Research security

Tri-agency guidance on the Policy on Sensitive Technology Research and Affiliations of Concern (STRAC Policy)

On February 14, 2023, the federal government announced its intent to adopt an enhanced posture regarding Canada’s research security. On January 16, 2024, a follow-up statement and the Policy on Sensitive Technology Research and Affiliations of Concern (STRAC) were published.

Following the STRAC Policy, grant applications submitted by a university or affiliated research institution to the federal granting agencies and the Canada Foundation for Innovation involving research that aims to advance a Sensitive Technology Research Area will not be funded if any of the researchers involved in activities supported by the grant are currently affiliated with, or in receipt of funding or in-kind support, from a Named Research Organization.

The federal granting agencies are implementing the STRAC Policy in a harmonized manner, to funding opportunities that launch as of May 1, 2024. This guidance describes the granting agencies’ harmonized approach, as well as agency-specific information, where necessary, as it pertains to the list of funding opportunities in scope of the policy (see relevant FAQ below), the individuals that are required to complete attestation forms, and other agency-specific procedures.

Should you have any questions regarding the implementation of the STRAC Policy, please contact:

• NSERC: researchsecurity@nserc-crsng.gc.ca
• CIHR: support-soutien@cihr-irsc.gc.ca
• SSHRC: researchsecurity-securiterecherche@sshrc-crsh.gc.ca

To learn more about the Canada Foundation for Innovation’s implementation of the policy, please consult its dedicated guidance page.

Definitions

Activities supported by the grant: This definition follows from the STRAC Policy. Any contribution to research related to the funded grant and throughout the lifecycle of the research project(s) or program(s), up to and including the dissemination of research results (e.g., publications).

Affiliation: This definition follows from the STRAC Policy. Individuals are considered affiliated to any organization at which they are employed, appointed, or conduct research. In cases where individuals hold multiple affiliations, all must be considered when ensuring compliance to this policy. The policy only applies to current affiliations. Former affiliations that are no longer active are not in scope of this policy.

Funding and in-kind support: This definition follows from the STRAC Policy. Monetary or non-monetary contributions, that include but are not limited to goods, equipment, materials and supplies, professional services, use of facilities (office space, lab access), software, technologies and databases.

Named Research Organizations (NRO): As defined by the STRAC Policy’s List of Named Research Organizations (NRO). This list is composed of research organizations and institutions that pose the highest risk to Canada’s national security due to their direct, or indirect connections with military, national defence and state security entities. Where applicable, grant recipients will be required to comply with the STRAC Policy for the duration of the grant, following the most recent version of the NRO list that was available at the time the grant application was submitted.

Research team: A group of researchers involved in a research program or project, who share collective competence, expertise and/or goals. The research team includes researchers with named roles in the grant applications, as well as any other researchers involved in activities supported by the grant, such as highly qualified personnel (HQP), co-authors, or informal collaborators who may or may not be identified in the grant application. HQP can include undergraduate and graduate students, post-doctoral researchers, as well as research staff.

Researcher: Any person conducting research activities. This definition follows from the STRAC Policy and the RCR Framework. For the purposes of funding applications to the federal granting agencies, researchers can hold different roles, including but not limited to applicants, co-applicants, collaborators, and highly qualified personnel (HQP).

Researchers with named roles in the grant application: Examples of named roles include, but are not limited to, the Applicant, the Co-applicant, and the Collaborator, as defined by each granting agency. These roles are identified at the application stage, and they are described and defined in Appendix 1 of the Tri-agency Guide on Financial Administration. Applicants are encouraged to consult the appropriate funding opportunity literature, as the named roles may differ according to the granting agency and funding opportunity. Researchers (including HQP) are not considered to have a named role in the grant application if they are simply named or listed as part of the body of a grant application.

