The U.S. Government has defined research security as "safeguarding the research enterprise against the misappropriation of research and development to the detriment of national or economic security, related violations of research integrity, and foreign government interference."1 The National Science Foundation has stated, "Ultimately, research security is about ethical behavior, regardless of background or origin. Ethical behavior is foundational to the conduct of research, and it can only be achieved when everyone can collaborate in an open environment, shielded from the threats of dishonest and unethical behavior."2
What is Research Security?
What is the IU Research Security Office?
The Research Security Office ("RSO") is one of the core divisions in IU Research. The primary mission of RSO is to assure research security at IU. The Chief Research Security Officer leads RSO, reports directly to the Vice President for Research, and is a member of IU Research's senior leadership team.
Guiding Principles
RSO is guided by the common values set out by the Association of American Universities ("AAU") with regard to malign foreign influence—academic freedom; free expression; inclusion and diversity; national interest; transparency; integrity; zero tolerance for harassment and coercion; and collaboration. RSO executes its research security program consistent with IU's longstanding commitment to global engagement and academic freedom, as well as its IU 2030 pledge to make IU a welcoming environment of mutual respect where students, faculty, and staff from every corner of the world are embraced as Hoosiers.
Why is IU focusing on Research Security?
The U.S. academic community's current focus on research security can be traced back to then NIH Director Francis Collins' "Dear Colleague Letter" to various NIH funding recipients noting that "foreign entities have mounted systematic programs" to "inappropriately influence" federally funded research, noting concerns of diversion of intellectual property and failure of researchers to disclose substantial resources from other organizations, including foreign governments" which would inappropriately influence funding decisions. In the years since, Congress, the White House, and federal funding agencies have increased the number of research security requirements and guidance with which we must contend.3 Ensuring a research environment that is both secure and compliant with these requirements is key to the continued success of IU students, faculty, and staff, and to achieving the goals of the IU 2030 Strategic Plan, Pillar Two.
Research Security Assurance Mission of RSO
The RSO seeks to assure faculty, staff, students, sponsors of research and other creative activities, and other stakeholders (collectively, the "Research Community") of a research environment free from threats of those who wish to exploit IU's open and inclusive academic research environment. RSO carries out this mission through engagement with the Research Community on topics related to research security, monitoring for research security concerns, and suggesting appropriate mitigation measures to the Research Community and IU leadership. RSO seeks to be a trusted advisor to the Research Community and IU leadership. RSO does not approve or disapprove faculty/staff hiring, projects, collaborations, publications, proposals, travel, or the like. RSO does monitor for risks to the Research Community and IU research environment posed in these areas.
Research Security Reviews and Risk Indicators
What Does RSO Review?
RSO reviews and provides input in a number of instances, including, but not limited to:
- recruitment and visa sponsorship for both visiting scholars and faculty/staff (e.g., J-1, H-1B);
- international travel;
- sponsored awards;
- potential conflicts of interest/commitment; and
- international engagement.
Research Security Risk Reviews
A "research security risk" means an increased likelihood that research and development efforts or results will be misappropriated to the detriment of to the detriment of national or economic security, as well as related violations of research integrity and foreign government interference.4 RSO conducts reviews in various situations to mitigate research security risks. RSO seeks to work with the Research Community to mitigate research security risks in a way that maximizes the scope and impact of research and creative activities by the Research Community.
Visiting Scholars
When an IU faculty or staff member seeks to sponsor a J-1 visa for a visiting scholar through IU, RSO is notified by the Office of the Vice President for International Affairs ("OVPIA") and conducts a review for research security risks.
Faculty/Staff Hires
RSO serves as a resource to hiring managers, school leadership, and other University stakeholders recruiting faculty and staff positions, and conducts reviews for research security risks on an as-requested basis.
International Travel
RSO receives reports from the IU Chrome River system indicating international travel requests. RSO reviews travel for research security risks and advises travelers, as well as school leadership and other University stakeholders.
Sponsored Awards
RSO is notified by the Office for Research Administration (“ORA”) when a sponsored award is made by an international sponsor to IU. RSO advises if any research security risks are posed by the engagement.
