When and how the Policy of Sensitive Technology Research and Affiliations of Concern applies
-
1. When will STRAC be applied to applicable funding opportunities?
The new Policy on Sensitive Technology Research and Affiliations of Concern is being implemented on a gradual basis, for funding opportunities launching as of May 1, 2024.
For program-specific implementation dates, the federal granting agencies and the Canada Foundation for Innovation will notify the research community of when this policy will be applied to their respective funding opportunities. For more information, consult the Tri-Agency Guidance on the STRAC Policy and the CFI’s dedicated guidance.
-
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.
For proposals to CIHR, these named roles include the Nominated Principal Applicant, Principal Applicants, Co-Applicants, Principal Knowledge Users, and Knowledge Users. It does not include collaborators as their role differs significantly for CIHR compared with the other funding agencies.
-
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.
-
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.
-
5. How do I assess whether my research is considered sensitive?
A grant application should be identified as aiming to advance a Sensitive Technology Research Area if the research supported during the course of the grant will aim to support the generation or discovery of knowledge that contributes to progress in the development of a technology described in the sub-categories of the list of Sensitive Technology Research Areas. For the advanced weapons category, any grant application that advances an advanced weapons technology during the course of the research falls under the STRAC Policy. By nature, this category would have military/national security applications.
Researchers themselves are the most knowledgeable about the content of their research, and should identify if they believe their research is captured by an identified sub-category, 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.
If the area of research in question is not captured by the sub-category but falls under the high-level technology category, the institution and/or the researcher are encouraged to apply robust due diligence practices to mitigate risks. For additional guidance on how to mitigate risks, researchers are encouraged to consult the resources provided under the Safeguarding Your Research portal or contact their respective internal resource responsible for research security and compliance.
-
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
-
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. 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.
-
8. Are federally funded student sponsorship, fellowship, and/or internship programs impacted by the Policy on Sensitive Technology Research and Affiliations of Concern?
The Policy on Sensitive Technology Research and Affiliations of Concern applies only to federal grants – administered by Canada’s granting agencies and the Canada Foundation for Innovation – that fund university-based research. Presently, scholarship, internship, 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 with these programs and institutions to determine how to best safeguard their resulting research in accordance with guidance provided by the Government of Canada.
-
9. 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.
-
10. 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.
-
11. How do I know if I'm aiming to advance a sensitive technology research area?
Under the Policy on Sensitive Technology Research and Affiliations of Concern, a research grant is considered to be advancing a Sensitive Technology Research Area if the research supported during the course of the grant aims to support the generation or discovery of knowledge that contributes to progress in the sub-categories of the list of Sensitive Technology Research Areas.
To determine if a research project will aim to advance a sensitive technology research area, individuals should consider the intended use of their research and the possible outcomes or resulting data. Research that will merely use, but not aim to advance, an existing technology is not within the scope of this policy. In addition, areas of research not covered by the sub-categories of the list are not currently considered sensitive for the purposes of this policy.
If you are unsure as to whether your research is aiming to advance a Sensitive Technology Research Area, you may contact the granting agency administering the funding opportunity for additional guidance.
-
12. Does the Policy on Sensitive Technology Research and Affiliations of Concern apply to the funding practices of federally funded third party research organizations?
While the new STRAC Policy only applies at present to federal grant applications from universities and affiliated research institutions submitted to the federal granting agencies and the Canada Foundation for Innovation, we recognize that similar policies are likely to benefit the research security posture of all organizations that receive federal funding for research.
The federal government has directed third party organizations to take complementary measures to identify, assess, and mitigate national security risks to Canada’s research ecosystem. The Government of Canada is committed to working with all organizations that are currently receiving, or who will be receiving federal funding for research, to ensure that this new policy is reflected in their funding practices. For that reason, the Guidance for Research Organizations and Funders on Developing a Research Security Plan will be updated in mid 2024 to reflect this new policy requirement.
If you are unsure as to whether your research is aiming to advance a Sensitive Technology Research Area, you may contact the granting agency administering the funding opportunity for additional guidance.