Sensitive Technology Research Area (STRA): Areas of research listed in the sub-categories of the STRAC Policy’s Sensitive Technology Research Areas List. Areas of research not covered by the sub-categories of the list are not currently considered sensitive for the purposes of this policy. Where applicable, grant recipients will be required to comply with the STRAC Policy for the duration of the grant, following the most recent version of the STRA list that was available at the time the grant application was submitted.

STRAC Policy: The Policy on Sensitive Technology Research and Affiliations of Concern.

Responsibilities of researchers

To comply with this new policy, applicants must undertake a two-step process prior to applying for a grant. Applicants are encouraged to complete the steps below well in advance of the grant application submission, in consultation with their institution’s research grants office and, where available, their institution’s research security office.

Step 1: Determine whether your grant will aim to advance any Sensitive Technology Research Areas

Applicants must determine and indicate in their grant application whether their proposed research grant will aim to advance any of the listed Sensitive Technology Research Areas. This list is composed of several high-level technology categories, where the sub-categories indicate the specific Sensitive Technology Research Areas of concern. For these areas, the specific concern is the advancement of a technology during the course of the research. Research that will merely use, but not 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.

A grant should be identified as aiming to advance a STRA 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.

• If the research grant will not aim to advance any of the listed Sensitive Technology Research Areas, select “no” to the question: “Will the proposed research activities supported by this grant aim to advance any of the listed Sensitive Technology Research Areas?”
  • No further steps are required under this policy.
• If the research grant will aim to advance any of the listed Sensitive Technology Research Areas, select “yes” to the question: “Will the proposed research activities supported by this grant aim to advance any of the listed Sensitive Technology Research Areas?”
  • The next step required is to check researchers’ affiliations and complete attestation forms for each researcher with a named role in the grant application (proceed to Step 2).

Step 2: Check researchers’ affiliations and comply with attestation requirements

For grant applications that will aim to advance any of the listed Sensitive Technology Research Areas, all researchers involved in the activities funded by the sensitive research grant must review the List of Named Research Organizations.

At the application stage, researchers with named roles in the grant application are individually required to complete the form-fillable Attestation Form PDF and submit it as part of the grant application (see relevant FAQ below for details on how to submit the form). Attestation forms are not required for grants that will not aim to advance any of the listed Sensitive Technology Research Areas.

Should the grant application be funded, additional requirements will apply for the duration of the grant. Following the terms and conditions of the grant:

• Grant recipients must inform the corresponding granting agency and their institutional officials if the nature of their research evolves (see this FAQ) or if the composition of the research team changes (see this FAQ).
• Grant recipients should ensure that all prospective research team members are aware of their individual responsibilities with regards to compliance with the STRAC Policy.
• All research team members involved in the activities funded by a grant that was identified as aiming to advance a STRA are individually responsible for ensuring that they do not hold an active affiliation or receive funding or in-kind support from any of the listed Named Research Organizations, following the versions of the lists that were publicly available on the date that the grant application was submitted. This requirement applies for the duration of their involvement in the activities supported by the grant, regardless of whether an attestation form was required from a research team member at the time of application.

Responsibilities of institutions

Following the Agreement on the Administration of Agency Grants and Awards by Research Institutions, institutions should support their researchers in being appropriately compliant with the STRAC Policy, including by using the resources offered and promoted by the Government of Canada.

As such, Research Grant Officers should (with support from their institutional research security office, where available):

• Ensure that researchers understand their responsibilities with respect to the STRAC Policy, as part of the grant application process and following the terms and conditions of awarded grants.
• Perform a completeness check to ensure that all required attestation forms have been provided with the application, if the applicant has identified that the grant will aim to advance a listed Sensitive Technology Research Area.
• Facilitate communication with the corresponding granting agency if, upon notification by a grant recipient:
  • The nature of their research evolves such that activities supported by the grant would aim to advance a listed Sensitive Technology Research Area (see relevant FAQ below).
  • The composition of the research team changes, requiring the submission of attestation forms from newly added members (see relevant FAQ below).

