Required and Recommended Best Practices for International Engagement
The following requirements and recommendations apply to Cornell University work with foreign collaborators generally, whether in Ithaca, New York City, or abroad. We encourage all Cornell faculty and staff to follow these best practices in their international work.
1. Disclosure of Support
All current and pending support of your research endeavors, including all foreign-sourced support, must be disclosed in federally funded applications, as required by the sponsor. The inclusion of a foreign component (e.g. subawards, consultants, and funded or unfunded collaborations with investigators located at a foreign site) in a project must also be disclosed in grant applications and reports. See NIH’s definition of foreign component.
Note: Adding a foreign component to an existing award may require prior approval by the agency. For specific requirements, please refer to agency policy and your award document, or contact your grant or contract officer in Cornell's Office of Sponsored Programs.
2. Disclosure of Consulting Activity
All time spent working for or consulting with foreign entities or institutions must be reported to the university regardless of whether such activity is conducted in your professional or personal capacity. University policy governs this activity, but individual consulting contracts are negotiated and executed by faculty in their personal capacity and do not go through the university system. Annual Conflict of Interest (COI) reports must include the approximate number of days spent internationally in paid or unpaid engagements with foreign governmental bodies and/or foreign institutions of higher education, including affiliated academic teaching hospitals, medical centers, or research centers.
Note: Faculty should be aware of any U.S. and foreign legal or governmental restrictions on their personal consulting work, as they could encounter personal visa or tax issues, put Cornell at risk, and potentially forfeit intellectual property rights if they do not exercise care. Such activities (whether abroad or domestic) must comply with IP responsibilities as well as export controls and related external regulations. The Office of the Vice Provost for International Affairs, in conjunction with the Office of University Counsel, will update this memo and circulate guidance regarding personal consulting work in China in the coming weeks.
3. Observing Appropriate Security Precautions when Traveling
It is required to register university-related travel abroad. The university has established a travel registry for all students, staff, and faculty to pre-register when they are traveling abroad. This registry helps the university to respond and assist in the event of individual or group emergencies. All students, staff, and faculty must register. Any student and faculty/staff traveling with students to a country designated as elevated-risk will require pre-approval of their travel by Cornell’s International Travel Advisory and Response Team (ITART). Failure to gain approval will result in Cornell funds being withdrawn from this activity.
Note: Disclosure of foreign travel may be required by funding or oversight agencies. All travel records must be maintained for a minimum of five years from the date of travel.
Note: Taking your laptop or mobile device when you travel significantly increases the possibility of data and identity theft. When traveling, especially to high-risk countries, including China, consider following security measures outlined by CIT. For example, you should avoid public Wi-Fi connections by bringing your own mobile hotspot. Faculty and executive staff may arrange to use loaner laptops and loaner handheld devices through the pilot High-Risk Travel Loaner Program while traveling. This program will be more widely available after the pilot phase.
4. When Negotiating Research Collaborations with Foreign Entities, Keep in Mind these Rules ...
(For certain collaborations, these rules are required.)
- All collaboration agreements (whether memorandum of agreement or sponsored agreement) include standard language to protect academic freedom, intellectual property, and non-discrimination; this language is not negotiable. (See information on MOAs.)
- Use open-source software and ensure compliance with licensing terms if proprietary hardware will be required.
- Provide strong data management plans in your grants and contracts, as required; see the Research Data Management Service Group for specific questions.
- Work with the Office of Sponsored Programs to sign a non-disclosure agreement with collaborators if working on sensitive data or technology, and be vigilant about unsupervised access to your laboratory or hardware.
- Do not allow unsolicited, unscheduled, or unsupervised on-site visits.
Note: Working with foreign collaborators on Cornell University grounds is often vital and productive to the research enterprise. If you are bringing a visitor to campus, whether a fellow scientist, student, or funder, make sure that you feel comfortable vouching for them on campus (depending on how well you know them, you may want to gather letters of recommendation or directly verify their CV, for example) and provide adequate supervision. If you have any concerns, see the information in the section on "restricted party screening."
May 28, 2019