Research Security

PURPOSE:

• Protect research data, information, equipment, and intellectual property from undue foreign influence, unauthorized access, use, disclosure, disruption, modification, or destruction.
• Ensure research compliance with federal, state, and institutional laws, regulations, and guidelines.
• Promote a culture of research security awareness and compliance among faculty, staff, and students.
• Facilitate transparency in disclosures, training, reporting, and monitoring processes.

SCOPE:

This policy pertains to all persons conducting research who are affiliated/ funded/supported by/ with ICOM including but not limited to: faculty, staff, student physicians, and research participants from outside organizations  

DEFINITIONS:

• Export Control: federal laws that govern how technology, technical data, technical assistance, and items or materials (from software to satellites and more) are physically or electronically exported, shipped, transmitted, transferred, or shared from the U.S. to foreign countries, persons, or entities.  These laws protect national security and U.S. foreign policy interests, prevent terrorism and the proliferation of weapons of mass destruction, and preserve U.S. economic competitiveness.  Penalties for violating these laws can be severe, both for the individual researcher and the university.  More information can be found here.
• FTRP – Foreign Talent Recruitment Program: 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 an individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue. Section 10631(b) of the CHIPS and Science Act of 2022
• Research: The Common Rule defines research as “systematic investigation, including research development, testing and evaluation, designed to develop or contribute to generalizable knowledge” (Protection of Human Subjects 45 CFR 46.102). This means that a project or study is research if it is conducted with the intention of drawing conclusions that have some general applicability and uses a commonly accepted scientific method.
• Research data: information that has been collected, observed, generated or created to validate original research findings. This can include: documents, spreadsheets, laboratory notebooks, field notebooks, diaries, questionnaires, transcripts, codebooks, audiotapes, videotapes, photographs, films, test responses, slides, artifacts, specimens, samples, collections of digital outputs, data files, and database contents (video, audio, text, images). 
• Undue Foreign Influence: refers to situations where foreign entities, governments, or individuals attempt to gain unfair or inappropriate advantages in research activities, potentially at the expense of research integrity, national security, or economic competitiveness. This can involve various actions, such as the illicit transfer of intellectual property, failure to disclose foreign funding or collaborations, or attempts to influence research outcomes.

POLICY:

To promote compliance with regulations and to maintain research security of both research data and research spaces, all students, faculty, staff and visitors shall comply with all research security procedures for: 

• Research with Prohibited Materials

• Research Security During Travel 

• Secure Management of Research Data

• Research Security Procedure

• Intellectual Property and Technology Transfer

• Materials/data transfer agreements 

• Undue foreign influence 

• Export control 

• Collaborative research

• Training and Compliance

Failure to comply with this policy and its associated procedures may result in disciplinary action, up to and including termination of employment or dismissal, in accordance with applicable ICOM policies. 

POLICY OWNER: 

Assistant Dean of the Research

CROSS REFERENCE AND SUPPORTING DOCUMENTS:

Information and links to other policies or supporting documents referenced within this policy.

APPROVAL:

Effective: 9/23/25

Last Reviewed: 9/23/25

Review Requirement: 3 Years