Policies and Procedures

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Export Controls

Notre Dame expects research activities performed for any sponsor, especially non-U.S. sources, will be fundamental in nature and placed in the public domain or disseminated freely in open publication, without restrictions. Any deviation from this practice should be discussed with Notre Dame Research Administration prior to accepting the work; a separate review by Notre Dame’s Export Control officer may be required.

To ensure compliance with the University’s obligations under U.S. export control laws and other applicable laws and regulations, the University must maintain a thorough understanding of the entities with which researchers work and share information. Accordingly, University faculty members, staff, and students are required to coordinate with Notre Dame’s Export Control Officer in any case in which collaboration or sponsorship of research with University personnel or is proposed by a non-U.S.-owned company or foreign government-related entity (either a person, company, or governmental organization) in order to verify that export control or U.S. government sanction obligations are satisfied.

Export control regulations seek to protect our national economic competitiveness, national security, and enforce U.S. trade sanctions. These regulations are complex and constantly evolving. For example, several countries are under comprehensive federal embargo (Cuba, Iran, North Korea, Syria, and the Crimea Region of the Ukraine). Travel to/from these countries/territories should be disclosed to Notre Dame’s Export Control Officer as early as possible in advance of the anticipated travel to ensure appropriate clearance can be obtained. 

Notre Dame faculty and staff members traveling internationally on University business should register at the University’s Travel Registry; students are required to register. International travelers should also consult with the Office of Information Technologies to ensure that any information carried abroad is properly secured and to review the Information Security Standards for International Travel. 

For full details on export control, please visit research.nd.edu/our-services/compliance/export-control. 

Intellectual Property

Pursuant to the University’s Intellectual Property Policy, Intellectual property and inventions must be promptly disclosed and appropriately reported to the IDEA Center using the Invention Disclosure Form to ensure intellectual property is protected.

Release of Unpublished Results

There are longstanding considerations to be taken into account regarding the release of unpublished results, depending on the particulars of a situation. In summary, non-physical (information, data, etc.) results of fundamental research may be shared, assuming that the research is: not subject to any export/dissemination controls (i.e., it can be widely published); the research is not subject to pre-publication approval or other restrictions or limitations by the sponsor; the research is not labeled as proprietary or confidential (could be the case under service/testing/fee-for-service contracts); no citizenship requirements were imposed on team conducting the research; and the research was conducted at the University of Notre Dame.

Securing Materials, Data & Confidential Information

Faculty members and staff who plan to share research materials or data with other institutions, foreign or otherwise, should ensure that an institutionally approved agreement is in place between Notre Dame and that institution, such as a material transfer agreement, data use agreement, or nondisclosure agreement to govern the use of those materials or data. Notre Dame Research Administration and Compliance (NDRAC) provides guidance on these agreements.

Similarly, faculty members and staff should consult with NDRAC before accepting any sensitive or controlled information under a research contract that may require heightened physical or cybersecurity requirements.

Faculty members and investigators must ensure that all agreements are reviewed and signed by institutional officials with specific delegation of signatory authority under the University’s bylaws.

For more information on agreements, please contact the Research Contracts Team by emailing rca@nd.edu. 

Related Policies & Procedural Resources

Need More Information?

The Office of General Counsel maintains the University’s policy repository at policy.nd.edu. Research-related policies are available here.

For relevant forms, codes, and policies, please visit the Resource Library.