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University of Wisconsin–Madison

Research Security Program

A Research Security Program is required by the federal government to protect against foreign government interference and exploitation at research institutions receiving federal funds. National Security Presidential Memorandum 33 (NSPM-33) is an executive branch directive intended to safeguard the security and integrity of federally funded research. Research security refers to national security concerns surrounding research involving types of sensitive data, intellectual property, export-controlled information and other risks.

Research security is important to protect public investment in research, prevent the misuse of research data and advanced technology generated at universities by malign actors, and to protect the safety and security of employees and students traveling abroad. The federal government is focusing on areas critical to protecting the security of U.S. research such as the disclosure of conflicts of interest and commitment, including relationships or affiliations with foreign entities, and research support provided by those entities. Federal agency partners have indicated that failure to disclose foreign relationships and activities may jeopardize eligibility for future funding. Our federal partners and U.S. research institutions continue to negotiate and clarify what the final NSPM 33 compliance requirements, forms, procedures and training will be. Our current understanding is that the final standards and requirements will be released by the end of the year.

UW–Madison values Open Research and Free Interchange of Information and International Research Collaborations and maintains its commitments to international faculty and student exchanges. UW-Madison strives to provide a welcoming environment to foreign students and scholars and to uphold academic freedom. We believe in the open dissemination of research and encourage our faculty and staff to collaborate with others to advance knowledge.

All of these perspectives help UW–Madison maintain its excellence in cutting-edge research.

Below are the components of the UW-Madison Research Security Program. This is a university-wide interdisciplinary collaborative effort involving research, technology security, export controls and international travel.

The Toolkit is a resource that informs researchers on the university’s research requirements and expectations and serves as a central location on where to contact university experts.

This resource provides information on the precautions that should be taken to maximize security in using and storing data.

  • Disclosures

Researchers are expected to disclose information about current and pending/other support to project sponsors.  Information may be disclosed in a proposal, during the Just-In-Time process, in a progress report, or at any time deemed appropriate by the sponsor.  UW–Madison policy puts the onus on the researcher to provide current, accurate, and complete information.

Faculty, staff, and others are required to complete Outside Activity Reports.  Outside activities that must be reported include compensation, ownership, leadership, foreign academic appointments, foreign research support, and travel (for researchers with federal grants).

Overarching guidance about what activities or support must be disclosed to which entities and in which documents are illustrated in the UW–Madison Disclosure Matrix.

Cybersecurity

The Office of Cybersecurity supports the CIO and the campus by leading and managing campus efforts to reduce risk. Strategies include appropriate handling of data, continued diagnostics and good processes and procedures to manage our intellectual property and other sensitive information.

The office helps researchers comply with Controlled Unclassified Information (CUI) requirements. The Office of Cybersecurity and the Office of the Vice Chancellor for Research and Graduate Education created a step-by-step process for researchers to follow. The process outline, forms and Q&As on these pages help users determine if their research is impacted by the CUI requirements and if so, what steps need to be taken.

UW-Madison has enacted or complies with the following policies:

Cybersecurity offers comprehensive required training for the university.

Export Control

The Export Control Office works with UW–Madison faculty, researchers, staff and students to ensure compliance with the U.S. Export Control laws and regulations, including the International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR) and Foreign Assets Control Regulations (FACR).

UW-Madison has enacted the following policies:

UW-Madison has developed the following training modules:

Outside Activities Reporting

All faculty, regardless of appointment, all academic staff with 50% or greater appointment, and all individuals listed as participants on human subject protocols or on federal grants are required to fill out an annual Outside Activities Report (OAR) and update whenever new outside activities are undertaken.

Foreign Travel Security

Foreign Travel Security

UW-Madison has many resources for faculty and staff who are traveling abroad. The International Division’s office of International Safety and Security (ISSD) is available to help you prepare for international travel. The International Safety and Security website offers broad resources and current information about: your destination’s risk environment; tips and best practices for planning safe travel; information about the university’s international health and medical insurance; and UW-Madison’s international travel policy.

The Export Control Office provides information on federal travel regulations and other guidance.

DoIT provides guidance and resources for protecting your data and devices when traveling.

  • 2022, established a working group to assess UW-Madison's preparedness for implementation of the Research Security Program
  • 2022, created an Interim Research Security Program Director to serve as the point of contact, manage the Research Security Program, and prepare the annual self-certification. 
  • 2023, established a Research Security Team to continue to review NSPM 33 guidance and the March 2023 draft Standards and Requirements
  • July 2023, published the Research Security Program website describing the established policy and training requirements required of the Security Programs Standard Requirement. 
  • September 2023, established a working group to create a a plan to establish a Research Security Program.
  • December 2023, enacted a Malign Foreign Talent Program policy.
Federal Laws, Regulations and Directives Pertaining to Research Security

The U.S. Government has enacted the following federal directives and legislation regarding disclosures, research security program requirements, and research security training:

Report a Research Security Concern

If you have concerns about any research security or compliance issue, please refer to the following information:

If you are Served with a Subpoena or Summons and Complaint, please contact the Office of Legal Affairs for assistance.

Foreign Government Talent Recruitment Programs and Malign Foreign Talent Recruitment Programs

UW-Madison PowerPoint: Foreign Government Talent Recruitment Programs

UW-Madison Policy UW-4818: Prohibition on Participation in Malign Foreign Talent Recruitment Programs

Malign Foreign Talent overview: UW Malign_talent_program_document

Representative List of Foreign Government Talent Recruitment Programs: This is not an exhaustive list but represents those that are currently identified.

 

For questions please contact the Export Control Office 

Additional resources: