USC is engaged in research around the globe, studying health, culture and environment in other countries, collaborating with scholars in foreign institutions, creating corporate research partnerships, and attracting students from overseas. USC supports the participation of all students, regardless of their national origin or religious affiliation, in our research and educational programs, and encourages our researchers to contribute to the needs for research that occur around the world.
- Exception Request to Conduct Restricted Research: – Under USC’s International Collaborations and Export Controls policy, all sponsored projects that restrict the ability of researchers to freely share the output of their research, or that restrict publication on the basis of nationality, require the Principal Investigator to obtain approval from the University to proceed.
- USC Policy on International Collaborations and Export Controls – Provides guidance on travel and relationships in foreign countries, as well as funded research that carries restrictions on exports and publications.
- USC International Travel Policy – Information on complying with international travel restrictions.
- International Human Subjects Research – Procedures for the protection of human research subjects internationally may be different from U.S. federal regulations and institutional policies. Contact the IRB for more information.
Frequently Asked Questions
Any clause(s) that:
- Permits the sponsor to prevent the publication of research
- Restricts participation and/or access to research based on
Clauses stipulating that publication is conditional upon the approval or agreement of the sponsor require review under this policy. Examples include:
- University shall not disclose any information or results made in the performance of the work without prior written approval of the
- Sponsor shall own all data and results made in the performance of the work.
In exceptional circumstances USC will consider requests from investigators to accept sponsored research agreements that limit dissemination of research results, pre-publication review or access to a research project based on nationality.
- The Principal Investigator (PI) must submit a request for exception, endorsed in writing by his or her dean, to the Vice President of Research.
- A decision on the proposed exception is made by the Vice President of Research upon recommendation of a standing committee of faculty based on a compelling need for the research to take place under the requested conditions.
- Applicants should submit the required form to Emily Pender, Export Controls Manager, at epender@usc.edu,
- In the event an exception request is approved, the Principal Investigator and all other personnel on the research project must adhere to all measures implemented to ensure compliance with sponsor requirements and export control regulations.
Proposals originating at ISI or ICT are expedited but should be requested at least one week in advance of the deadline.
Publication delays are acceptable so that a sponsor may review publications and (1) offer comments or suggestions and/or (2) determine if its proprietary or confidential information is inadvertently disclosed and/or (3) screen for patentable ideas. The final decision on content must rest with the author.
Work closely with the Department of Contracts and Grants (DCG) on your award. DCG personnel will try to negotiate with the sponsor to remove publication restrictions. If that negotiation is not successful, and you still wish to seek funding from the sponsor, you must formally request an exception by submitting the exception form.
- You will need to provide demographic information about your proposal, the nature of the restriction, and the location of the work.
- In addition, you will need to provide a rationale for why the research should take place at USC (e.g., nature of the research, USC’s reputational risk relative to potential benefits, magnitude of risks to students participating in the research), disclose whether students will be involved in the research, and identify the steps you will take to comply with applicable restrictions.
Please be aware that if you intend to involve students or receive restricted data from the sponsor or a third party, you must describe the steps that will be taken to protect student rights to publication and/or to protect the security of restricted information provided to USC, as applicable. Protecting restricted information may include the implementation of a Technology Control Plan (TCP).
- The request will be reviewed by the Office of Culture, Ethics and Compliance to assess how and whether the restrictions can be satisfied.
- If students will participate in the research, then the Office of Academic Affairs will work with the principal investigator to develop an approach to protect publication rights of the
- These reviews, along with the exception request and proposal, will then be reviewed by the standing faculty committee on international research, which will vote as to whether USC should accept the agreement and how the agreement is managed.
- The committee’s vote will be communicated to the Vice President of Research, who will make a final decision.
- For research conducted off-campus at ISI or ICT, the Vice President of Research is permitted to grant approval through an expedited process explained in the Policy on International Collaboration and Export Controls.
Typically, sponsors define a “US person” as any of the following:
- S. Citizen
- S. lawful permanent resident (“a green card holder”)
- Person granted asylum
- Person granted refugee status
All other persons are considered foreign nationals.
No. Citizenship eligibility requirements alone do not trigger the policy. However, if the requirement for a fellow to be a U.S. Citizen is coupled with a publication and/or export control restriction then the Fellow/PI would be required to request an exception.
- Contractor shall not engage any foreign nationals in the performance of the work without prior written approval of the Sponsor.
- DFAR 252.204-7000 – Disclosure of Information
- DFAR 252.204-7008 – Compliance with Safeguarding Covered Defense Information Controls
- DFAR 252.204-7012 – Safeguarding Covered Defense Information and Cyber Security Reporting
- DFAR 252.204-7020 and 7019.
- “The University shall comply with all U.S. export control laws and regulations, including the International Traffic in Arms Regulations (ITAR), 22 CFR Parts 120 through 130, and the Export Administration Regulations (EAR), 15 CFR Parts 730 through 799, in the performance of this contract.”
- “The University shall be responsible for obtaining export licenses, if required, before utilizing foreign persons in the performance of the contract, including instances where the work is to be performed on–site at Sponsor’s facilities, where the foreign person will have access to export- controlled technical data or ”
- “All applicants will be subject to the following requirement concerning foreign national involvement. Upon Sponsor’s request, Prime Recipients must provide information to facilitate Sponsor’s responsibilities associated with foreign national access to Sponsor sites, information, technologies, and ”