In certain situations, specific data, software, technology, or equipment may be subject to export control regulations, and therefore, may only be shared with some foreign persons under an export license or under certain conditions and limitations.
In these instances, the Export Control Officer works with the unit to develop and implement a Technology Control Plan. A Technology Control Plan is a confidential document that supports and promotes international research and academic engagement by outlining compliance steps that are required for some foreign persons engaging in specific activities.
These plans ensure that controlled information, data, technology, and equipment are easily identifiable by researchers. They thereby ensure that foreign nationals are able to fully participate in their research and scholarship without inadvertently committing a deemed export violation.
When Technology Control Plans May Be Required
Technology Control Plans are implemented on a case-by-case basis. Examples of when a Technology Control Plan may be required include when:
- A foreign national will be engaged in research that involves controlled equipment on campus.
- A foreign national from an embargoed country (Cuba, Iran, North Korea, and Syria) accesses technology on campus.
- A researcher accepts a sponsored award that involves Confidential Unclassified Information (CUI).
- A foreign national receives access or admin privileges to high-performance computing technology on campus.
- Physical and information security measures are needed to prevent unauthorized access to controlled equipment in labs, institutes, and research centers on campus.
The UO remains steadfast in its commitment to international collaboration and in its stance against national origin discrimination. Technology Control Plans are implemented to ensure compliance with federal regulations and never in suspicion of a specific individual.
Prior to implementation, all project personnel will be asked to review and sign the Technology Control Plan.
Contents of Technology Control Plans
Technology Control Plans begin with a standard template to cover areas of research or scholarship where the Export Control Officer determines additional compliance measures are required. The Technology Control Plan is then tailored for the specific context. In some situations, the Export Control Officer may need to apply for and obtain an export license from the federal government as part of a Technology Control Plan.
Technology Controls Plans are tailored to specific situations, but generally cover the following points as applicable:
- Management commitment to export compliance
- Summary of applicable federal regulations
- Description of issue
- Federal agency jurisdiction
- Item classification
- Information security plan
- Physical security plan
- Personnel screening procedures
- Training and awareness program
- Self-evaluation program