Canada’s New Policy on Sensitive Technology Research and Affiliations of Concern

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 in early 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 will only come into effect as of early 2024, the Government of Canada may take research affiliations into account immediately 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.

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.