Research Security

The U.S. Government has expressed increasing concerns about foreign threats to federally funded research activities, including diversion of intellectual property, sharing of confidential information, failure of researchers to disclose research resources and support provided by other organizations, including foreign entities and foreign governments, and other breaches of research ethics which compromise our national security and economic interests. 

 

These threats are often disguised as seemingly normal activities meant by a foreign entity to exert undue influence upon our research enterprise.  It is incumbent upon the University’s entire research community including its faculty, staff and students who are engaged in federally funded research, to understand our obligation to identify and mitigate risks so that we can collectively protect our national security and economic interests.

 

OSU-CHS is committed to supporting faculty and staff in meeting these obligations through training, transparency, and best practices.

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1. Research Security Training Requirements

Federal agencies require Research Security Training (RST) for senior/key personnel on proposals and awards. This mandate originates from the National Security Presidential Memo-33 (2021) and the CHIPs and Science Act (2022). It is recommended that all University faculty, staff, and students engaged in the conduct of research complete the training. This training helps researchers understand cybersecurity, foreign influence risks, and disclosure obligations. Training is available through the CITI Program. 

 

Compliance Dates

Training is valid for one year, per the CHIPS and Science Act.  Most federal agencies will require annual certifications.

 

2. Disclosure of Other Support & Outside Activities

All Senior/Key Personnel on federally funded research must disclose all sources of support, including:

• Domestic and foreign funding
• In-kind contributions (e.g., lab space, equipment)
• Appointments and affiliations (paid or unpaid)
• Significant financial interests and potential conflicts
• Disclosures must be submitted at key stages: proposal submission, Just-in-Time (JIT), annual progress reports, and upon changes in support or affiliations. 

See the requirements in OSU-CHS policy #4-70131 Disclosures of Other Support for Federally Funded Projects.

 

Why is this important? Full disclosure ensures transparency and prevents duplicate funding or conflicts of interest. Visit our detailed guidance page: Disclosure of Other Support.

 

3. Foreign Influence & International Engagement

Federal agencies require transparency in international collaborations to mitigate undue foreign influence. Researchers must avoid participation in Malign Foreign Talent Recruitment Programs and disclose all foreign affiliations, appointments, and support.

 

Learn more about risks and compliance: Foreign Influence Guidance.

 

4. Export Control & Travel Security

Sharing controlled items and information with a foreign national as well as shipping-controlled items to a foreign destination may require export licensing. 

 

Primary responsibility for compliance with export regulations falls on the Principal Investigator. The following activities may be subject to export control regulations, and can occur at any time during your research:

• Sharing proprietary or otherwise restricted information, technology or software with a foreign national
• Engaging in a sponsored project where the research results must be approved by the sponsor prior to publication
• Projects performed abroad by university personnel
• Export of tangible items outside the United States
• Furnishing defense services to a foreign person or entity within the United States or abroad
• Transacting with embargoed or sanctioned countries or parties

More information about these activities can be found on the Export Controls webpage

 

Faculty, staff and students traveling for University purposes (REGARDLESS OF THE SOURCE OF FUNDING) are required to request travel approval via university procedures (Policy 1-0134 EMPLOYEE DOMESTIC AND INTERNATIONAL TRAVEL).  Faculty, staff and students traveling internationally must contact Research Security Office to have a Restricted Parties Screening completed with regards to country, entities, and people that OSU personnel will be interacting with. For more information and assistance with planning and conducting international travel, please visit OSU Global website.

 

More info: U.S. Bureau of Industry and Security.

 

5. Data Security & Cybersecurity

Protecting sensitive research data is critical. Controlled Unclassified Information (CUI) refers to data that requires safeguarding but is not classified. Best practices include:

• Use encrypted storage and secure networks
• Follow institutional IT security policies
• Handle CUI appropriately and avoid unauthorized sharing

Refer to OSU-CHS policy #4-70121 Stewardship of Research Data for details.

 

6. Reporting Concerns

If you suspect foreign influence, data breaches, or other security issues, report immediately to the Office of Research. Anonymous reports can be made via Oklahoma State University's anonymous reporting system by phone at 1.866.294.8692 or online at https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=10933.