GTRI Master TCP
We are pleased to announce that the “GTRI Master Technology Control Plan” (GTRI Master TCP) has been developed. The purpose of this GTRI Master TCP is to control the dissemination of Export Controlled (EC) information and other Controlled Unclassified Information (CUI) being utilized during the performance of Georgia Tech Research Institute (GTRI) projects. This TCP shall be used exclusively for projects with GTRI-only personnel and when there is no expectation of exporting data, technology, equipment, information or materials to a foreign person, company or government.
This Master TCP shall not be used in certain circumstances. A project specific TCP will be required if any of the following conditions exist:
- Projects that require the use of Non-US Persons
- Projects that require the use of Students (including US citizens) for thesis or dissertation
- Projects that involve collaborative projects with main campus Resident Instruction facilities or labs (i.e. non-GTRI labs and participants)
Note: Projects that will export, transfer, ship or share any export controlled information, technology, data, equipment, materials or services outside the USA – even to a US Military installation abroad – require a license or exemption. Please contact the Export Control team in the Office of Research Integrity Assurance (ORIA) for licensing and/or exemptions prior to shipment. Please plan well ahead as some shipments, licenses or exemptions may require a significant lead time.
Once you have had a chance to read the attached TCP please sign the last page (Attachment A) and return via email to Ray Kangas in GTRI RSD. All projects with TCPs require annual Export Control training as described in the GTRI Master TCP.
PERSONNEL TRAINING AND AWARENESS
All individuals shall attend annual export training to ensure compliance with the spirit and intent of the protection criteria contained herein. Fulfilling the annual training requirement may be done in one of the following two ways:
1) In person training is required every other year. Instructions for registering for in-person Export Control & TCP classes are available by clicking here. Out of state participants can contact the Export Control staff in ORIA at firstname.lastname@example.org to schedule a session.
2) On-line training may be used in alternate years when in-person training is not required, however the website is currently under construction (http://tinyurl.com/GTRI-Export-Training).
Of course, you are welcome to attend the in-person session each year if you prefer and may retake any additional training courses as often as you wish.
Reminder – Security Concerns GTRI face include export control regulations:
When you interface with foreign nationals (sponsors, colleagues, visitors or students who are not lawful residents – green card holder), whether in the U.S. or abroad, you should be aware of the possibility that information you possess may be subject to export control regulations. The U.S. Government regulates the transfer or disclosure of sensitive physical items, technologies, and information to foreign nationals both in the U.S. and abroad. A release of export controlled goods/information can occur through a verbal exchange, through e-mail, regular mail, through a presentation that is attended by foreign nationals, public displays of information such as a poster session. Though classified information would always be export controlled, not all export controlled information may be classified, therefore as a general rule of thumb in GTRI regarding information that is not already published and in the public domain should be considered technical data, materials or information controlled until a review determines otherwise.
For questions on export controls related to GTRI, contact the Export Control team in ORIA. Failure to comply with export regulations may result in personal exposure to criminal and civil penalties under the law, as well as disciplinary action including termination.