Research Grant Officers are not expected to validate the accuracy of attestation forms that are submitted to the granting agencies. Each researcher with a named role in the grant application is individually responsible for their attestation statement. Applicants and holders of agency grants are responsible for providing true, complete and accurate information in their funding applications and related documents, pursuant of Article 2.2 of the Tri-Agency Framework: Responsible Conduct of Research. Grant applications will be periodically selected for a process to validate the accuracy of attestation forms, in compliance with the STRAC Policy.

Where possible, institutions may support their grant recipients in following best practices when seeking to recruit new prospective research team members and/or to develop new collaborations and partnerships, as part of a project or program funded by a grant that aims to advance a STRA (see relevant FAQ below). This may include the provision of support to researchers seeking to conduct open-source due diligence to verify a prospective team member’s affiliation(s) and sources of funding or in-kind support.

Validation processes

Validation of the advancement of Sensitive Technology Research Areas

The granting agencies will conduct periodic validations, with engagement from subject matter experts where required, on a randomized subset of funded grants to ensure that applicants have appropriately identified whether their grant would aim to advance a listed Sensitive Technology Research Area as defined at the time of application. In cases where the validation process uncovers information that suggests that a grant application should have been identified as aiming to advance a STRA, the agency will inform the applicant and may request the submission of attestation forms.

Validation of attestation forms

Grant applications that were identified to be aiming to advance a STRA will be periodically selected for a process to validate the accuracy of attestation forms in compliance with the policy, according to the version of the list of Named Research Organizations defined at the time of application. Validation will take place through one of two routes.

For funding opportunities and programs where the National Security Guidelines for Research Partnerships also apply, the validation of attestations will be completed in parallel for any application that is referred to the national security departments and agencies for their assessment and advice following the Risk Assessment Review Process. In these cases, validation will occur prior to a funding decision.

For all other funding opportunities and programs, attestations will be validated periodically, on a randomized subset of funded grants. This validation process will be conducted post funding decision, and therefore will not impact the service standards of each funding opportunity. A subset of funded grants identified as aiming to advance a Sensitive Technology Research Area will be randomly selected for validation. The attestation forms provided as part of the grant application, as well as the title and publicly available abstract of the related grant, will then be shared with the national security departments and agencies for their assessment.

A researcher’s eligibility to participate in the activities supported by the grant may be impacted if the validation process uncovers information that suggests that they may have provided inaccurate information as part of an attestation form provided for the purposes of a grant application. Further action may be taken to address this finding, pursuant to the corresponding granting agency’s authorities, and to the terms and conditions of the grant. The corresponding granting agency will work with the relevant institution(s) to address the issue and to determine the best route forward to minimize impacts, as possible, on the research, on the grant and on associated research personnel.

Should the finding invoke an allegation of misrepresentation in an agency application or related document, as per Article 3.1.2 of the Tri-Agency Framework: Responsible Conduct of Research (RCR Framework), or a breach of Agency policies or requirements for certain types of research, as per Article 3.1.4, the researcher’s institution will be responsible for conducting an inquiry and (if warranted) an investigation of the allegation following the RCR process. As per Article 4.3.4, investigation processes are conducted by a committee appointed by the researcher’s institution for the purpose of determining the validity of the allegation, wherein the respondent is provided an opportunity to be heard as part of the investigation. The respondent may appeal if a breach of policy is confirmed, and institutions can impose their own recourse.

Recourse for breaches of the RCR Framework varies by severity, intentionality, and impact of the breach, as per Article 6.1.3 of the Framework. Recourse from the corresponding granting agency may include, but is not limited to:

• issuing a letter of awareness to the researcher;
• requesting that the researcher correct the research record and provide proof that the research record has been corrected;
• advising the researcher that the agency will not accept applications for future funding from them for a defined time period or indefinitely;
• terminating remaining instalments of the grant or award;
• seeking a refund within a defined time frame of all or part of the funds already paid;
• advising the researcher that the agency will not consider them to serve on agency committees (e.g. peer review, advisory boards); and/or
• such other recourse available by law.

