Policy on Sensitive Technology Research and Affiliations of Concern

 

New Policy on Sensitive Technology Research and Affiliations of Concern

Canada’s world-class research ecosystem is defined by excellence and its open and collaborative nature. This openness can make it a target for foreign influence that increases the potential for research and development efforts to be misappropriated to the detriment of national security. For example, the illicit transfer of knowledge - especially in transformational research areas such as AI, quantum computing, and genetic engineering that could have dual-use applications for military and surveillance purposes - poses major challenges to Canada and its allies.

The federal government has been active in supporting researchers and institutions to protect Canada’s research, providing advice and tools through the Safeguarding Your Research portal, and implementing national security considerations into the development, evaluation, and funding of research partnerships through the National Security Guidelines for Research Partnerships.

On February 14, 2023, the federal government announced its intent to further protect Canada’s research, its institutions, and its intellectual property by announcing that Canada would adopt an enhanced posture regarding Canada’s research security. The resulting new Policy on Sensitive Technology Research and Affiliations of Concern was developed in close consultation with implicated federal departments and agencies including Canada’s federal granting councils – the Canadian Institutes of Health Research (CIHR), the Natural Sciences and Engineering Research Council of Canada (NSERC) and the Social Sciences and Humanities Research Council of Canada (SSHRC) – as well as the Canada Foundation for Innovation (CFI), Global Affairs Canada (GAC) and Canada’s research community through the Government of Canada-Universities Working Group.

In the development of this policy, Canada focused on ensuring that Canada’s research ecosystem remains as open and internationally collaborative as possible, in alignment with its foundational principles of transparency, merit, academic freedom, and reciprocity. In so doing, this enhanced posture is meant to safeguard, but not limit, Canada’s cutting edge research by mitigating research security risks. To appropriately protect Canada’s research ecosystem, the Government of Canada will continue to work in close collaboration with Canada’s research community, universities and our provincial and territorial government partners.

Starting May 1, 2024, research grant and funding applications submitted by a university or affiliated research institution to the federal granting councils and the Canada Foundation for Innovation involving research that advances a sensitive technology research area will not be funded if any of the researchers involved in activities supported by the grant are affiliated with, or in receipt of funding or in-kind support, from a university, research institute or laboratory connected to military, national defence, or state security entities that could pose a risk to Canada’s national security. To support this, Canada is releasing two lists that provide clear, defined, and transparent guidance so that researchers can quickly and efficiently determine if these new requirements apply to their research.

First, the Government of Canada is publishing a list of Sensitive Technology Research Areas that support the development and advancement of new technologies. It will allow researchers to self-assess whether their proposed research is within the scope of this new requirement. Research that will merely use an existing technology is not within the scope of this policy.

Second, the Government of Canada is publishing a list of Named Research Organizations connected to military, national defence, or state security entities that could pose a risk to Canada’s national security. This list was developed by Public Safety Canada and with experts across the federal government using a risk-based approach.

Canada’s research security policies remain country-agnostic. Recognizing that threats evolve and can come from anywhere in the world, both lists will be regularly reviewed to keep pace with the latest developments in research and to ensure that we continue to address evolving risks in an increasingly complex geopolitical environment.

This policy will be implemented through an attestation by researchers that have a named role (for example, applicants co-applicants, and collaborators) as part of the grant / funding application process for research projects advancing sensitive technology research areas. The federal granting councils and the Canada Foundation for Innovation are developing procedures and guidance to implement this new policy. More detailed information on the implementation of the policy, including forms and procedures, will be published on their respective web pages in advance of the policy implementation.

While the policy first came into effect on May 1, 2024, the Government of Canada may take research affiliations into account prior as part of research funding decision-making processes, should risks be identified. In particular, research affiliations will be considered as part of the national security assessment of any research grant applications that are subject to the National Security Guidelines for Research Partnerships.

Canada recognizes that some research collaborations in sensitive technology research areas not involving connections to listed named research organizations may still present risks, and as such, researchers and institutions are encouraged to continue to exercise due diligence in all of their research partnerships, and to make full use of other research security tools available to them including those provided on the Safeguarding Your Research portal. Canada will also continue to encourage Canadian universities to implement a similar enhanced posture for all research partnerships and collaborations in sensitive technology research areas.

