Research Security Frequently Asked Questions

Why is Research Security Planning Important?

Understanding key export control and security concepts will assist in securing intellectual property, resources, information, technology, and individuals on our campuses while protecting national security and reducing overall risk to Wake Forest University. 

Additionally, it facilitates collaboration and the exchange of information in a safe, efficient, and legal manner. Security planning assists employees and students in identifying risks and developing appropriate controls and countermeasures to provide a safe and secure work environment at Wake Forest University.  

Who is required to conduct research security planning at Wake Forest University?

Collaboration with both international and domestic colleagues is a critical component of information sharing in an effort to advance education, research, science and technology here at Wake Forest University. The U.S. Government has continued to see a sharp increase in the theft or illegal acquisition of information and technology at both companies and Universities nationwide, resulting in increasing legal and compliance obligations.

To support the University’s interests in collaboration, while complying with laws and regulations, the University has published the [List Policy Here] to help with protecting intellectual property, research data, research facilities, network access, and physical spaces.

What is Controlled Unclassified Information (CUI)?

Controlled Unclassified Information is information that requires safeguarding or dissemination controls pursuant to and consistent with applicable law, regulations, and government-wide policies but is not deemed “classified” under Executive Order 13526 or the Atomic Energy Act, as amended.  Relevant legal guidance on CUI is available via Executive Order 13556 “Controlled Unclassified Information” (the Order) and 32 CFR Part 2002 (“Controlled Unclassified Information”).  The National Archives also maintains a CUI Registry, a government-wide online repository for federal guidance regarding CUI.

• Research data and other project information that a research team receives, possesses, or creates during the performance of federally funded research may be CUI.
• The federal sponsor will determine whether or not an award involves CUI and award documents should expressly identify CUI and applicable security requirements. 

The RSP and IT Security can assist you with identifying and training research teams concerning Controlled Unclassified Information (CUI).

What Kinds of International Collaborations and Activities Are Permissible?

Under federal law and guidance, there are several international collaborations and activities that are not considered part of a prohibited malign foreign talent recruitment program. Protected activities do not include activities for or with a restricted entity. Protected international activities may include:

• Scholarly presentations and publishing materials
• Participating in or disseminating information at international conferences or other international exchanges
  • Please note that international conferences held in an embargoed or sanctioned country may require an export control license. The Export Control Office identifies travel to embargoed countries when the travel is entered into the International Travel Form and contacts the traveler with next steps.
  • For export control questions, please contact rsrchsec@wfu.edu.
• Participating in research projects or programs that involve open and reciprocal exchange of scientific information that are aimed at advancing international scientific understanding
• Advising a foreign student enrolled at an institution of higher education or writing a recommendation for such a student at the student’s request
  • Please note that formal advising of a foreign student in an embargoed or sanctioned country may require an export control license. Please email the      Office of Research Security prior to beginning an advising relationship for a student in an embargoed or sanctioned country.
• Taking a sabbatical in a foreign country, serving as a visiting scholar, or serving as a U.S. government appointee to a board of a joint scientific fund
  • This may still require and export control review due to sanctions, and if the faculty member is staying on U.S.-sponsored grants while on sabbatical.
  • Please note that foreign work-related travel should be entered into XX prior to the trip, even if that travel occurs during a sabbatical. Such travel may be subject to approval. Serving as a visiting scholar may require disclosure under the Conflict of Interest, Conflict of Commitment, and Outside Activities Policy or under the Financial Conflict of Interest in Research Policy. For reference, please refer to Wake Forest University’s International Travel Policy.

Can I attend or present at a conference in another country?

Of course, and you may need to disclose that conference attendance. Before confirming attendance or your presentation:

• Request an export control compliance check on the institution hosting the conference. The export control officer will also work with you to determine the feasibility of applying for an export control license if one is needed for you to present on your research.
• Disclose the outside activity in your annual disclosure to comply with WFU’s Conflict of Interest, Conflict of Commitment, and Outside Activities Policy (which applies to all WFU employees) and with the Financial Conflict of Interest in Research Policy (which applies to all researchers accepting sponsored awards).
• If you receive federal funding, contact your post-award team at Sponsored Project Services to ask about disclosing the foreign collaboration to current sponsors and in proposals.

If federal funding will be used to cover the cost of the travel, contact your post-award team at Sponsored Project Services to receive approval from the sponsor before booking your travel.

Do export control regulations apply to me?

A: Most likely, yes! Export control regulations govern the shipment, transmission, or transfer of certain items, software, data, and information to foreign countries, persons, or entities. 

Export control regulations apply to university research and scholarship when:

• International employees, visiting scholars, or students conduct research at WFU
• Employees travel abroad with items, software, equipment, and/or information
• Employees engage in collaborations with researchers, academics, organizations located outside the U.S.
• Items, software, and/or information are shipped outside of the U.S.
• Sponsored research contains clauses requiring confidentiality
• A non-disclosure agreement is in place for an employee or the employee’s unit

The above list is not exhaustive, but is representative of many scenarios on campus in which export control regulations apply.

Export control regulations are intended to promote national security, further U.S. economic sanctions, aid regional stability, implement anti-terrorism and crime controls, and protect global human rights. The regulations affect not only the shipment of items outside the U.S., but also research conducted by international employees on campus, travel with WFU equipment outside the U.S., and collaborations with entities abroad.

Export controls works with other central offices on campus to help employees meet export control regulations without adding additional steps for the employee. For example, we work with ORSP to vet foreign collaborators and sponsors, and we work with Purchasing and Contracting Services to vet foreign vendors. We may also reach out to employees directly before they travel to certain countries or participate in research or collaborations with a foreign component.

WFU must apply for and receive an export control license prior to engaging in an activity that requires one. Typically, few exports will require an export control license, and many situations at WFU will qualify for an exemption. The university must document its analysis, including the availability of an exemption, and departments should not undertake this analysis on their own but instead contact us.

How do I ask or report a research security concern or question?

If you have any questions related to research security, please email  rsrchsec@wfu.edu for assistance.