When and how the Policy of Sensitive Technology Research and Affiliations of Concern applies
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1. When does this policy come into effect?
The policy will come into effect for new applications to applicable funding opportunities of the three granting agencies and the Canada Foundation for Innovation in early 2024. The policy does not apply to funding opportunities that are launched before the policy is in effect. More information will be provided by the three granting agencies and the Canada Foundation for Innovation in the coming months regarding which funding opportunities are in-scope for the policy.
The Government of Canada may take affiliations into account as part of research funding decision-making processes prior to early 2024, should risks be identified. In particular, 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.
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2. Must I provide an attestation whenever I apply to a funding opportunity that is in scope of this policy?
If you are a researcher with a named role in the grant application (e.g., applicants, co-applicants, collaborators, co-directors or equivalent roles), you are required to provide an attestation at the time of application, for each funding application that is advancing a listed sensitive technology research area. If your funding application does not advance a sensitive technology research area, an attestation is not required.
For proposals to the Canada Foundation for Innovation, the attestation requirement will apply only to named project leaders, co-project leaders, and team members; other named users will not be required to attest for Canada Foundation for Innovation grant applications.
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3. How does this policy apply to Highly Qualified Personnel (HQP) such as undergraduate and graduate students, post-doctoral fellows, and research staff?
Only those researchers with a named role in the grant application must provide an attestation form at time of submitting a grant application, and this is only required if the grant will support research that advances a sensitive technology research area. If an HQP is invited to participate in a research project that advances a sensitive technology research area, but does not hold a named role in the application, they do not need to provide an attestation form.
However, for the duration of the grant, all research team members (including HQP) are required to comply with the policy. This means that any HQP who are working on research activities that are funded by a grant that advances a sensitive technology research area, cannot be currently affiliated or in receipt of funding or in-kind support from a named research organization. Where applicable, grant recipients must ensure that HQP understand their responsibilities with regard to this policy and to the terms and conditions of the grant, prior to them beginning their work on the research team.
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4. How do I attest that I do not have an affiliation, nor am I in receipt of financial or in-kind support, from a named research organization?
Attestation forms will be required if the grant is identified by the applicant to advance a sensitive technology research area. In such cases, researchers with named roles in the grant application (see Question 2) will be asked to complete and submit an attestation form with their grant application, to certify that they do not have an affiliation, nor are they in receipt of financial or in-kind support, from a listed named research organization.
Further information regarding these requirements, including appropriate forms and procedures, will be provided by the granting agencies and the Canada Foundation for Innovation in advance of the policy implementation.
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5. It is not clear if my research area would be considered sensitive. How should I proceed?
The Government of Canada has provided information on what is considered a sensitive technology research area. Researchers themselves are the most knowledgeable about the content of their research, and should identify if they believe their research is considered sensitive, according to this policy, and lean towards a cautionary approach. If additional guidance is required for their specific context, applicants may reach out to their respective internal resource responsible for research security and compliance for help, who can then contact the Government of Canada’s Research Security Centre for case-specific advice.
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6. If my research team composition changes over the course of a grant that supports the advancement of a sensitive technology research area, what steps do I need to take to ensure compliance with this policy?
For the duration of the grant, all research team members are required to comply with the policy. Therefore, you must ensure that any new research team member understands their responsibilities with regards to this policy and to the terms and conditions of the grant, prior to them beginning their work as part of the research team.
If any prospective team member has an affiliation with or is in receipt of financial or in-kind support from a named research organization, they must terminate this relationship before joining the research team. For more information on terminating such relationships, please consult the question and answer on this subject below.
What is covered by the Policy on Sensitive Technology Research and Affiliations of Concern
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7. What grant and funding programs are covered by this policy?
This policy applies to all federal funding opportunities administered by Canada’s federal granting agencies that fund grants to universities and affiliated research institutions — the Canadian Institutes of Health Research, the Natural Sciences and Engineering Research Council of Canada and the Social Sciences and Humanities Research Council of Canada — and the Canada Foundation for Innovation. Presently, Scholarship and Fellowship programs are not in scope for this policy, nor are funding opportunities that exclusively fund grants to colleges, polytechnics, and CEGEPs. The Government of Canada is engaging these institutions to determine how best to safeguard their research, in accordance with this policy and other tools and guidance provided by the Government of Canada. Researchers employed by a college, polytechnic or CEGEP who are part of a university led research grant team will be required to comply with the policy.
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8. Will historical relationships with a named research organization be considered under this policy?
To respect procedural fairness and to enable researchers to take any appropriate actions to comply with this new policy, only currently held affiliations and financial or in-kind support will be considered. Past affiliations and previous financial or in-kind support will not be considered. See the Definitions section to review what is considered an affiliation and financial or in-kind support under the policy.
Any grants that have already been awarded and that are still ongoing – including multi-year projects where the notice of decision was communicated prior to this guidance being published – will not be affected by this policy. All researchers are encouraged to carefully read the enhanced guidance provided by this policy to protect their sensitive research from collaborations of concern.
If a project is being considered for an extension with additional funds and researchers must apply for the funded extension, the project must comply with this policy. Extensions without additional funds will not be considered under this policy.
