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

All researchers with named roles engaged in activities supported by the research grant will be required to attest that they have read, understood, agree with, and are compliant with this policy. They and their research team(s) will be required to comply with the policy for the duration of the federal grant.

This new policy is focussed on researcher affiliations and targets the highest risk collaborations with military and state security-related institutions. As part of this policy, researchers should keep in mind that institutions that are not included on the Named Research Organizations list at this point in time may still pose a risk to Canada’s research and are encouraged to apply due diligence practices to mitigate risks that may be associated with any collaboration or partnership in a sensitive technology research area. A suite of research security guidance and tools is available on the Safeguarding Your Research portal, including the National Security Guidelines for Research Partnerships which apply as a requirement to certain federal research partnership funding opportunities.

Validating Information: What Happens After Application

Federal research grant applications and Canada Foundation for Innovation funding applications will be periodically selected for a process to validate compliance with the policy.

Validation is expected to take place through one of two routes:

• For most federal research grant funding opportunities, validation will be conducted through a sampling of funded applications, on a regular basis within each granting council and the Canada Foundation for Innovation. This validation may be completed after grant funding has been awarded.
• For federal research partnership grant funding opportunities where the National Security Guidelines for Research Partnerships apply, validation of attestations will be completed in parallel for applications that are selected for national security assessment. In these cases, validation will occur prior to a funding decision.

The Government of Canada is committed to minimizing the impact of this new requirement on funding decision service standards.

The validation process will be actioned by national security departments and agencies in collaboration with the relevant funding organization(s).

If the validation process finds that a researcher has an undisclosed affiliation of concern, or is in receipt of funding or in-kind support from a listed institution, it will impact the researcher’s eligibility to participate in the activities funded by a grant in a sensitive technology research area. Further action will be taken by the federal granting council and / or the Canada Foundation for Innovation to address the finding, pursuant to the organization’s authorities and to the terms and conditions of the related grant(s).

Any misrepresentation by a researcher in a grant or funding application may constitute a breach of the Tri-Agency Framework: Responsible Conduct of Research (RCR). Following the RCR process, the Canadian institution that the researcher is affiliated with will be responsible for conducting an inquiry and (if warranted) an investigation of the allegation. Recourse for breaches of the RCR Framework varies by severity, intentionality, and impact of the breach, but may include and is not limited to: withholding installments of and/or termination of the grant; a requirement to reimburse funds; and ineligibility to hold/apply for federal funding, for a defined period of time or permanently.

For More Information

The federal research granting councils and the Canada Foundation for Innovation are in the process of implementing this new policy. More detailed information, including forms and procedures, will be published on their respective web pages in the coming months.

Applicants and research institutions are also invited to communicate with the Research Security Centre if they have further questions.