In the rare circumstance where a research project does not fall under the Fundamental Research Exclusion, a Technology Control Plan (TCP) will be required. A TCP is a comprehensive document that outlines how a researcher will handle and safeguard export controlled technologies, data, and information to comply with U.S. export control regulations.
Before the new project can be setup by the Sponsored Programs Office, the Research Integrity and Compliance Office will collaborate with a researcher to develop a TCP via Kuali Build. Key components of a Technology Control Plan include:
- Research Project Description - An overview of the research being performed, and identification of the elements of the project that are export controlled.
- Project Details – Information including the project title, start and end dates, and a list of project participants.
- Security Measures – An outline of the security measures that will be followed to protect export controlled technology, data, or information. Safeguards may vary depending on the nature of the research or activity, and could include physical or digital controls, restrictions on project participants, and training requirements.
- Recordkeeping and Documentation – A description of the steps that will be followed related to record maintenance and disposal.
- Approvals – The TCP and its accompanying obligations will be reviewed and approved by the project’s principal investigator, their department head and dean, and the Research Integrity and Compliance Office to ensure all parties are aware of the TCP requirements to ensure the terms are met.
A TCP will run for the entirety of the project in question, with the Research Integrity and Compliance Office performing annual check-ins to verify that the terms of the TCP are being followed. The lead researcher should contact the Research Integrity Compliance Office if there are any substantive changes to the research project that would require the TCP to be modified.