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9. Are foreign talent and recruitment programs considered under this policy?
Foreign talent and recruitment programs are not formally considered under this policy, given that they are typically not administered by the types of research organizations named in the list of Named Research Organizations. However, should the participation in such a program involve a researcher becoming affiliated with, and/or receiving financial or in-kind support from a named research organization, this would be captured by the policy.
Further guidance regarding risks associated with participation in foreign talent and recruitment programs, as well as best practices, can be found on the Safeguarding Your Research portal.
Sensitive Technology Research Areas
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10. I am using a technology related to a listed sensitive technology research area, but I am not explicitly advancing the technology. Is my research project considered sensitive?
No, a grant application would not be considered to be advancing a sensitive technology research area if it is only using or applying that technology in relation to the project. The policy applies to the advancement of sensitive technology research areas. For example, if a researcher is using artificial intelligence (AI) to sort through data in relation to a social sciences project, this is not considered as advancing a sensitive technology research area. However, if through the course of using this technology, the researcher makes advances in relation to AI, they must report this to the appropriate funding organization to ensure compliance with this policy.
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11. My grant will support multiple research projects, but only one project will advance a listed sensitive technology research area. Does my grant application have to be identified as advancing a sensitive technology research area under this policy?
Yes, if any project supported by the grant will advance a listed sensitive technology research area, then the grant application must be identified as such.
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12. I am affiliated with, or in receipt of funding or in-kind support from, a listed named research organization. Am I eligible to apply for a grant?
Until you terminate your relationship with the listed named research organization, you will only be eligible to apply for grants that will not be advancing a sensitive technology research area, and you cannot be involved in research activities funded by any grant that advances a sensitive technology research area.
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13. I am currently working on a project in collaboration with an individual who has an affiliation with a listed named research organization. I plan on applying for a grant to conduct research that advances a sensitive technology research area, that is unrelated to this collaboration. Do I need to terminate my existing collaboration to be eligible for the grant?
Eligibility is determined on a grant-by-grant basis. Your eligibility to apply for a grant that advances a sensitive technology research area will not be affected by existing projects or collaborations with individuals who have an affiliation with a named research organization, so long as these individuals will not be involved in the research activities supported by the grant.
Appropriate safeguards should be put in place to ensure that these individuals do not gain access to, or become involved in, the research supported by a grant that advances a sensitive technology research area.
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14. What should I do if my grant application was funded and did not require any attestation of compliance with the policy, since it was not identified as advancing a sensitive technology research area, but the nature of my research changed over the course of the grant?
While the grant remains active, you should inform the funding organization that awarded the grant and your institutional officials of any changes in the nature of your research that would lead to grant funds supporting the advancement of a sensitive technology research area. Attestations of compliance with this policy would be required if it is determined the project is now advancing a sensitive technology research area. You should not proceed with research activities that advance sensitive technology research area until approval from the funding organization has been obtained. For Canada Foundation for Innovation-funded projects, the award ends at the submission of the final financial report.
Publication and Dissemination of Research
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15. What does conduct of research mean?
Per the Tri-Agency Framework: Responsible Conduct of Research (2021), research is an undertaking intended to extend knowledge through a disciplined inquiry and/or systematic investigation.
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16. Is the publication of research through a co-authored publication considered a research activity for the purposes of this policy?
The dissemination of research results is considered a research activity under this policy. Co-author affiliation may be of concern given that the policy applies to all research team members involved in research activities supported by grants that advance a listed sensitive technology research area. If the research that supported this co-authored publication was related to a grant identified as advancing a sensitive technology research area (as defined by this policy), the inclusion of this co-author on the publication may be considered a breach of the policy.
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17. If I disseminate my research via publication with a co-author who is affiliated with a named research organization, will the Government of Canada consider me to be affiliated with that same organization?
No. Per the previous question, your co-authors would be considered as part of your research team; but organizations they are affiliated with are not considered your affiliations. Co-publishing an article with an individual affiliated with or in receipt of funding or in-kind support from a named research organization would not create an affiliation between you and that named research organization. Affiliations are not transferable in this manner. See the Definitions section to review what is considered an affiliation under the policy.
Validation and Enforcement
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18. How will research applications be validated for compliance?
To ensure appropriate compliance with the policy, two elements will be validated. This includes a validation of whether applicants have accurately identified whether their research advances any of the sub-categories of the listed sensitive technology research areas, as well as a validation of whether the attestations provided are accurate in terms of researchers not being affiliated with, or in-receipt of financial or in-kind support from a named research organization.
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19. How will grant applications be selected for validation?
Validation will be conducted on small, randomly selected subsets of all applicable grant applications that were funded during the preceding fiscal year. To minimize bias, no personal information will be used as part of the random selection and validation process. Sample selection will be based solely on alphanumerical unique identifiers associated with each application. To ensure that all applicable funding opportunities are validated fairly, the process will also ensure that the validation sample is representative of the volume of grants funded in each applicable funding opportunity during that period. Validations conducted on randomly selected grant applications will occur post application decision, as to not impact service standards.
