University Disclosure

Overview 

Disclosure of External Interests and Commitments

Transparency is fundamental to maintaining research integrity, research security, and public trust. Stony Brook University's Disclosure of External Interests and Commitments Policy requires certain faculty, staff, students, and other researchers to disclose external interests, professional activities, appointments, affiliations, research support, and participation in certain Foreign Talent Recruitment Programs.

These disclosures help the University identify and appropriately manage potential Conflicts of Interest (COI) and Conflicts of Commitment (COC), comply with sponsor requirements, support responsible research, and protect the integrity and security of the research enterprise.

This page explains who must disclose, what must be disclosed, how to establish and maintain a University Disclosure Profile, and what to expect after submitting a disclosure. Additional guidance regarding Conflict of Interest, Conflict of Commitment, Foreign Talent Recruitment Programs, Organizational Conflict of Interest, and sponsor disclosure requirements is available through the Disclosure Program webpages and Disclosure Reference Guides.

Disclosure Requirements

University policy requires certain individuals to disclose external interests, professional activities, appointments, affiliations, research support, and participation in Foreign Talent Recruitment Programs. These disclosures help the University identify and appropriately manage potential conflicts of interest and commitment, comply with sponsor requirements, and support responsible research.

Annual Disclosure Required 

The following individuals are required to maintain an annual Disclosure Profile and certify its accuracy each year.

• Salaried faculty
• Researchers (salaried and non-salaried)
• Executive/senior leadership
• Other personnel who advise on, negotiate or approve, on behalf of the University, transactions, arrangements or agreements with external parties involving the use of University resources.

See Definitions for more information 

Situational Disclosure Required 

Certain individuals who are not required to complete an annual Disclosure Profile may still be required to submit a disclosure in specific circumstances.

This includes Research Foundation personnel who perform work on sponsored projects but are not primarily responsible for the design, conduct, or reporting of research, such as:

• Postdoctoral associates
• Research scientists
• Technicians
• Veterinarians
• Graduate students
• Undergraduate students
• Other project personnel (e.g., secretaries, animal caretakers, draftsmen)

These individuals are required to submit a Disclosure Profile only if they have a foreign external interest or activity related to their institutional responsibilities, including participation in a Foreign Talent Recruitment Program.

 What to Disclose

Disclosure Profile Guidance Flyer

All financial, personal and professional interests, activities and relationships that you or an immediate family member have with any non-University entities that create, or could be perceived to create, a conflict of interest or commitment that:

• Might be reasonably perceived to be related to your institutional responsibilities; or
• May otherwise present a conflict of interest or conflict of commitment, or the perception of such a conflict, with your duties to the University.

The following is a non-exhaustive list of the types of external interests and commitments of individuals and their immediate family members, whether located in the U.S. or outside of the U.S., that must be disclosed:

• External paid and unpaid positions/obligations at institutions other than Stony Brook, including: current relationships, relationships that occurred during the previous 12 months, and any anticipated future relationships, whether located in the U.S. or outside of the U.S.
• External resources/support provided by entities other than Stony Brook or Research Foundation for SUNY (e.g.: payments or remunerations, provision of or support for laboratory or other facilities, gifts, equity holdings or ownership, and sponsored travel).
• Relationship with an external organization (e.g.: research, consulting, sponsored travel, equity in external company, etc.).
• Intellectual property rights and interests.

• Participation in Foreign Talent Recruitment Program

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How to Disclose

Individuals required to disclose must establish and maintain a Disclosure Profile through the myResearch portal. The Disclosure Profile serves as the University's centralized record of an individual's external interests, commitments, appointments, affiliations, research support, and other reportable activities. Once established, it should be maintained throughout the year by updating new or anticipated reportable activities within 30 days of becoming aware of the reportable activity or commitment.

How to Complete Your Disclosure Profile in myResearch 

Annual Disclosure 

Create a Disclosure Profile:  Create a  Disclosure Profile through the myResearch portal.

Maintain a Disclosure Profile:  Maintain their Disclosure Profile by modifying their profile to account for new or anticipated external interests and/or commitments within 30 days of acquiring knowledge of such external interests and/or commitments.

Annual Disclosure Profile Certification:  Certify to the completeness and accuracy of their profile at least annually which includes during the annual disclosure period. 

Note: This Annual Disclosure Profile Certification is separate from the annual NYS Financial Disclosure Statement that is submitted to the NYS Joint Commission on Public Ethics (JCOPE) by filers.   Some individuals may be required to submit under both disclosure processes.

Situational Disclosure 

Individuals who are not required to complete an annual Disclosure Profile but who meet the situational disclosure criteria should contact the Office of Research Security to establish a Disclosure Profile through the myResearch portal. Once a profile has been established, disclosures must be updated within 30 days of acquiring knowledge of a new or anticipated reportable interest or commitment.

When to Disclose

The annual filing period is May 1 to May 31. Updates to a Disclosure Profile must be made within 30 days of acquiring knowledge of a new or anticipated reportable interest or commitment.

What Happens After I Submit? 

ORS reviews each Disclosure Profile to determine whether additional evaluation or coordination is required. Most disclosures require no additional action. When appropriate, ORS may request additional information, coordinate review with other University offices, or initiate review under the University's Conflict of Interest or Conflict of Commitment processes.

Related Guidance