In exercising the appropriate recourse, the corresponding granting agency will give consideration to affected research personnel including students, post-doctoral fellows and research support staff.

For more information, please consult Tri-Agency Framework: Responsible Conduct of Research and the relevant RCR Framework Interpretations.

Frequently asked questions

Frequently asked questions (FAQ) about the STRAC Policy have been published alongside the policy on Canada’s Safeguarding Your Research portal. The following FAQs are intended to complement the broader FAQs, with regards to the implementation of the STRAC Policy at the granting agencies.

• When does the Policy on Sensitive Technology Research and Affiliations of Concern take effect at the granting agencies?
• Which funding opportunities does the Policy on Sensitive Technology Research and Affiliations of Concern apply to?
• Does the STRAC Policy apply to research grant applications submitted by researchers at colleges, polytechnics and CEGEPs?
• How do I submit my attestation form?
• Who has access to submitted attestation forms?
• Do highly qualified personnel (HQP) such as undergraduate and graduate students, post-doctoral researchers and research staff named in the body of the grant application need to submit an attestation form to the granting agencies?
• I was awarded funding for a grant application that will support research that aims to advance a STRA, and will be recruiting HQP (undergraduate and graduate students, post-doctoral researchers and research staff) to work on the project(s) or program of research funded by the grant. Will they need to comply with the STRAC Policy?
• How are collaborators impacted by the STRAC Policy?
• How does this policy impact the use of data and databases that might be linked to a Named Research Organization (NRO)?
• How will compliance with this policy be impacted by periodic changes to the lists of Sensitive Technology Research Areas and Named Research Organizations?
• My research is advancing a Sensitive Technology Research Area and I have recently ended my affiliation with or stopped receiving funding or in-kind support from a listed Named Research Organization. Do I need to indicate this in my funding application?
• My research is related to a Sensitive Technology Research Area, but I am unsure whether it aims to support the advancement of a technology as indicated in the policy. How can I make this determination?
• Do I need to inform the granting agencies if there is a change in the nature of the research pursued as part of a funded grant, that was not deemed to be advancing any of the listed Sensitive Technology Research Areas (STRA) at the time of the application, but that may now be advancing a STRA?
• What happens if a researcher who is affiliated with, or in receipt of funding or in-kind support, from one or more of the institutions on the List of Named Research Organizations seeks to join the research team for a project or program supported by a grant that aims to advance a Sensitive Technology Research Area?
• Can I recruit or collaborate with a researcher who was previously — but is no longer — affiliated with a Listed Named Research Organization (NRO)?
• What if a research team member becomes affiliated with or receives funding or in-kind support from an NRO after leaving a research team that is supported by a federal grant that aims to advance a STRA?
• How is this policy distinct from the National Security Guidelines for Research Partnerships?
• When should I reach out to the relevant granting agency, and when should I reach out to the Research Security Centre?

When does the Policy on Sensitive Technology Research and Affiliations of Concern take effect at the granting agencies?

The STRAC Policy and its requirements will be in effect for identified funding opportunities that launch as of May 1, 2024. Where applicable, applicants should review the Policy on Sensitive Technology Research and Affiliations of Concern, the guidance provided on this page, and the appropriate funding opportunity literature to ensure that they comply with these new requirements. These requirements will not apply retroactively to previously awarded grants.

However, as stated in Section 1 of the STRAC Policy, the Government of Canada may take affiliations into account as part of research funding decision-making processes prior to this date, 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.

Which funding opportunities does the Policy on Sensitive Technology Research and Affiliations of Concern apply to?

At this time, the Policy on Sensitive Technology Research and Affiliations of Concern applies only to funding opportunities that fund research grants to university and university-affiliated institutions. The following list of funding opportunities will apply the STRAC Policy, for competitions launching as of May 1, 2024. Please consult the appropriate funding opportunity literature to determine whether the STRAC Policy applies and, where applicable, for any additional information on procedures to be followed.

