Managing Controlled Software

Software refers to a collection of one or more computer programs or micro programs in either source code (programming statements) or object code (machine-readable instructions).

There are United State laws regulating technology, this includes software. Software falling within this category is consider controlled software. Unauthorized access, use for an unpermitted purpose, and or mismanagement of such software creates a risk for the information owner and reputational harm and legal complications for Purdue University. The Export Controls Office is here to help ensure the proper management of controlled software.

Purdue University must meet the regulation requirements to ensure compliance. Examples of regulations included, but are not limited to:

• International Traffic in Arms Regulations (ITAR)
• Export Administration Regulations (EAR)
• Department of Energy regulations (DOE)
• Nuclear Regulatory Commission (NRC)

The types of regulation requirements vary and require export control review. Examples software controls included, but are not limited to:

• Restrictions foreign entities or persons
• Software with distinct licensing requirements
• Distinct disposal requirements
• Software restriction for operation outside of the US

Note: Controlled software must not be installed until a full review has been conducted by Export Controls.

The following items could be required when working with Controlled Software, this would be performed by Export Controls.

• Take the appropriate export control Training
• Having a completed background check of individuals working with the software 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 with controlled software
• Parties should be screened against U.S. Government Restricted Party Lists when applicable
• When necessary, a TCP or GGM will be created if the software has export controls

RSICC License Request

Purdue University, has created a process to request and install RSICC controlled software on a central service. The secure process allows us to compile with export regulations and RSICC licensing terms while safeguarding the installation of the software. See RSICC License Request.

Related Resources

• Export Classification
• Purdue IT Standards
• Purdue End User Security Guidelines
• Purdue Data Classification & Handling
• Media Disposal Guidelines