RCI Research Security

UC San Diego is committed to sustaining an environment that attracts and retains the brightest scholars and most exciting scholarships. This is embodied by our commitment to the University of California's principles of academic freedom. Our many talented international populations of scholars and students, both foreign-born and natural citizens, are essential to the research and education enterprise on our campus. We value all collective contributions beyond measure.

UC San Diego believes that scientific research and academic scholarship work best with open collaboration whether nationally or internationally. We are committed to having an open, welcoming campus; respecting the rights of faculty, staff, and students; and abiding by our Principles of Community. As a global research university, we proudly have hundreds of faculty and educators from around the world teaching in our classrooms.

UC San Diego and its researchers must adhere to federal regulations, state laws and UC San Diego policy on Research Security which contains many aspects such as training, reporting and disclosure requirements around international engagements and collaborations. By prioritizing proper documentation and reporting, we can ensure the university's continued access to federal funding and maintain our reputation as a trusted steward of research awards. Accurate and timely reporting enables us to demonstrate our commitment to compliance and uphold the highest standards of research integrity.  Further we need to address the federal government's increasing concerns about foreign entities unduly influencing U.S. research, such as malign foreign talent recruitment programs and other international collaborations; and adhere to the guidelines and policies the government puts in place.

It is essential for UC San Diego researchers to be transparent about any affiliations with foreign entities when applying for federal contracts and grants. Only by a researcher’s full disclosure will UC San Diego be in compliance with the University of California principles and federal regulations and therefore able to advise, assist, and protect researchers and their work. This situation is evolving and fluid. Please continue to keep yourself apprised.

Similar to most U.S. federal agencies, UC San Diego performs a risk-based approach with our risk assessment and Risk Mitigation Plans. This approach is crucial in today's collaborative research environment, where foreign interference and unauthorized access to sensitive information are growing concerns. Our risk based approach helps to align UC San Diego’s activities with preserving academic freedom and research collaboration, while maintaining compliance with federal regulations, state laws and UC San Diego policy.  RCI-RS will work with the researchers, the Sponsored Project Office and other compliance offices to review, assess, and develop a Risk Mitigation Plan. 

If you have questions or federal agencies are asking questions, please immediately contact Jennifer J. Ford, RCI Operational Executive Director at RCIresearchsecurity@ucsd.edu to discuss, assess the risk and develop a Risk Mitigation Plan. Once a Risk Mitigation Plan is developed, then the applicable Researchers participating in the project or program will need to review and provide concurrence to comply.

In August 2023, UCOP’s former President Drake issued a framework for reviewing and accepting any UC international affiliations and agreements involving emerging technology and countries of concern to the U.S.. Government.  RCI-RS assists the central office with signature authority (i.e., Sponsored Project Offices, Global Engagement, Advancement, etc.) to provide the risk assessment and mitigation plan for activities whether for research or other agreements that require enhanced review by UCOP. This UCOP enhanced review framework includes:

• Campus-level and UCOP review of all institution-level affiliations and agreements related to emerging technology and involving countries of concern to the federal government. 
  
  
• Emerging technologies include those listed by the Department of Commerce, Bureau of Industry and Security in 83 FR 58201 including, but not limited to, Artificial Intelligence (AI) and Machine Learning, Quantum Information/Sensing, Semiconductor and Microelectronics, Biotechnology, and other areas identified by UC San Diego’s Export Control Officer based on evolving federal government classification of emerging technology important to national security. Researchers need to review the current list of Critical and Emerging Technology (CET) under the National Science and Technology Council.
  
  
• • Countries of concern include Qatar, Saudi Arabia, United Arab Emirates, the People’s Republic of China (including Hong Kong and Macau), the Democratic People’s Republic of Korea (North Korea), the Russian Federation, and the Islamic Republic of Iran. See e.g., Section 19221 of the CHIPS and Science Act of 2022 [42 U.S.. Code § 19221]; Section 117 of the U.S. Higher Education Act of 1965; and https://www2.ed.gov/policy/highered/leg/institutional-compliance-section-117.pdf.

• UCOP has developed enhanced review and approval guidance that must be reviewed by the researcher and applicable department or ORU.
  
  
• RCI-RS, along with the applicable authorized central office, will collaborate with the researcher and the applicable department or ORU to gather information, provide guidance and perform a review regarding potential activities such as engagements, conduct campus evaluation and endorsement, and make recommendations for risk mitigation measures, if appropriate. 

RCI-RS provides consultations on all types of international collaborations and opportunities afforded to researchers.

Institutional Engagements: UC San Diego engages in many international engagements for research, education, clinical or societal benefit. If you are contemplating or beginning an institution-level engagement with a country of concern to the U.S. Government, please collaborate with your divisional/unit leadership to evaluate whether the engagement poses a level of risk to your research, intellectual property, and due diligence measures that may be required with federal agency funding. UCOP has developed enhanced review and approval guidance to help determine which engagements require enhanced review, whether to proceed with engagement, and identify risk mitigation measures as needed. 

For interest in an institutional international agreement, please also reach out to Global Initiatives.

Individual Engagements: UC San Diego faculty and researchers are offered the ability to engage internationally at conferences, research engagements, foreign travel, foreign talent recruitment programs (FTRP), presentations, and publications with international colleagues. 

If you are offered and contemplating an international engagement and have or plan to have federal funding, please be sure you are aware of the UC policy on the prohibition of participating in malign FTRP. Before agreeing, please consider consulting with RCI-RS.

The University of California has developed Research Security Training consistent with the CHIPS and Science Act and National Security President Memo 33 for covered individuals applying for federal research funding. Topics include:

• An Overview of Research Security
• Case Studies
• International Collaboration
• Disclosure
• Information and Data Security
• Elicitation
• Talent Recruitment Programs and Malign Foreign Talent Recruitment Programs
• International Travel

Researchers must take their Research Security Training at University of California, via UC Learning.