Conflicts of Interest/Commitment
RSO monitors for research security risks posed by potential undisclosed conflicts of interest/commitment ("Conflicts") through various means, including, but not limited to, review of publications, non-U.S. patent filings, and disclosures of Conflicts by IU personnel pursuant to Policy UA-17.
International Engagement
When new primary or sub-agreements with international institutions are considered by OVPIA, RSO is notified and advises OVPIA of any research security risks.
Potential Research Security Risk Indicators
In its reviews, RSO looks for potential research security risk indicators ("PRI").
Indiana University prohibits discrimination on the basis of age, color, disability, ethnicity, sex, gender identity, gender expression, genetic information, marital status, national origin, race, religion, sexual orientation, or veteran status.
None of the foregoing may be used as a PRI in the course of RSO reviews. RSO is committed to upholding Policy UA-01, Non-Discrimination/Equal Opportunity/Affirmative Action. RSO seeks to use publicly available, reliable, and objective information sources when determining the existence of a PRI.
Potential Research Security Risk Indicators (PRIs)
- Failure to make full disclosure in proposals for federal or other sponsored awards, including, but not limited to, inclusion of current and pending support, other research support, and a complete biosketch
- Individuals or entities sanctioned by United States Government or collaboration/association therewith5
- Involvement in STEM field or with Critical and Emerging Technologies
- Individuals or entities listed on U.S. Department of Defense list of entities engaging in "problematic activity" or collaboration/association therewith6
- Entities based in or existing under the laws of a "foreign country of concern" or collaboration/association therewith7
- Individuals or entities with evidence of cooperation, affiliation, or association with government of a foreign country of concern or collaboration/association therewith
- Indicators of participation in a malign foreign talent recruitment program8
- Filing patent application in a foreign country of concern or filing in any other country prior to filing in the United States
Questions or Concerns?
C. Collin Rich
Chief Research Security Officer
collinr@iu.edu
Tad Mitchell
Director, Research Security Assurance
tadmitch@iu.edu
Footnotes
1 National Science and Technology Council, Guidance for Implementing National Security Presidential Memorandum 33 (NSPM-33) on National Security Strategy for United States Government -Supported Research and Development (2022)
2Research Security at the National Science Foundation (last March 20, 2024).
3 E.g., see: §1286, FY 2019 National Defense Authorization Act (Pub. L. 115-232); §223, FY 2021 National Defense Authorization Act (Pub. L. 116-283); CHIPS and Science Act of 2022 (Pub. L. 117-167); National Security Presidential Memorandum 33 ("NSPM-33"); NSPM-33 Implementation Guidance; Department of Defense Policy for Risk-Based Reviews of Fundamental Research (June 2023); OSTP "Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs" (Feb. 2024); OSTP "Policy Regarding Use of Common Disclosure Forms for the "Biographical Sketch" and the "Current and Pending (Other) Support" Sections of Applications by Federal Research Funding Agencies" (Feb. 2024); NSF Proposals and Awards Policies and Procedures Guide (Jan. 2024)
4 Department of Defense, Countering Unwanted Foreign Influence in Department-Funded Resarch at Institutions of Higher Education (June 29, 2023)
5 E.g., U.S. Department of Commerce, Bureau of Industry and Security ("BIS") Entity List, Supplement No. 4 to Part 744, Title 15 (2024); BIS Unverified List, Supplement No. 6 to Part 744, Title 15 (2024); U.S. Department of Treasury, Office of Foreign Assets Control ("OFAC") Specially Designated Nationals List
6 See: Countering Unwanted Foreign Influence in Department-Funded Research at Institutions of Higher Education (June 2023), Part 3, as required by Section 1286 of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (Pub. L 115-232), as amended
7 The term "foreign country of concern" is defined by the CHIPS and Science Act of 2022 (Pub. L. 117-167) as "(A) a country that is a covered nation (as defined in section 4872(d) of title 10 United States Code);" and "(B) any country that the Secretary, in consultation with the Secretary of Defense, the Secretary of State, and the Director of National Intelligence, determines to be engaged in conduct that is detrimental to the national security or foreign policy of the United States." Currently, these countries are the Democratic People's Republic of North Korea, the People's Republic of China, the Russian Federation, and the Islamic Republic of Iran.
8§10638(4), CHIPS and Science Act of 2022 (Pub. L 117-167)