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Office of Research Security

Research Security News

DUAs, NDAs, MTAs and Other Agreements Need OSP Review

Faculty who receive a Data Use Agreement (DUA), data access agreement, Non-Disclosure Agreement (NDA), Material Transfer Agreement (MTA), confidentiality agreement, or similar document from an outside organization should not sign it individually or begin accessing the data before institutional review. These agreements may create legal, regulatory, security, privacy, export control, or sponsor-compliance obligations for Clemson, even when the data appear routine or the project is already underway.

These agreements should be routed to the Office of Sponsored Programs before signature or acceptance. OSP will coordinate with the appropriate Clemson offices as needed to determine whether the agreement requires additional review, such as data security planning, privacy review, export control review, controlled data handling requirements, or use of an approved secure computing environment. Faculty should contact OSP before signing, downloading, receiving, storing, sharing, or analyzing data under a DUA.

NIH Clarifies Foreign Component Definition and Reporting Expectations

The National Institutes of Health has issued Notice NOT-OD-26-084, Reminder - Definition of Foreign Components, to clarify that NIH has not expanded its longstanding definition of a foreign component, even as NIH oversight of foreign collaborations has increased. NIH defines a foreign component as the performance of any significant scientific element or segment of a project outside the United States, whether by the recipient or by a researcher employed by a foreign organization, and regardless of whether NIH funds are expended. Examples may include human subjects or animal work at a foreign site, extensive foreign travel for data collection or similar activities, use of facilities or instrumentation at a foreign site, collaborations with investigators at a foreign site expected to result in co-authorship, or receipt of financial support or resources from a foreign entity.

NIH also emphasizes that foreign co-authorship does not automatically mean a foreign component exists in every case, but most instances of co-authorship involving a foreign collaboration may require review. NIH recipients should report foreign co-authorship to the funding Institute or Center as soon as they become aware of it so NIH can determine whether additional steps are needed. Faculty should also ensure NIH-funded publications accurately acknowledge federal support, avoid attributing publications to awards that did not support the work, and review NOFO restrictions carefully because some NIH programs do not permit foreign components.

Source: NIH Notice NOT-OD-26-084

DOE Prohibits Participation in Malign Foreign Talent Recruitment Programs

The U.S. Department of Energy has highlighted federal restrictions prohibiting participation in malign foreign talent recruitment programs. These restrictions are part of the federal government's broader research security framework and are intended to prevent foreign governments or affiliated entities from using talent recruitment arrangements to obtain U.S. research, technology, intellectual property, or federally funded expertise in ways that conflict with U.S. national and economic security interests.

Faculty should carefully review any foreign appointment, affiliation, consulting arrangement, talent program, sponsored position, laboratory appointment, or similar offer before accepting or continuing participation. Arrangements that include compensation, access to research results, obligations to recruit others, duplicate commitments, undisclosed appointments, transfer of intellectual property, or requirements to perform work for a foreign institution may raise research security concerns. Faculty with questions about a foreign affiliation or talent program should contact the appropriate Clemson offices before signing or participating.

Source: DOE: Prohibition on Malign Foreign Talent Recruitment Program Participation

International Travel Alert: Hong Kong Device Access Requirements

Faculty, staff, and students traveling to or transiting through Hong Kong should be aware of recent changes to Hong Kong's National Security Law implementation rules. According to the travel alert shared for faculty communications, as of March 23, 2026, individuals in Hong Kong, including U.S. citizens, may face criminal penalties for refusing to provide passwords or decryption assistance for personal electronic devices such as laptops and cell phones. The alert also noted that Hong Kong authorities may have expanded authority to take and retain devices they allege are connected to national security matters.

Researchers traveling internationally should consider whether their devices contain unpublished research, export-controlled technical data, controlled unclassified information, confidential sponsor information, identifiable human subject data, proprietary information, or other sensitive Clemson data. Before travel, faculty should consult Clemson guidance on international travel, data security, and export control review, and should avoid carrying unnecessary sensitive data on personal or University devices. This is one of those "your laptop may be more interesting than your passport" situations - plan accordingly.

Source: DSSPPP: Hong Kong Security Alert

Safeguarding Research Data, Intellectual Property, and Technology

A joint federal publication, Safeguarding Our Data, Intellectual Property, and Technology from Non-traditional Collectors, warns that foreign governments may seek to acquire U.S. technology and intellectual property by using academics, students, researchers, business professionals, or technology professionals as "non-traditional collectors." The publication explains that these individuals may not have a direct relationship with a foreign intelligence service, but may still acquire intellectual property, proprietary information, sensitive technology, research data, or personally identifiable information to support a foreign government's economic, military, technology, or national development goals. The publication specifically identifies countries such as China, Iran, and Russia as examples of governments seeking to acquire U.S. technology and intellectual property through these methods.

The publication encourages organizations to watch for indicators such as false or incomplete information on applications, unusual interest in U.S. government-funded research or personnel, unauthorized use of recording devices or removable media, attempts to conceal foreign affiliations or funding, suspicious computer activity, and efforts to access sensitive information outside the scope of assigned duties. Recommended mitigation steps include vetting individuals with access to sensitive work, protecting important data with encryption and strong authentication, limiting access to sensitive research and information systems, providing clear guidance on device and travel security, and reinforcing reporting mechanisms for suspicious activity.