Updates on Foreign Engagements and Research Security and Integrity
Dear Faculty, Researchers, and Staff:
As mentioned in prior communications from the Office of the Vice Provost for Research, the federal government remains concerned that some foreign governments do not demonstrate, as we do in the U.S., a dedication to open scientific exchange and seek to exploit U.S. and international research environments. With a continued commitment to openness in fostering research discoveries and innovation, the federal government is taking steps to protect intellectual capital, discourage research misappropriation, and ensure proper stewardship of funds.
In January 2021, National Security Presidential Memo-3 (NSPM-33) outlined the Administration’s expectations for protection against foreign government interference and exploitation in federally funded research and development. In January 2022, the Office of Science and Technology Policy issued guidance tofederal agencies around the implementation of NSPM-33. Over the comingmonths, we expect federal agencies to respond by modifying policies andprocedures with which universities will need to comply, and complete their plans for implementation of NSPM-33.
The five areas of research security addressed by NSPM-33 that will impact research and sponsored programs include 1) disclosure requirements and standardization, 2) digital persistent identifiers, 3) consequences for disclosurerequirement violations, 4) information sharing, and 5) research security programs.
Regarding disclosure requirements and research data security, tools and resources have been developed and faculty have been engaged through various outreach efforts to 1) facilitate understanding of agency-specific disclosure requirements for sponsored research; 2) communicate NYU policies and procedures along with best practices around data management planning; and 3) conduct research data risk assessments, categorize research data, andprovide secure environments for research data.
In the next 12-18 months, guidance, policies, and procedures will again be updated to achieve compliance with agency implementations for disclosure and the use of digital persistent identifiers. In addition, an institutional researchsecurity program will be developed to address requirements related to 1) cybersecurity, 2) foreign travel security, 3) research security training, and 4) export control training.
The Offices of Research Administration, Research IT, Libraries, andCompliance and Risk Management, with input from faculty and researchers at WSQ, NYUAD, and NYUSH, will conduct a gap analysis, create tools and training modules, and develop guidance to meet the federal standards forcompliance with NSPM-33 and certification of NYU’s research security program. We will continue to support the critical research and network of international collaborations across NYU while achieving compliance with government requirements around foreign interference.
Below are steps you can take now to ensure that you are appropriately disclosing affiliations and support to NYU and to external sponsors:
- Complete your annual NYU academic conflict of interest survey in Cayuse COI
- Familiarize yourself with key federal sponsor disclosure requirements (NIH and NSF)
- Contact your OSP Project Officer if you have questions or need assistance with creating your biosketch or current and pending support documentation in SciENcv or obtaining information on your sponsoredprojects from Cayuse SP via customized reporting tools
- Conduct research data risk assessments, categorize research data, and plan your secure environment for research data
- Utilize data management planning resources and explore data storage solutions for your research projects
- Register for an ORCID iD digital persistent identifier to centrally share andmanage your professional information (affiliations, grants, publications)
- Cormac Slevin, Global Research Manager (firstname.lastname@example.org) is available to host an outreach session for your lab or department on foreign activities andreview specific questions around NYU and sponsor-specific disclosure requirements. We appreciate your continued attention and commitment toconducting open, collaborative, and secure research at NYU.
Nancy Daneau, Associate Vice Provost for Research