FAQs — Academic Research Security Compliance and Risk Mitigation
How is fundamental research different than Controlled Unclassified Information (CUI)?
Fundamental research is defined as basic and applied research in science and engineering, the results of which ordinarily are published or shared broadly within the scientific community. CUI falls in a restricted research category as opposed to fundamental research. CUI is subject to safeguarding or dissemination controls established by federal regulations but is not classified.
What should I tell sponsor’s when they ask if I can perform CUI work?
Inform your sponsor that Georgia Tech has launched an initiative to transition all Georgia Tech research projects and data into a Secure Research Enclave (SRE). Transition into the platform is ongoing in phases to minimize disruption to research activities. During the migration effort, security requirements for research activities outside of the SRE environment will be established on a project‑by‑project basis, enabling cybersecurity controls to be tailored to the specific scope, risk profile, and regulatory obligations of each effort. As a result, it is critical to define the nature of each project during the pre-proposal phase to determine whether the work will involve CUI or quality as fundamental research.
What should I do if a sponsor identifies data as CUI but I believe it qualifies as fundamental research?
Ask your sponsor to identify the specific CUI category and subcategory being applied to the information produced under this project. Identification of the precise CUI designation is necessary for us to determine whether the designation is appropriate. If the sponsor cannot provide this information, work with your research administration team to submit a Fundamental Exemption Request (FRE).
If my project contains a restriction on foreign national participation, is this project considered CUI?
Short answer: No. A federal project that restricts foreign national participation is not automatically assumed to contain CUI handling. Foreign national restrictions can be a signal of a lesser restriction based on a federal agency’s current policy or practice. This is different than CUI since it is regulated by laws and regulations.
Who should I contact if I have questions or concerns about handling CUI data or materials?
If your question is related to ITAR or EAR controlled data or materials, please reach out to the Export Control team at export@gatech.edu If your question is related to other CUI data or materials, please reach out to the Academic Research Security Compliance team at rspo@enclave.gatech.edu.
Where can I get additional training on CUI?
This controlled unclassified information (CUI) Overview course is required of every employee at the time of new hire onboarding and annually during our Fall Compliance Campaign. If someone would like a refresher, the video can be accessed on CUI Overview.
What disclosures are currently required to submit proposals to federal agencies?
Currently, the following disclosures and training requirements are required for proposals to federal agencies: Federal Disclosures
The Department of Energy (DoE) has a required form for pre-approval of any foreign national participation on federally funded awards. If you anticipate hiring foreign nationals on your project, please submit the Foreign National Participation document in your proposal in eRouting.
Define Malign Foreign Talent Recruitment Programs and why does it matter to me?
Malign Foreign Talent Recruitment Programs (MFTRPs) are foreign government-sponsored initiatives aimed at recruiting U.S. scientists and researchers, often with the intent to acquire U.S. scientific research or technology. These programs may involve compensation from foreign entities, such as research funding or travel, and can lead to ethical conflicts of interest or intellectual property loss for U.S. researchers. Federal agencies, including the National Science Foundation (NSF) and the Department of Defense (DoD), require researchers to certify their non-participation in these programs to ensure compliance and protect national security. MFTRPs pose serious risks to U.S. research integrity and national security, making it crucial for researchers to be aware of and avoid such programs.
Are there additional steps that I should be aware of if I am traveling internationally?
Traveling abroad is an integral part of our international collaborations. If you are traveling internationally on official Georgia Tech business, follow the current Georgia Tech requirements via the Travel Authority Request (TAR).
What is an ORCID ID?
ORCID IDs provide a unique identifier that distinguishes you from other researchers and is now required for federally funded research. It ensures proper attribution and that your work is discoverable throughout your career. If you do not already have one, register here: ORCID ID.
What is the definition of a country of concern?
A country of concern is defined as a foreign country that is engaged in conduct detrimental to the national security or foreign policy of the United States. This designation is used by federal agencies and the Research Security Program as a risk marker for entities owned, controlled, or subject to the jurisdiction of a country of concern. The designation does not mean that research collaborations with individuals in or visiting scholars from those countries are banned. Instead, it serves as a warning for federal agencies to review such collaborations more closely.
What are the current Countries of Concern?
- China (including Hong Kong and Macau)
- Iran
- North Korea
- Russia
Can I collaborate with a former graduate student or post doc who is now affiliated with a university in one of the countries of concern?
Collaborating with a former graduate student or post-doc who is now affiliated with a university in one of the countries of concern is not recommended due to potential risks and security concerns. It is essential to adhere to the guidelines set by federal agencies and university policies regarding research security. These guidelines often include restrictions on international collaborations, especially with countries of concern, to protect the integrity and security of the research enterprise.
Can I collaborate with individuals from other countries not designated as countries of concern?
Collaborating with individuals from other countries not designated as countries of concern is generally permissible. However, it is crucial to ensure that all research activities comply with U.S. export control laws and international compliance regulations. This includes screening research collaborators to ensure they are not on a U.S. restricted list and following the appropriate procedures for international collaborations.