Does the STRAC Policy apply to research grant applications submitted by researchers at colleges, polytechnics and CEGEPs?

The STRAC Policy does not currently apply to funding opportunities that exclusively fund grants to colleges, polytechnics and CEGEPs, such as the College and Community Innovation program. However, as indicated in the STRAC Policy FAQ, researchers from colleges, polytechnics and CEGEPs will be required to comply with the STRAC Policy if they are members of a research team for a grant application submitted to a funding opportunity that is in-scope for the STRAC Policy (see list provided above).

How do I submit my attestation form?

Researchers with named roles in the grant application must download the form-fillable Attestation Form PDF template and save the file as “read-only”. For this purpose, one option is to save the file as a PDF. To fulfill application requirements, the lead applicant must collect all the necessary attestation forms from researchers with named roles in the grant application and use a PDF merging tool to combine all documents into a single PDF file. The applicant must then upload the single PDF into the “Attestation Form” module in the grant management system. Specific instructions will be provided at the agency level, for each grant management system.

For privacy considerations, researchers are encouraged to use trusted PDF merging tools provided or recommended by their institution.

If any funding opportunity deviates from this harmonized procedure, alternate procedures will be noted in the funding opportunity literature.

Who has access to submitted attestation forms?

Submitted attestation forms will be stored securely by the relevant granting agency in adherence with the Privacy Act. As a result, only the applicant, co-applicants, the relevant institutional officials and the relevant granting agency will have access to the submitted attestation forms.

If selected for the validation process, all information provided in the attestation forms will be shared with relevant Government of Canada departments and agencies for the purpose of national security assessment to validate compliance with the policy.

Do highly qualified personnel (HQP) such as undergraduate and graduate students, post-doctoral researchers and research staff named in the body of the grant application need to submit an attestation form to the granting agencies?

No. The naming and/or listing of HQP and other researchers within the body of a grant application does not constitute a named role for these researchers.

Only researchers with named roles in the grant application need to complete an attestation form as part of the grant application, if the grant will support research that aims to advance a STRA. However, students, post-doctoral researchers and/or research staff must complete an attestation form if they have a specific named role in the grant application (for example, as an applicant or co-applicant).

I was awarded funding for a grant application that will support research that aims to advance a STRA, and will be recruiting HQP (undergraduate and graduate students, post-doctoral researchers and research staff) to work on the project(s) or program of research funded by the grant. Will they need to comply with the STRAC Policy?

Yes. To comply with the policy, all research team members — including all HQP — involved in the activities funded by a grant that was identified as aiming to advance a STRA are individually responsible for ensuring that they do not hold an active affiliation or receive funding or in-kind support from an NRO, following the versions of the lists that were publicly available on the date that the grant application was submitted. This requirement applies for the duration of their involvement in the activities supported by the grant, regardless of whether an attestation form was required from a research team member at the time of application.

Following the terms and conditions of the grant, grant recipients should ensure that all prospective research team members — including all HQP — are aware of their individual responsibilities with regards to compliance with the STRAC Policy.

How are collaborators impacted by the STRAC Policy?

At the grant application stage, if the funding opportunity requires the identification of collaborators as researchers in a named role (in addition to other named roles like “applicant” and “co-applicant”), any researchers who are identified as collaborators must complete the form-fillable Attestation Form PDF and submit it as part of any grant application that is identified as aiming to advance a Sensitive Technology Research Area (see relevant FAQ below for details on how to submit the form). Attestation forms are not required for grants that will not aim to advance any of the listed Sensitive Technology Research Areas.