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Principles

The development and implementation of the Policy on Sensitive Technology Research and Affiliations of Concern is guided by the following principles:

  • Risk-targeted: the policy is based on evidence and focused on the most sensitive technology research areas and highest national security threats.
  • Science appropriate: the policy minimizes impacts on Canada’s research and research funding ecosystem by ensuring that it is as open as possible and as secure as necessary.
  • Transparent: criteria and guidance are clear and openly accessible to the research community.
  • Free from Discrimination, Harassment, and Coercion: this policy focuses on specific threats identified with regards to the military, national defence, or state security entities that could pose a risk to our national security; it does not target or profile any group of people or country.
  • Collaboration with the research community: through continued dialogue and consultation-development of research security measures.

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Definitions

  • Activities supported by the grant: Any contribution to research related to the funded grant and throughout the lifecycle of the research project(s), up to and including the dissemination of research results (e.g., publications).
  • Affiliation: Individuals are considered affiliated to any organization at which they are employed, appointed, or conduct research. In cases where individuals hold multiple affiliations, all must be identified and considered when ensuring compliance to this policy.
  • Funding and in-kind support: Monetary or non-monetary contributions, that include but are not limited to goods, equipment, materials and supplies, professional services, use of facilities (office space, lab access), software, technologies and databases.
  • Researcher: Any person conducting research activities. For the purposes of funding applications to the federal granting councils and the Canada Foundation for Innovation, researchers can hold different roles, including but not limited to applicants, co-applicants, collaborators, and highly qualified personnel (HQP). HQP can include undergraduate and graduate students, post-doctoral fellows, as well as research staff.
  • Sensitive technology research area: areas of research identified on the list of Sensitive Technology Research Areas. For the purposes of this policy, only projects in listed sub-categories of areas of research are considered sensitive and trigger an attestation requirement. Areas of research not covered by the sub-categories of the list are not currently considered sensitive for the purposes of this policy and therefore do not trigger an attestation requirement. Within the scope of this policy, research in a sensitive technology research area is not a concern on its own, unless it is conducted in affiliation with a research-performing institution of concern. Research in these areas with likeminded collaborators, partners, and institutions is strongly encouraged.
  • Universities, research institutes and laboratories connected to military, national defence or state security entities that could pose a risk to our national security: as defined by the list of Named Research Organizations. The list is a non-exhaustive inventory of universities, research institutions, or laboratories connected to military, national defence or state security organizations that could pose a risk to Canada’s national security.

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Steps for Researchers: How to Comply with the New Policy

To comply with this new policy, applicants must undertake a two-step process prior to applying for a grant / funding. Applicants are encouraged to complete the steps below well in advance of the grant application submission, in consultation with their institution’s research grants office.

Step 1 : Determine whether your grant / funding will aim to advance any sensitive technology research area

Principal investigators (PIs) applying to any federal research grant funding opportunity offered by NSERC, SSHRC, CIHR or to funding offered by the Canada Foundation for Innovation must review the list of Sensitive Technology Research Areas to determine if their proposed research will aim to advance any of the listed areas.

A grant should be identified as aiming to advance a STRA if the research supported during the course of the grant will aim to support the generation or discovery of knowledge that contributes to progress in the development of a technology described in the sub-categories of the list of Sensitive Technology Research Areas.

  • If the proposed research will not aim to advance any of the listed sensitive technology research areas, no further steps are required under this policy. Research that will merely use an existing technology is not included in this policy.
  • If the proposed research will aim to advance any of the listed sensitive technology research areas, the following step must be followed whereby all researchers with named roles involved in the activities funded by the grant must attest that they are not affiliated with, or in receipt of funding or in-kind support, from any of the institutions on the list of Named Research Organizations.

Step 2 : Check researchers’ affiliations

All researchers involved in the activities funded by a research grant advancing a sensitive technology research area must review the list of Named Research Organizations. If a researcher is affiliated with, or in receipt of funding or in-kind support, from one or more of the institutions on the list of Named Research Organizations, they must terminate these connections in order for the federal grant application process to continue. Only currently held affiliations are of concern for this policy; past affiliations will not be considered. For example, if an undergraduate student has previously studied or worked at a listed institution but has since left the institution and maintains no formal obligation to return to being affiliated with the listed institution, then they are not currently affiliated to that institution and do not raise a concern with regards to this policy.

If a researcher chooses to continue to be affiliated with, or in receipt of funding or in-kind support, from a listed institution, the grant application will not be eligible for federal funding. The grant application process can only proceed if the connection to the listed institution is terminated, or if the researcher in question is no longer part of the grant application. Moreover, researchers affiliated with, or in receipt of funding or in-kind support, from a listed institution cannot join a project once the grant has been awarded, unless they terminate these connections prior to joining the project.