Sensitive Technology Research Areas
-
13. 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.
-
14. 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.
-
15. 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.
-
16. 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.
-
17. 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
-
18. 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.
-
19. 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. 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.
-
20. Would I be in breach of this policy if I release a co-authored publication, supported by a federal grant to which the STRAC Policy applies, with an individual affiliated with a Named Research Organization?
If you disseminate your research via a publication on research that was supported through a federal grant to which the policy applies, the publication would be considered a research activity supported by the grant. The inclusion of a co-author who is affiliated with a Named Research Organization on the publication could therefore be considered a breach of the policy, given they were involved in an activity supported by the grant.
The Government of Canada recognizes that research funded by a grant may result in a publication months or years after the project has been completed, and that some of the co-authors on a publication supported by a grant that is aiming to advance a STRA may be team members who have left the project partway through. In some cases, a past research team member may independently take on a new affiliation with an NRO, outside of the control of the grant recipient and other members of the research team.
To comply with the policy, any researcher who takes on a new affiliation with, or new funding or in-kind support from, an NRO must immediately cease any involvement in the activities funded by the grant. In accordance with established norms, this researcher’s contributions to the research should still be appropriately recognized; this can include authorship on publications resulting from the research.
There would be no conflict with the policy if:
- the researcher ceased any involvement in the activities funded by the grant prior to becoming affiliated with, or receiving funding or in-kind support from, the NRO; and
- their contribution as a co-author on the publication reflects their contributions to the research before they became affiliated with the NRO.
In the event that a researcher continues to be engaged in research funded by a grant that aims to advance a STRA, after they become affiliated to an NRO, their continued involvement may be considered a breach of the policy.
Consult the Tri-Agency Guidance on the STRAC Policy for more information.
-
21. My research is supported by a federal grant to which the STRAC Policy applies and, as a member of a large international research consortium, I may be required to include a very large number (hundreds to thousands) of consortium members as co-authors on my publications, even if they are not directly involved in my project. Could following the consortium’s publication requirements create a conflict with the STRAC Policy?
An international research consortium is a collaborative structure that connects many individuals and organizations from multiple countries to pursue shared research objectives, typically operating under a formal governance and operational framework. These consortia are often formed to address complex and multifaceted research challenges that require diverse expertise, resources, and perspectives.
Large international research consortia can span from hundreds to thousands of members, wherein individual researchers primarily interact with smaller teams focused on specific aspects of the research, rather than with the entire membership of the consortium. Accordingly, Canadian researchers may not always be aware of — nor may they have any influence over — the affiliations, funding ties, and in-kind support received by other researchers involved in the broader membership of the consortium. The Government of Canada recognizes the value of these large international research consortia in tackling the most challenging and complex problems in research, and continues to encourage Canadian researchers to engage in these collaborative efforts.
Following the STRAC Policy, recipients of federal grants that are aiming to advance a STRA are responsible for ensuring that all members of their research team are aware of their individual responsibilities with regards to compliance with the STRAC Policy. This includes any collaborators from a research consortium who may become directly involved in the activities supported by the grant. If you are aware that some consortium members have ongoing affiliations with any of the listed Named Research Organization (NRO), these members must not be directly involved in the research activities supported by your grant.
The Government of Canada also recognizes that some large international research consortia require that publications stemming from the consortium attribute co-authorship to a very large number of the researchers that make up its broader membership, even if they were not directly involved in the research project. This can lead to publications with hundreds or even thousands of researchers listed as co-authors, some of whom may have affiliations that are unknown to the Canadian researchers involved in the project.
Following these publication norms may require that a researcher who is supported by a federal grant that is aiming to advance a STRA include one or more researchers affiliated to NROs as co-authors on their publications, even if these NRO-affiliated researchers were not directly involved in any research activities supported by the grant. Including these co-authors on a publication would not represent a conflict with the STRAC Policy, as long as these co-authors are not directly involved in any research activities supported by your federal grant that is aiming to advance a STRA.
