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, the work and the results are subject to the export control regulations and the project is considered Controlled.

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 Controls 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 Controls 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
• Export Controls 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.

Relevant Guidance Documents

• Controlled Thesis Submission Process
• EXRC Access Request Process
• For more info on how to scope your research effort to be fundamental research, please click here.

Purdue Offices Involved in Controlled Research

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