In addition, should the grant application be funded, additional requirements will apply for the duration of the grant. All research team members involved in the activities funded by a grant that was identified as aiming to advance a STRA — including all formal and informal collaborators who are engaged as part of the research team — are individually responsible for ensuring that they do not hold an active affiliation or receive funding or in-kind support from any of the listed Named Research Organizations, following the versions of the lists that were publicly available on the date that the grant application was submitted. This requirement applies for the duration of their involvement in the activities supported by the grant, regardless of whether an attestation form was required from a research team member at the time of application.

Following the terms and conditions of the grant, grant recipients should ensure that all prospective research team members — including all formal and informal collaborators who are engaged as part of the research team — are aware of their individual responsibilities with regards to compliance with the STRAC Policy.

How does this policy impact the use of data and databases that might be linked to a Named Research Organization (NRO)?

Data and databases can constitute a form of in-kind support, per the Policy’s definitions. Accordingly, a researcher involved in the activities funded by a grant that aims to advance a STRA may be in breach of the policy if they obtain data or databases from a Named Research Organization (NRO)

Specifically, it is the origin and ownership of the dataset that determines whether there may be a conflict with the policy. For example:

• If an NRO owns the dataset, or if an NRO is providing access to a dataset that was created by or in partnership with them, obtaining this dataset would be considered in-kind support from the NRO.
• If the dataset was created in collaboration with an NRO, but it is entirely owned by an organization that is not an NRO and access to the dataset is being provided by an organization that is not an NRO, obtaining this dataset would not be considered as in-kind support from an NRO.
• If the dataset was created by or in collaboration with an NRO, but it was published openly through a third-party open-access database and was obtained without any intervention by an NRO, this would not be considered as in-kind support from an NRO.

At all times, researchers are encouraged to apply sound cybersecurity and data management practices when obtaining, storing, and using data from an external source.

How will compliance with this policy be impacted by periodic changes to the lists of Sensitive Technology Research Areas and Named Research Organizations?

The lists of Sensitive Technology Research Areas and Named Research Organizations will be updated on a periodic basis, as risks can evolve and mature over time. It is therefore important to consult the latest version of these lists, when preparing any application for a funding opportunity where the STRAC Policy applies. More information will be provided at a later date, regarding the frequency of updates to these lists, and the method through which the research community will be informed about updates.

Where attestation forms are required as part of a grant application, these forms must include the date on which each form has been completed. Accordingly, the attestation will be considered following the versions of the lists that were publicly available through the links above, on the date indicated.

Should the grant application be funded, all research team members involved in the activities funded by the grant will be expected to comply with the policy, following the versions of the lists that were publicly available on the date that the grant application was submitted.

Where possible, list updates will be scheduled to avoid conflicts with active funding opportunity deadlines. However, in the event that the lists are updated between the date that a researcher’s attestation form was completed and the date when the application was submitted, the corresponding granting agency may request new dated attestation forms that certify the researcher’s compliance with the policy following the version of the lists at the time the grant application was submitted.

My research is advancing a Sensitive Technology Research Area and I have recently ended my affiliation with or stopped receiving funding or in-kind support from a listed Named Research Organization. Do I need to indicate this in my funding application?

No proof is required when submitting a grant application; however, you may be contacted at a later date should your application be selected for validation.

As outlined in the STRAC Policy FAQ, you are encouraged 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). For example, a copy of your resignation letter, emails from former co-workers acknowledging your departure, and any other proof that you can produce could help more definitively demonstrate whether your affiliations have ended.

My research is related to a Sensitive Technology Research Area, but I am unsure whether it aims to support the advancement of a technology as indicated in the policy. How can I make this determination?

A grant application should be identified as aiming to advance a STRA 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.

If you are unsure whether your research is aiming to advance a Sensitive Technology Research Area, you may contact the granting agency administering the funding opportunity for guidance:

• NSERC: researchsecurity@nserc-crsng.gc.ca
• CIHR: support-soutien@cihr-irsc.gc.ca
• SSHRC: researchsecurity-securiterecherche@sshrc-crsh.gc.ca

Do I need to inform the granting agencies if there is a change in the nature of the research pursued as part of a funded grant, that was not deemed to be advancing any of the listed Sensitive Technology Research Areas (STRA) at the time of the application, but that may now be advancing a STRA?

