Disclosure of External Relationships

Researchers have an obligation to disclose all external relationships - both domestic and international - in a manner that is consistent with applicable requirements, including federal and state laws, regulations, and agency guidance, as well as the university's own policies and procedures. 

• Campus Disclosure Requirements for the Campus Community

  Disclosure of External Interests and Commitments Policy

  Individual (researchers, faculty, and staff) have an obligation to avoid conflicts of interest and commitment  when carrying out their external and University education, research, scholarship, or service responsibilities.  This includes activities over summer and winter break months.  These external activities must be reported in myResearch Conflict of Interest in an individual's Disclosure Profile. 

  For additional information and resources,  see the  University Disclosure Requirements website.

• Federal Sponsor Disclosure Requirements for Researchers

  Researchers are required to appropriately disclose all activities, including all international relationships, activities and components, in accordance with their federal sponsor's guidance and policies*.  

  Resources and guidance on federal sponsor disclosure requirements can be found here. 

  *Federal sponsors continue to have varying disclosure requirements for the Current and Pending (Other) Support and Biographical Sketch. 

• Gifts

  Gifts may be in the form of donations of money, property, or resources with no clear expectation of direct benefit to the donor.   

  All gifts to SBU should be reported to ensure proper review,  management, and reporting. 

  • Gift Policies, Stony Brook Foundation 
  • Gifts for Research, Office of the Vice-President for Research
• Foreign Gift Reporting to Federal Agencies and Sponsors

  Research reporting requirements of gifts and federally sponsored projects: 

  • If gift funds are used to support sponsored research there may be additional reporting to the research sponsor (e.g. disclosure of other support). 

   SBU institutional reporting requirements of foreign gifts:

  • Disclose semi-annually to the U.S. Department of Education specific financial transactions pursuant to Section 117.
  • Disclose annually to the National Science Foundation specific financial transactions pursuant to the CHIPS ad Science Act of 2022.

Protection of Intellectual Property, Research Data, and Materials

Researchers, as stewards of their data, have an obligation to protect their data in accordance with all applicable policies.  This includes institutional policies, sponsor policies, and any terms and conditions accepted in an agreement. 

• Research Data Ownership, Retention, and Access Policy

  Research Data Ownership, Retention, and Access Policy

• Cybersecurity

  SBU Cybersecurity Policies

  Sensitive Information Classification Policy 

  Data Classification Security Standards  

  • Faculty, staff, and students are required to comply with SBU cybersecurity and data security policies.  
  • Researchers (both funded and unfunded) may have additional laws and/or regulations that oversee the data security requirements of a category of data. 
  • Researchers may have additional cybersecurity laws and/or regulations that are required for the conduct of their projects.  (See Federal Awards and Protection Standards below) 

  Read more about cybersecurity.

• Controlled Unclassified Information (CUI)

  SBU does not conduct or accept classified research or controlled unclassified information (CUI).  

  Controlled Unclassified Information (CUI) is information the Government creates or possesses, or that an entity creates or possesses for or on behalf of the Government, that requires safeguarding or dissemination controls consistent with applicable laws, regulations, and Government-wide policies but is not classified under Executive Order 13556 “Classified National Security Information” or the Atomic Energy Act, as amended.

  Contact the Research Security Program if you have questions regarding CUI for research. 

• General Data Protections Regulation (GDPR) and Similar Laws

  SBU cannot accept or store data subject to the GDPR or other similar data protection laws.  

  The General Data Protection Regulation (GDPR) is a regulation in European Union law on data protection and privacy concerning the processing by an individual, a company or an organization (including SBU) of personal data relating to individuals in the European Union and European Economic Area. 

  Many other countries have similar types of laws.   

  Review Data Use Agreements for the appropriate contact area. 

• Research Data Security

  Certain categories of research data require increased security measures. 

  Researchers working with and/or creating such research data must also comply  all applicable regulations and laws and sponsor policies.

  Read more about data security and data categories.

• Federal Awards and Protection Standards

  Federal sponsor awards, particularly contracts and sub-contracts, include cybersecurity and data protection standards. 

