What is a Technology Control Plan (TCP)?
A TCP is a document that formalizes the procedures that UNH will use to control access to and release of export controlled items, 信息, 材料, 等. in accordance with federal export regulations. A TCP is also a mechanism for documenting that 研究 personnel are aware of their compliance responsibilities.
When do you need to use a TCP?
A TCP should be used when:
- A project or activity involves the receipt of Sensitive Unclassified Information (SUI) from an outside party or sponsor under a nondisclosure agreement or sponsored 研究 agreement
- Projects or activities are not considered 基础研究; or
- Projects or activities involve technology and software associated with export-controlled equipment.
TCPs need to be completed and approved prior to handling export-controlled 信息 associated with a 研究 project.
What are the elements of a TCP?
A TCP generally includes:
- A statement of institutional commitment to complying with applicable regulations;
- Commodity Jurisdiction (which agency has authority) and classification (what type of item/信息 is involved);
- A description of physical security measures;
- A description of 信息 security measures;
- Personnel requirements; and
- Administrative elements (i.e., inspections, training, recordkeeping, 等.)
The Office of 合同 and 出口管制 (CEC) provides a project-specific TCP template to serve as a starting point, with the intention that it will be adapted to comply with the specific regulatory requirements and to accommodate the particular University project or program.
The completed TCP should be sent to CEC for review and comment BEFORE collecting the required signatures on the TCP 认证. Once CEC has approved the safeguards and confirmed the eligibility of the identified users the PI will be notified. At that point the PI will need to distribute the TCP to the authorized users and have them sign the TCP 认证. Once all of the user signatures have been obtained the signed form(s) must be returned to CEC for final approval.
The 知识库 contains forms, instruction and training material, 分钟, 政策, tools and other resources to support your 研究 efforts by topic area.
维克多·索萨，局长
合同 & 出口管制
电话:(603)862-2001
电子邮件: 维克托.Sosa@csnkwx.com
梅丽莎 McGee, Assistant Director
研究 Integrity Services
电话:(603)862-2005
电子邮件: 梅丽莎.McGee@csnkwx.com
