Skip to main content

Accepting Publication or Dissemination Restrictions in Research Contracts

Fundamental Research: When Purdue researchers conduct research that is free from any publication approval or dissemination control or participation restrictions, the work and results of that work are outside the scope of the export control regulations. The work is considered "excluded from the regulations." This exclusion is often referred to as the Fundamental Research Exclusion and the vast amount of research conducted at Purdue is considered Fundamental Research because it falls within this exclusion. When Purdue accepts publication or dissemination restrictions in a project agreement, that project would be considered Controlled Research and the export control regulations will affect the results of that research. When SPS contracting receives a contract with restrictive terms, they will refer that agreement to the Export Control/Information Assurance Team, who will review the agreement and discuss the impact with the principal investigator to decide the best path forward. (See the contracting process graphic)

Controlled Research: When Purdue accepts a contract with a publication or dissemination restriction or when a sponsor or third party provides proprietary technical information, the information is subject to the export control regulations and the Export Control/Information Assurance team will work with the project team to ensure appropriate controls are in plan. (Often a Technology Control Plan is necessary)

Controlled Research Projects

In order to work on Controlled Research Projects, Personnel must do the following:

  • Take the appropriate Training
  • Have a completed Background Check on file with Human Resources - see Purdue’s Policy on Background Checks (VI.F.6)
    • Note: Consistent with Purdue’s Policy, if a pre-employment background check was not completed, one will be required before someone is authorized to work on a controlled Research Project
  • Be screened against U.S. Government Restricted Party Lists
  • Read, understand and acknowledge in writing any applicable Technology Control Plan
  • Principal Investigators of Controlled Research Projects are responsible to ensure all Project Personnel have Completed these steps before they are granted access to the Controlled Research.

Technology Control Plans

When necessary, the Export Control/Information Assurance Team will work with the Principal Investigator to develop a Technology Control Plan that addresses:

  • Authorized personnel
  • Dissemination and publication rules (including how to handled student theses that may result from the controlled research)
  • Physical security
  • Information technology security

Technology Control Plans must be signed by:

  • Principal Investigator
  • ITaP Security & Policy Office (ITSP) (unless no Information will be stored or transmitted electronically)
  • Lead Department Head/Center Director
  • Research Information Assurance Officer
  • All project personnel with access to the controlled research (Prior to being granted access)

Plans may need to be amended for any of the following reasons:

  • Significant changes to the scope or project plan (including any new effort not originally proposed)
  • Personnel additions or deletions
  • IT hardware additions or deletions
  • IT storage or software changes
  • Physical location (office or lab additions or change)
  • Significant changes to the physical security
  • Change to student thesis/dissertation committee or new plan of study submission.

All active TCPs are subject to periodic review and a managed close out process.

Purdue Offices Involved in Controlled Research

Sponsored Program Services - Contracting
IT @ Purdue (IT - Security and Policy Group)

Contracting Review Process diagram

START

Sponsored Programs Services Contracting Reviews Contract for Terms

  • Publication approval
  • Restrictions on participants
  • Dissemination limits
  • Foreign Sponsor

Export Control/Information Assurance Team WIll Review and Conduct:

  • Jurisdiction review (EAR v. ITAR)
  • Technology review
  • Lab review

Export Control Review:

Includes both physical and digital controls

Based on Review:

Export Control/Information Assurance Team will work with PI to put a plan in place

Once the Plan Is Finalized...

Export Control/Information Assurance Team:

Approves the negotiation to go forward

Negotiation Approved:

Contract execution

END

Need Help?

Contact the Purdue export control/information assurance team by email at exportcontrols@purdue.edu, by phone at (765) 494-9806, or in person on the 3rd floor of Hovde Hall.

Purdue University, West Lafayette, IN 47907 (765) 494-4600

© 2017 Purdue University | An equal access/equal opportunity university | Copyright Complaints | Maintained by the Office for Research and Partnerships

If you have trouble accessing this page because of a disability, please contact the Office for Research and Partnerships at evprp@purdue.edu.