The STRAC Policy is within scope of Article 2.4 of the Tri-Agency Framework: Responsible Conduct of Research. As such, grant recipients must inform the relevant granting agency and officials at their institutions, including Research Grant Offices, of any changes in the nature of the research that may require the submission of attestation forms. Grant recipients may not proceed with these new research activities until the appropriate granting agency’s approval has been obtained.

If the grant is identified as aiming to advance a STRA after the grant application was initially submitted and the resulting change causes a conflict with the policy due to the involvement of a Named Research Organization, the corresponding granting agency will work with the relevant institution(s) to address the issue and to determine the best route forward to minimize impacts, as possible, on the research, on the grant, and on associated research personnel.

For the purposes of this policy, only the listed sub-categories of the list of Sensitive Technology Research Areas are considered sensitive. Areas of research not covered by the sub-categories of the list are not currently considered sensitive for the purposes of this policy. As noted previously, while the list of Sensitive Technology Research Areas may change over time, researchers are expected to be compliant with the version of the list at the time the application was submitted.

What happens if a researcher who is affiliated with, or in receipt of funding or in-kind support, from one or more of the institutions on the List of Named Research Organizations seeks to join the research team for a project or program supported by a grant that aims to advance a Sensitive Technology Research Area?

If any prospective team member has an affiliation with or is in receipt of financial or in-kind support from a Named Research Organization, and the research project or program is supported by a grant that aims to advance a Sensitive Technology Research Area, they must terminate this relationship before joining the research team. For the duration of the grant, all research team members are required to comply with the STRAC Policy.

When recruiting new prospective research team members and when developing new collaborations and partnerships, we recommend:

• Openly discussing researchers’ responsibilities with respect to the STRAC Policy and the terms and conditions of the grant.
• Conducting open-source due diligence to verify the prospective team member’s affiliation(s) and sources of funding or in-kind support. The Government of Canada offers a free online open-source due diligence training to safeguard research partnerships.

Should there be any changes to the set of researchers with named roles in the grant, please note the following:

• Grant recipients (such as “applicants” and “co-applicants”) must inform the corresponding granting agency and their institutional officials. Following the Tri-agency Guide on Financial Administration, grant recipients are responsible for ensuring that individuals on the grant team meet any applicable eligibility criteria detailed in the program and funding opportunity literature as well as in any relevant agency agreements. The administering institution is responsible for submitting a request to change the grant recipient or individuals on the grant team by completing the Grant Amendment Form for the corresponding granting agency’s approval.
• Other researchers with named roles in the grant application that do not have access to grant funds, such as “collaborators”, you may contact:
  • NSERC: researchsecurity@nserc-crsng.gc.ca
  • CIHR: support-soutien@cihr-irsc.gc.ca
  • SSHRC: researchsecurity-securiterecherche@sshrc-crsh.gc.ca

Other than changes to researchers with named roles, the granting agencies do not need to be advised of other changes to the composition of the research team (e.g., an HQP added to the research team) for the purposes of this policy.

Can I recruit or collaborate with a researcher who was previously — but is no longer — affiliated with a Listed Named Research Organization (NRO)?

Yes. The policy only applies to active affiliations with — and ongoing financial or in-kind support from — a listed NRO. Past affiliations and previous financial or in-kind support will not be considered.

If the grant was identified to be aiming to advance a STRA at the time of application, all prospective members of the research team must ensure to end all affiliations with — and financial or in-kind support from — an NRO prior to joining the team.

What if a research team member becomes affiliated with or receives funding or in-kind support from an NRO after leaving a research team that is supported by a federal grant that aims to advance a STRA?

Per Question 16 of the Policy’s FAQ, the dissemination of research results (for example, through a publication) is considered a research activity under this policy.