Validation and Enforcement
-
22. 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.
-
23. How and when will grant applications be selected for validation?
Validation processes will be conducted biannually on small, randomly selected subsets of all applicable grant applications that were funded in a given time period. To minimize bias, random sample selection will be based solely on alphanumerical unique identifiers associated with each application and will not use any personal information. To ensure that all applicable funding opportunities are validated fairly, the process will also ensure that validation samples are representative of the volume of grants funded through 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.
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, the accuracy of attestation forms will be validated as part of the Risk Assessment Review Process. Funding opportunities where the Guidelines are applicable will be indicated in the application process.
Validation may also occur on an ad-hoc basis, should the funding organization become aware of information suggestive of a possible policy breach.
-
24. Who is conducting the validation, and what information is shared with them?
The validation of whether applicants have accurately identified if their research is aiming to advance any of the technology sub-areas of the listed sensitive technology research areas will be coordinated by the corresponding funding organization, with engagement from subject matter experts where required.
For the validation of the accuracy of attestation forms, the funding organizations will conduct a random selection of grants funded in a given period and collate the relevant attestation information to be shared with Public Safety Canada. The information used for validation purposes will only include the personal information provided by individuals as part of their attestation forms (i.e. their name, primary affiliation, form completion date), 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 federal research partnership granting funding applications where the National Security Guidelines for Research Partnerships (the Guidelines) apply and that are referred to Public Safety under the Risk Assessment Review Process, all relevant documents from the grant application – including any attestation forms – will be shared with Public Safety Canada to support the Risk Assessment Review Process. 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. 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. Public Safety Canada will communicate to the corresponding funding organization any findings that indicate a potential policy breach.
-
25. 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.
-
26. What happens if findings are uncovered that indicate a potential policy breach?
The corresponding funding organization will be notified of the findings and may take further action to address this finding pursuant to their authorities and to the terms and conditions of the grant. For more information, please see “Validating Information: What Happens After Application”.
Terminating Affiliations
-
27. 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
-
28. 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.
-
29. Should research institutions exclude individuals who are affiliated with a Named Research Organization from all research projects?
This is not required under the Policy on Sensitive Technology Research and Affiliations of Concern. Following the policy, an affiliation with a Named Research Organization is only of concern when current and active research projects or programs aim to advance a Sensitive Technology Research Area.
-
30. Should students from a Named Research Organization be accepted into a Canadian academic institution?
The Policy on Sensitive Technology Research and Affiliations of Concerns, and the supporting list of Named Research Organizations, are not designed to inform any academic institution’s student admissions criteria or processes. The intent of this policy is to focus on risks related to sensitive technology research performed with research institutions that pose the highest risk to Canada’s security. The development and implementation of the Policy on Sensitive Technology Research and Affiliations of Concern was guided by a set of principles, including that it be free from discrimination, harassment and coercion. This policy targets specific threats associated with military, national defence, or state security entities that could pose a risk to Canada’s national security; it does not target or profile any group of people or country. Excluding individuals from a research project or program based on country of origin or ethnicity is a discriminatory and unacceptable practice and does not improve the security of a research project.
-
31. Why does the Government Canada have two lists of sensitive technologies (the Sensitive Technology Research Areas and the Sensitive Technologies List)?
Both the Sensitive Technology Research Areas (STRA) list and Sensitive Technologies List (STL) were developed by Public Safety Canada — with scientific expertise across the federal government — to identify emerging technologies or those with novel uses. The STRA was informed by Public Safety Canada’s ongoing development of the STL.
The STL was created to inform Government of Canada policy across departments and agencies. It is adaptable to suit the needs of any program or policy. The STRA list is specifically meant to be used in relation to the implementation of the STRAC Policy. Hence, the STL does not supersede or replace the STRA, and the research community seeking federal funding should continue to use STRA in their consideration of the STRAC Policy.
The STRA list will be reviewed in consideration of the STL. Any subsequent changes to the STRA will be communicated and published at that time.