All researchers with named roles engaged in activities supported by the research grant will be required to attest that they have read, understood, agree with, and are compliant with this policy. They and their research team(s) will be required to comply with the policy for the duration of the federal grant.

This new policy is focussed on researcher affiliations and targets the highest risk collaborations with military and state security-related institutions. As part of this policy, researchers should keep in mind that institutions that are not included on the Named Research Organizations list at this point in time may still pose a risk to Canada’s research and are encouraged to apply due diligence practices to mitigate risks that may be associated with any collaboration or partnership in a sensitive technology research area. A suite of research security guidance and tools is available on the Safeguarding Your Research portal, including the National Security Guidelines for Research Partnerships which apply as a requirement to certain federal research partnership funding opportunities.

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Validating Information: What Happens After Application

Federal research grant applications and Canada Foundation for Innovation funding applications will be subject to validation processes to ensure compliance with the STRAC Policy. In operationalizing these validation processes, the Government of Canada remains committed to minimizing the impact of this policy on funding decision service standards. Two types of validation processes will be applied, to determine whether applicants appropriately identified their grants as aiming to advance a sensitive technology research area, and to validate the accuracy of submitted attestation forms.

Validation of the advancement of Sensitive Technology Research Areas

The funding organizations will conduct periodic validations, with engagement from subject matter experts where required, on a randomized subset of funded grants to ensure that applicants have appropriately identified whether their grant would aim to advance a listed Sensitive Technology Research Area as defined at the time of application. In cases where the validation process uncovers information that suggests that a grant application should have been identified as aiming to advance a sensitive technology research area, the funding organization will inform the applicant and may request the submission of attestation forms.

Validation of attestation forms and compliance with the STRAC Policy

Grant applications that were identified to be aiming to advance a sensitive technology research area will be subject to a process to validate the accuracy of attestation forms in compliance with the policy, according to the version of the list of Named Research Organizations defined at the time of application. Validation will take place through one of three streams:

  1. For all applicable funding opportunities and programs, a subset of funded grants identified as aiming to advance a sensitive technology research area will be randomly selected for validation. This validation process will be conducted post funding decision and will not impact the service standards of each funding opportunity. The attestation forms provided as part of the grant application, as well as the title and publicly available abstract of the related grant, will be shared by the corresponding funding organization with Public Safety Canada to coordinate the validation of attestations.
  2. For federal research partnership grant funding applications where the National Security Guidelines for Research Partnerships apply and that are referred to Public Safety Canada under the Risk Assessment Review Process, the validation of attestations will be completed in parallel. In these cases, validation will typically occur prior to a funding decision.
  3. Should the corresponding funding organization become aware of information suggestive of a potential policy breach, validation may occur on an ad-hoc basis.

A researcher’s eligibility to participate in the activities supported by the grant may be impacted if the validation process uncovers information that suggests that they may have provided inaccurate information as part of an attestation form provided for the purposes of a grant application. Further action may be taken to address this finding, pursuant to the corresponding funding organization’s authorities and the terms and conditions of the grant. The corresponding funding organization will work with the relevant institution(s) to address the issue and to determine the best route forward to minimize impacts, where possible, on the research, on the grant and on the associated research personnel.

Findings that indicate a potential misrepresentation by a researcher in a grant application submitted to the federal granting agencies, or a potential breach of agency policies or requirements for certain types of research, may further invoke an allegation of a breach of the Tri-Agency Framework: Responsible Conduct of Research (RCR). Recourse for breaches of the RCR Framework varies by severity, intentionality, and impact of the breach, but may include and is not limited to: withholding installments of and/or termination of the grant; a requirement to reimburse funds; and ineligibility to hold/apply for federal funding, for a defined period of time or permanently.

Additional information regarding the validation process can be found through the Tri-Agency guidance on the Policy on Sensitive Technology Research and Affiliations of Concern.

Innovation, Science and Economic Development Canada (ISED) will report annually on the outcomes of the validation process through the Annual Report on the Implementation of Research Security Policies in the Federal Granting Agencies and the Canada Foundation for Innovation, subject to applicable laws including the Privacy Act. ISED, the funding organizations, and PS will also review results annually to improve this process, based on lessons learned and available data.

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For More Information

The federal research granting councils and the Canada Foundation for Innovation are implementing this policy. More detailed information, including forms and procedures, can be found on their respective web pages.

Applicants and research institutions are also invited to communicate with the Research Security Centre if they have further questions.

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