The granting agencies recognize that, since the research funded by a grant may only result in a publication months or years after the research has been completed, some of the co-authors on a publication supported by a grant that is advancing a STRA may be research team members who have left the team. The granting agencies also recognize that, 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.

Accordingly, when possible, the author affiliations listed for this researcher on the publication should be limited to the affiliation(s) they held at the time when they were involved in the activities funded by the grant; that is, before they became affiliated with the NRO. This would fairly recognize the researcher’s contributions to this work, while avoiding any inadvertent perception of conflict with the policy. If the journal or other dissemination venue requires all current affiliations to be listed, further detail could be conveyed in the body of the publication to specify that the researcher’s contributions to the work predated their affiliation to the NRO, in order to mitigate any inadvertent perception of conflict with the policy.

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.

How is this policy distinct from the National Security Guidelines for Research Partnerships?

The Policy on Sensitive Technology Research and Affiliations of Concern (STRAC) is distinct from, but complementary to, the National Security Guidelines for Research Partnerships (NSGRP). These policies operate independently and apply distinct requirements at the grant application stage and for the duration of the grant. Consult the appropriate funding opportunity literature to determine whether the NSGRP and/or the STRAC Policy apply. In some cases, both the STRAC Policy and the NSGRP may apply to the same funding opportunity.

The STRAC Policy addresses risks related to Sensitive Technology Research Areas performed with research organizations and institutions that pose the highest risk to Canada’s national security. This policy applies to all relevant funding opportunities that fund research grants to university and university-affiliated institutions. For these funding opportunities, any research grant applications that aim to advance a Sensitive Technology Research Area (STRA) will require the submission of attestation forms from researchers with named roles on the grant application certifying that they are not currently affiliated with, or are in receipt of funding or in-kind support from a Named Research Organization (NRO). For the duration of the grant, all research team members involved in the activities funded by the grant are individually responsible for ensuring that they do not hold an active affiliation or receive funding or in-kind support from any of the listed NROs, following the version of the NRO list that was publicly available on the date that the grant application was submitted. No additional requirements apply for grant applications that do not aim to advance any of the listed Sensitive Technology Research Areas.

The NSGRP address risks related to research projects conducted in partnership with private sector partner organization(s). Applications that apply the NSGRP undergo a Risk Assessment Review Process that supports the identification, analysis and mitigation of risks as part of the development, evaluation, and funding of research partnerships. The NSGRP apply to selected federal research partnership programs, where applicants seeking grant funding for research with one or more private sector partner organization(s) must complete a Risk Assessment Form, and grant recipients must implement any risk mitigation measures identified in their completed Risk Assessment Form and in their Notice of Decision. For more information, consult the Tri-agency guidance on the National Security Guidelines for Research Partnerships.

When should I reach out to the relevant granting agency, and when should I reach out to the Research Security Centre?

You should contact the relevant granting agency for any inquiries pertaining to :

• The granting agency’s implementation of the STRAC Policy, including the Tri-Agency Attestation Form and any guidance provided on this webpage.
• Research security requirements that apply as part of a grant application or to an awarded grant.

For questions or guidance on the above, you may contact:

• NSERC: researchsecurity@nserc-crsng.gc.ca
• CIHR: support-soutien@cihr-irsc.gc.ca
• SSHRC: researchsecurity-securiterecherche@sshrc-crsh.gc.ca

You should contact the Research Security Centre for any inquiries related to:

• Guidance on research security, including on how to safeguard research and associated best practices, as well as advice on any case-specific scenarios or concerns.
• The STRAC Policy including the lists of Sensitive Technology Research Areas and Named Research Organizations.
• Guidance on how to terminate an affiliation with, or funding or in-kind support, from a Named Research Organization.
• Guidance on how to apply due diligence practices and/or how to mitigate risks that may be associated with a collaboration or partnership that aims to advance a Sensitive Technology Research Area — whether or not the organization is listed in the most recent list of Named Research Organizations.