Sponsor & Agreement Requirements
Overview
Research security, export control, information protection, disclosure, and other project-specific requirements are often established through sponsor solicitations, funding announcements, notices of award, research agreements, contracts, subawards, and other project documents.
Most sponsor requirements and agreements do not require review by the Office of Research Security (ORS). However, some contain provisions that establish obligations affecting how research is conducted, who may participate, how research information is shared or protected, or what sponsor and regulatory requirements apply throughout a project.
ORS assists researchers in identifying and addressing research security, export control, international research, research information protection, and other project-specific requirements before research begins.
REQUEST A RESEARCH SECURITY REVIEW
Contact ORS If Project Documents Include
Contact ORS if a proposal, solicitation, award, contract, agreement, or other project document includes requirements related to:
- Export controls or references to the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), or export licensing.
- Restrictions on participation by foreign persons or international collaborators.
- Publication review, publication approval, or restrictions on dissemination of research results.
- Proprietary, confidential, government-controlled, or other restricted research information.
- Data protection, secure research computing, or enhanced cybersecurity requirements.
- Federal Contract Information (FCI), Controlled Unclassified Information (CUI), or other government safeguarding requirements.
- International collaborations; foreign sponsors; foreign governments; foreign military or defense organizations; or organizations located in Countries of Concern.
- Sponsor-specific research security, disclosure, certification, or prior approval requirements.
- Restrictions on sharing research information, software, technology, equipment, materials, or technical information.
Key Considerations
Research security requirements may be established by a sponsor, incorporated into an award, or included in a research agreement or other project document.
These requirements may affect:
- Project personnel.
- International collaborations.
- Research information.
- Data protection.
- Secure research computing.
- Sponsor disclosures and certifications.
- Research project oversight.
Researchers should understand these requirements before beginning project activities.
Some projects include export control provisions that restrict access to equipment, software, technology, technical information, or other research materials.
Project documents may also establish requirements related to export licensing, foreign person participation, or international transfers.
Researchers should contact ORS whenever export control requirements are identified or suspected.
Some sponsors and agreements establish enhanced requirements for protecting research information.
These requirements may involve:
- Proprietary or confidential research information.
- Government-controlled information.
- Controlled-access research data.
- Secure research computing.
- Project-specific Data Protection Plans.
ORS assists researchers in identifying appropriate safeguards and coordinating implementation with the appropriate University offices.
Research involving international collaborators, foreign sponsors, foreign governments, or other foreign organizations may establish additional research security requirements.
Researchers should contact ORS whenever project documents involve:
- International collaborations.
- Foreign research funding.
- Foreign organizations.
- Countries of Concern.
- Restricted entities.
- International research activities requiring sponsor review or certification.
Some sponsor requirements and agreements establish conditions affecting publication or project participation.
Examples include:
- Sponsor review prior to publication.
- Publication delays.
- Restrictions on dissemination of research results.
- Restrictions on participation by certain individuals.
- Limitations on access to research information or technology.
These provisions may affect research security, export control compliance, or sponsor obligations and should be reviewed before research begins.
Depending on their content, ORS may review research security provisions contained in:
- Sponsor solicitations and Requests for Proposals (RFPs).
- Notices of Funding Opportunity (NOFOs).
- Award terms and conditions.
- Sponsored research agreements.
- Collaboration agreements.
- Non-Disclosure Agreements (NDAs).
- Data Use Agreements (DUAs).
- Material Transfer Agreements (MTAs).
- Software license agreements.
- Memoranda of Understanding (MOUs).
- Subawards and subrecipient agreements.
- Other research documents establishing project-specific requirements.
The need for ORS review depends on the requirements contained within the document, not the type of document itself.
Many research documents require review or execution by an authorized University office.
Depending on the document and the nature of the research, review may involve the Office of Sponsored Programs, Research Foundation, Office of General Counsel, Procurement, Research Compliance, Information Security, ORS, or other administrative offices.
Faculty and researchers should not sign agreements on behalf of the University unless they have been specifically authorized to do so.
If you are unsure whether ORS review is needed or which office should review a document, contact ORS before proceeding.
Related Guidance
| Related Guidance | Description |
|---|---|
| International Collaborations | Guidance for planning, establishing, conducting, and managing research collaborations with international researchers, institutions, companies, and organizations. |
| Sharing Research Information | Guidance for sharing research information, data, software, technology, technical information, presentations, publications, or other research outputs with collaborators, sponsors, companies, government agencies, or other third parties. |
| Working with Proprietary & Confidential Research Information | Guidance for receiving, accessing, using, storing, sharing, and protecting proprietary or confidential research information received from sponsors, collaborators, companies, universities, and other external organizations. |
| Working with Government Information | Guidance for receiving, accessing, using, storing, sharing, and protecting government information, including CUI, FCI, Government-Furnished Information (GFI), and other government-controlled information. |
| Data Protection Plans | Guidance for developing, implementing, and maintaining sponsor-, contractual-, or institutionally required Data Protection Plans. |
| Secure Research Computing | Guidance for research requiring secure research computing environments, specialized storage, controlled access, or sponsor-required cybersecurity safeguards. |
| Restricted Entity Screening | Learn how organizations and individuals are screened against U.S. government restricted party and entity lists before certain research activities. |
Frequently Asked Questions
Does ORS review every proposal or research agreement?
No. Most proposals, awards, and research agreements do not require ORS review. ORS typically becomes involved when project documents establish research security, export control, information protection, or other project-specific requirements.
When should I contact ORS?
Contact ORS whenever sponsor requirements, award terms, or agreement provisions establish obligations related to research security, export controls, international research, information protection, or sponsor disclosures, or whenever you are uncertain whether these requirements apply.
Does ORS approve research agreements?
ORS reviews research security, export control, international research, and research information protection provisions when appropriate. Other University offices review legal, financial, procurement, intellectual property, and other institutional matters within their areas of responsibility.
What should I look for in sponsor requirements or agreements?
Researchers should pay particular attention to requirements involving:
- Export controls.
- International collaborations.
- Publication restrictions.
- Information protection.
- Government-controlled information.
- Secure research computing.
- Foreign person participation.
- Sponsor disclosure or certification requirements.
Need Assistance?
Research security, export control, and information protection requirements are often established before a project begins through sponsor solicitations, award terms, research agreements, and other project documents.
Early consultation with ORS helps researchers identify applicable requirements, coordinate with the appropriate University offices, and implement appropriate safeguards before project activities begin.