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

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.

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.

• 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 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.