Validations would only occur prior to grant funding if the funding opportunity also applies the National Security Guidelines for Research Partnerships (the Guidelines) and if the application has been identified as requiring further national security assessment. In these cases, attestations will be validated as part of the national security assessment process. Funding opportunities where the Guidelines are applicable will be indicated in the application process.
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20. Who is conducting the validation, and what information is shared with them?
The validation of whether applicants have accurately identified if their research advances any of the sub-categories of the listed sensitive technology research areas will be coordinated by the relevant funding organization, with engagement from subject matter experts where required.
For the validation of attestations and whether they are accurate in terms of researchers’ non-affiliations with named research organizations, the funding organizations will collate the relevant attestation information to be shared with Public Safety Canada. For most grants, the information used for validation purposes will only include the personal information provided by individuals as part of their attestation forms, as well as relevant contextual information about the grant (e.g., the title and abstract) that would normally be made publicly available by the funding organization. This information – not the entire application – will be shared with Public Safety Canada for validation.
For funding opportunities where the National Security Guidelines for Research Partnerships also apply and where the application has been identified as requiring further national security assessment, all relevant documents from the grant application including any attestation forms will be shared with Public Safety Canada for validation. Funding opportunities where the Guidelines are applicable will be indicated in the application process.
In all cases, Public Safety Canada will coordinate the validation of attestations and report any findings to the appropriate funding organization. Further assessments, as required, will be conducted by Public Safety Canada, departments, and agencies, that have the mandate or expertise to provide information in support of the validation of attestations.
Further information on these validation procedures will be provided in the coming months.
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21. Is the primary applicant responsible for the validity of the attestations of other members of their research team?
No, the primary applicant is not responsible for ensuring the validity of the attestations provided by other members of the research team with named roles in the grant application. Each team member is responsible for the validity of their own attestation. Primary applicants and institutions must however exercise due diligence in ensuring that no grant application includes researchers with known affiliations to listed entities, as this could result in the grant application not being eligible for funding.
The primary applicant will be required to collect and submit all completed attestation forms on behalf of research team members with named roles in the grant application, as part of the grant application package.
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22. What will happen if an attestation is found to be inaccurate?
If the validation process uncovers inaccurate information as part of an attestation form, this may impact the researcher’s eligibility to participate in the research activities supported by the grant. This could also result in funding for the project temporarily or permanently ceasing.
Should a misrepresentation be suspected or alleged, the researcher’s institution will be responsible for conducting an inquiry and (if warranted) an investigation of the allegation following the RCR process. If the allegation involves a researcher based at a foreign institution, the Canadian institution where the grant is held will be responsible for conducting an inquiry, which could result in the researcher’s exclusion from the project.
If this investigation finds that a researcher has provided inaccurate information in their attestation form, they may be removed from research activities supported by the grant. Recourse for breaches of the RCR Framework varies by severity, intentionality, and impact of the breach, but may include and is not limited to: a letter of reprimand; withholding installments of and/or termination of the funding; a requirement to reimburse funds; and ineligibility to hold/apply for federal funding for a defined period of time or permanently. The researcher’s primary institution(s) may be called upon to address the issue and/or to determine the best route forward to minimize impacts on the research and on the grant.
Terminating Affiliations
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23. I have an affiliation with a named research organization. What steps should I take to end this affiliation to be eligible for federal funding?
If you have an affiliation with a named research organization and your proposed research will not advance a sensitive technology research area, no further action is required.
If you have an affiliation with a named research organization and your proposed research will advance a sensitive technology research area —or if you plan on joining a team whose research is advancing a sensitive technology research area —you should take action to immediately terminate or wind down those relationships. We recognize that it may not be easy to end relationships immediately with these organizations, which is why the Government of Canada is providing a time period between the policy announcement and the date at which the policy comes into effect in early 2024. This will allow researchers to fully remove themselves from any affiliations that may make them ineligible for federal funding. If you are experiencing issues with ending your affiliations with named research organizations, you should first reach out to your respective institutional resource responsible for research security and compliance for help, who can then contact the Government of Canada’s Research Security Centre for case-specific advice.
It is always prudent to maintain a record of affiliations that you have ended, since public information may not always be up-to-date (e.g., your name may still be listed as an employee or researcher at a named research organization on their website even though you’ve tendered your resignation). A copy of your resignation letter, emails from former co-workers acknowledging your departure, and any other proof that you can produce will help more definitively demonstrate whether your affiliations have ended. Such proof will not be required when completing an attestation form for a grant application; however, you may be contacted at a later date should validation be required.
Additional
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24. Is the Government of Canada applying this policy to research projects led by their own scientists, or for research funding decisions by science-based departments and agencies?
At this time, this policy applies only to federal funding opportunities administered by Canada’s federal granting agencies (CIHR, NSERC, and SSHRC) and the Canada Foundation for Innovation that fund grants to universities and affiliated research institutions.
Research projects and programs internal to the Government of Canada are subject to existing federal security policies, including those relating to personnel security.
The government is reviewing the potential application of these criteria to these policies, as well as to collaborations between government and external academic researchers.