  These standards include:

  • IT and physical security requirements and/or
  • Prohibitions on vendors, software, hardware, and/or social media applications.
• Physical Security

  Careful consideration should be given to the level of physical security that is needed to protect equipment,  materials, and research data.  

  Environmental  Health  & Safety has established  baseline requirements for lab  security based on risk factors. 

  Contact the Research Security Program if you are contemplating research with increased physical security requirements or are purchasing export controlled items.

• Share/Protect Data, Materials, Intellectual Property, and Ideas

  Transfer of data, and materials to other researcher and labs must follow all applicable laws, regulations, contractual obligations and SBU policies. 

  Some common types of agreements are:

  • Data Use Agreements
  • Sponsored Research Agreements (including unfunded Collaboration Agreements)
  • Material Transfer Agreements 
  • Intellectual Property License Agreements 
  • Non-Disclosure Agreements 

  Who can sign agreements?

  Check to see what office is authorized to sign an agreement.

• Report Your Discovery (Invention Disclosures)

  SUNY Patents, Inventions and Copyright Policy

  Researchers are required to disclose:

  • Intellectual property as required to sponsors.
  • Any potential inventions or other intellectual property to Intellectual Property Partners (IPP).

  Resources and guidance on intellectual property protection.

International Engagements-High Risk Activities

The U.S. federal government has identified certain parties, countries, and areas of research that require additional due diligence when engaging in international activities.   These are Restricted Parties, Countries of Concern, Foreign Talent Recruitment Programs, and Critical and Emerging Technologies. 

• Restricted Parties

  The U.S. government maintains lists of entities and persons who are restricted and/or denied certain transactions.  This includes the recent "1286 List" - Restricted Party Overview

  All  foreign person and entities must be screened for inclusion on any of these lists prior to engaging in activities. 

  How to conduct a restricted party screening using Descartes Visual Compliance software

  Any activities with a Restricted Party must be reviewed by the Research Security Program. 

• Countries of Concern

  Countries of Concern: China, Iran, Russia, and North Korea. 

  Recognized as countries of concern by many federal agencies and sponsors.  Activities that include these countries have additional risks and must be reviewed by the Research Security Program. 

  June 2023, the U.S. Department of Defense issued "Countering Unwanted Foreign Influence in Department-Funded Research at Institutions of Higher Education". 

• Foreign Talent Recruitment Programs

  Faculty and other key personnel on federally funded research awards should understand the definitions of Foreign Talent Recruitment Programs (FTRP) and Malign Foreign Talent Recruitment Programs (MFTRP) and federal sponsor restrictions on MFTRPs. 

  Many federal sponsors now require certification that faculty and other key personnel are not participating in a MFTRP. 

  Is My Talent Program Malign? 

  Resources and guidance on FTRPs and MFTRPs can be found here.  

• Emerging and Critical Technologies

  The federal government maintains a list of critical and emerging technologies that are potentially significant to U.S. national security.    Researchers contemplating a research activity with an international partner in one of these areas should contact the Research Security Program.
  

  Federal Resource:  Critical and Emerging Technologies List Update (February 2024); Fast Track Action Subcommittee on Critical and Emerging Technologies of the National Science and Technology Council

Compliance with Export Controls

 Researchers have an obligation to be aware of export restrictions applicable to any ideas, information or equipment they intend to share with international collaborators, whether they are overseas or visiting the U.S. 

• Export Control Policy

  Export Control Policy 

• Export Controls

  Export control assistance: 

  • Export Controls Website 
  • SBU Export Control Manual
  • Contact the Export Control Compliance team

  Export control overview:

  Export controls are a body of  federal regulations that regulate:

  • Disclosure, shipment, use, transfer, or transmission of any item, commodity, material, technical information, technology, software, or encrypted software for the benefit of a foreign person or foreign entity anywhere (including the transfer of controlled information within the U.S. “deemed export”); 

  • Transactions and the provision of services involving prohibited countries, persons or entities based on trade sanctions, embargoes and travel restrictions.