program? As defined by the Office of Science and Technology Policy, a malign foreign talent recruitment program is (as defined by Section 10638(4) of the Act):

(A) any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to the targeted individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue, in exchange for the individual—

(i) engaging in the unauthorized transfer of intellectual property, materials, data products, or other nonpublic information owned by a United States entity or developed with a Federal research and development award to the government of a foreign country or an entity based in, funded by, or affiliated with a foreign country regardless of whether that government or entity provided support for the development of the intellectual property, materials, or data products;

(ii) being required to recruit trainees or researchers to enroll in such program, position, or activity;

(iii) establishing a laboratory or company, accepting a faculty position, or undertaking any other employment or appointment in a foreign country or with an entity based in, funded by, or affiliated with a foreign country if such activities are in violation of the standard terms and conditions of a Federal research and development award;

(iv) being unable to terminate the foreign talent recruitment program contract or agreement except in extraordinary circumstances;

(v) through funding or effort related to the foreign talent recruitment program, being limited in the capacity to carry out a research and development award or required to engage in work that would result in substantial overlap or duplication with a Federal research and development award;

(vi) being required to apply for and successfully receive funding from the sponsoring foreign government's funding agencies with the sponsoring foreign organization as the recipient;

(vii) being required to omit acknowledgment of the recipient institution with which the individual is affiliated, or the Federal research agency sponsoring the research and development award, contrary to the institutional policies or standard terms and conditions of the Federal research and development award;

(viii) being required to not disclose to the Federal research agency or employing institution the participation of such individual in such program, position, or activity; or

(ix) having a conflict of interest or conflict of commitment contrary to the standard terms and conditions of the Federal research and development award; and

(B) a program that is sponsored by—

(i) a foreign country of concern or an entity based in a foreign country of concern, whether or not directly sponsored by the foreign country of concern (see definitions in the Act, Section 10637);

(ii) an academic institution on the list developed under section 1286(c)(8) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. 4001 note; Public Law 115-232); or

(iii) a foreign talent recruitment program on the list developed under section 1286(c)(9) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. 4001 note; Public Law 115-232).

For questions regarding potential participation in a MFTRP please contact the Export Controls and International Compliance Office: ([email protected]) or 541-737-0647.

Helpful Links:

Security and Training

University Information and Technology has a number of offices to support researchers. The Office of Information Security is a partner to researchers who have information security compliance needs, have questions about information security when traveling, or have general questions about securing their data. The Office of Information Security invites researchers to discuss their projects and requirements early in the process to ensure requirements can be met and research opportunities are successfully awarded. University Information and Technology’s new office, Digital Research Infrastructure, has been established to help researchers with research computing requirements, including finding compliant IT environments to conduct research.

  • Governance Risk and Compliance: GRC Team Services oversees the university's information security program, policies, and procedures.
  • Digital Research Infrastructure: Digital Research Infrastructure supports research computing and data security requirements.
  • Academic Technologies: Academic Technologies offers technologies to support teaching and OSU's academic ecosystem.
  • Digital Persistent Identifier: Distinguish yourself from other researchers by creating your digital persistent identifier.

The CHIPS and Science Act and other Federal directives require all federally funded researchers to complete research security training to help identify and manage risks that can arise when working with international partners or at international locations. Research security training focuses on the issues and risks associated with international research, the importance of disclosing outside interests, and strategies for managing risks. Log in to the CITI Program to complete the mandatory research security module on understanding risks and risk mitigation, and also select one additional module that is relevant to your work.

The National Science Foundation (NSF) has also developed four research security training modules for the research community. OSU researchers may take any or all of the NSF modules instead of to meet the research security requirement. In addition, you may contact the research security program to schedule an in-person training of your department, school, or research group. If you do not complete your training using the CITI Program, please log your completion and notify the research security program. 

The Export Controls and International Compliance Office is here to help OSU researchers, faculty, students, and staff navigate complex regulations by providing consultations, training, and support in a way that promotes successful university endeavors while ensuring compliance at OSU’s campus and around the world. You should contact the Export Controls and International Compliance Office prior to collaborating, shipping, or traveling internationally with technology or technical data, or sharing these commodities with foreign individuals within the United States.

International Engagement

All OSU employees, students, and others who engage in university-related international travel are required to register their travel with the university and adhere to OSU's International Travel Policy. Register your travel as soon as possible, ideally 60 days in advance of planned travel. Registering your travel will help OSU locate you and coordinate help in the event of an emergency. Registered travelers are automatically enrolled in a travel insurance policy with a 24/7 health and safety service.

The International Travel policy defines intermediate-risk and high-risk destinations. Travelers to these destinations have additional requirements and may require approval from a senior administrator.

The Office of International Services is the central campus resource for hosting international students, exchange visitors and international employees. OSU colleges and departments admit graduate students, and sponsor the immigration status of international faculty, professionals, and exchange visitors as they teach, research, collaborate, and engage in internships and training at OSU. The Office of International Services is the central campus resource for advising departments and international colleagues on immigration related matters, and advising on immigration regulations and compliance.

Governance and Resources

Learn more about research security from the National Science Foundation.

OSU is required by Federal agencies to establish a research security program that includes cybersecurity, foreign travel security, research security training, and the oversight of export controls, including relevant training. These areas, listed on this site, are overseen by multiple offices at OSU. OSU's Global Engagement Compliance Committee, which is co-chaired by the Associate Vice President for Research Integrity and the Deputy Senior International Officer and includes representatives from various administrative and academic units, serves as a clearinghouse for information sharing and coordination on research security issues.

OSU’s research security point of contact is Christopher Viggiani, Associate Vice President for Research Integrity ([email protected]).

 

NSPM-33. National Security Presidential Memorandum (NSPM-33) was issued on January 14, 2021 to “strengthen protections of United States Government-supported R&D against foreign government interference and exploitation” while “maintaining an open environment to foster research discoveries and innovation that benefit our nation and the world.” NSPM33 is directed at funding agencies and departments and requires that they:

  • Develop standardized disclosure requirements for institutions.
  • Require institutions to utilize digital persistent identifiers.
  • Develop guidance for administering consequences for the violation of disclosure requirements.
  • Provide clarity regarding circumstances when agencies may share information regarding violations and potential violations.
  • Provide clarity on what constitutes a research security program, which institutions will be required to implement. Program elements will include: 
    • Guidance for implementing NSPM-33 focuses on the key elements of a research security program:
      • a. Cybersecurity.
      • b. Foreign Travel Security.
      • c. Research Security Training.
      • d. Export Control Training.

CHIPS in Science Act. Creating Helpful Incentives to Produce Semiconductors (CHIPS) and Science Act. The CHIPS Act was signed into law on August 9, 2022, and is designed to boost US competitiveness, innovation, and national security in science and technology. The law aims to catalyze investments in domestic semiconductor manufacturing capacity. It invests $280 billion to bolster US semiconductor capacity, catalyze R&D, and create regional high-tech hubs and a bigger, more inclusive STEM workforce. NSF will also be establishing a research security and integrity information sharing and analysis organization in an effort to help universities and researchers alike. The CHIPS Act requires NSF to take a number of actions related to research security affecting institutes of higher education, including (but not limited to) the following:

  • 1. Prohibits recipients of federal funding from participating in “malign” foreign talent recruitment programs;
  • 2. Expands responsible conduct in research (RCR) training and includes a requirement for research security training;
  • 3. Requires researchers to report foreign financial support of $50,000 and above;
  • 4. Prohibits working with persons or entities of concern; and
  • 5. Requires NSF to develop to identify research areas supported by NSF that may involve access to controlled unclassified or classified information, including in the key technology focus areas.