U-M Framework for Conducting Sensitive Research or Critical Technology Research while Traveling Internationally

Sensitive research focuses on subjects that may bring unwanted, potentially harmful action towards the researcher by any actor that deems the research or researcher a threat. The actor can be the host government, organizations, companies, or individual people. Examples of sensitive research can include topics related to:

• Marginalized groups based on gender, sexual orientation / presentation, ethnicity, race, religion, political leanings or affiliations, etc.
• Movements, policiespolicy, projects, topics, or organizations that are deemed socially or politically taboo and/or may be considered illegal in the host country.
• See University of College London: Sensitive Research for other definitions of sensitive research. 

According to the Clinton White House Archives, critical technology can be defined as “technology as knowledge that has the following characteristics:

• Systematized and practical, based on experimentation and/or scientific theory
• May involve new discoveries, current knowledge, or a combination of both
• Directed toward application or achieving a goal rather than only toward understanding
• Involves direct manipulation of materials or biological systems, or the implementation of mathematical algorithms
• Is reproducible and transferable” (National Critical Technologies List)

Examples of critical technology can include research related to:

• Resources of strategic interest to the host country (AI, machine learning, aerospace, communications, natural resources, etc), or intellectual property that other corporations or governments may deem valuable enough to intercept.
• Critical and emerging technologies of strategic U.S. national interest as defined with the critical and emerging technology list.

Within the Department of State Travel Advisories, the State Department identifies 8 countries with a higher risk of wrongful detention. These countries include Burma (Myanmar), China, Eritrea, Iran, Nicaragua, North Korea, Russia, and Venezuela. Though these countries have State Department advisories, instances of harassment, extended questioning at secondary inspection, and detainment may occur in other locations as well, such as Egypt, India, Israel, Turkey, and more. Travelers concerned about wrongful detention should contact the Global Engagement Team at global.safety@umich.edu. 

The U.S. government identifies Foreign Countries of Concern within the NSPM-33 guidelines where there is a heightened risk of theft of proprietary information.  These Foreign Countries of Concern include China, North Korea, Russia, Iran, and any other country deemed to be a country of concern as determined by the Department of State. Faculty and students conducting research in these locations or are concerned with traveling with proprietary information to any country should review the review the U-M International Engagement website and contact the research security team at InternationalResearchGuidance@umich.edu

International travel by University employees or students may be subject to export control regulations depending on the travel destination and the hardware, software, and/or technical data that is taken. Destinations subject to the most comprehensive U.S. embargos include Cuba, Iran, North Korea, Syria, and Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine. All faculty and staff are encouraged to review ITS’ Security Guidelines for International Travelers, U-M Know what you are taking with you, and U-M International Travel and Export Controls. Travelers going to Cuba, Iran, North Korea, or other sanctioned countries should contact the UM Export Control Program (exportcontrols@umich.edu) to ensure your travel complies with U.S. export control regulations.

1. Are any aspects of your research perceived to be Sensitive Research or considered Critical Technology Research as outlined in this document? If yes, how so?
2. Are you traveling to a country / location that poses a higher risk offor being arbitrarily detained or harassed based on your research? Notable countries include Burma (Myanmar), China, Cuba, Eritrea, Iran, Nicaragua, North Korea, Russia, Syria, Ukraine (Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine), and Venezuela.
3. Have scholars or researchers been harassed, harmed, detained, arrested, or deported for research similar to your topic? If so, what legal recourse do you have in the event one of these situations occurs? Resources include:
   1. The “Concerns involving the Rule of Law, Arbitrary Detention, Official Harassment, Corruption &/or Transparency” section of your country’s OSAC Country Security Report
   2. Within the “Local Laws and Special Circumstances” section of your travel destination’s Country Information page
   3. Crisis24 Location Intelligence Brief (sign-in or follow these account registration instructions to access the Crisis24 Horizon platform)
   4. The U-M resource What to Do: Detention or Arrest While Abroad
4. Does your research pose potential safety concerns for you, research colleagues, local contacts familiar with your research, or the research participants / interviewees? If yes, please describe.
5. Have you discussed the sensitive nature of your research and outlined a plan to conduct the research as safely as possible with colleagues, advisors, other researchers conducting similarly sensitive research in your intended travel locations, or the travel safety members of the Global Engagement Team?
6. Are there other characteristics related to your identity or experiences that may further increase your risk, such as your nationality, having dual nationality (note that many countries do not recognize dual nationality if you are traveling to a country where you are considered a citizen), gender, race/ethnicity, sexual orientation, religion, job category or employment history, affiliations with political parties or other organizations, history or evidence of activism, being related to activists or political dissidents, history of research interests, having perceived sensitive content on the internet, etc?.
7. Are you using United States federal funding, such as an NIH, DoD, or DoE, or other federal funding, for your travel or research / U-M business associated with your travel? If so, visit the U-M International Engagement page to determine if you are traveling to a country of concern and need to take additional precautions such as authorization from your research funding source.? For questions, contact the U-M research security team at  InternationalResearchGuidance@umich.edu

• Ethical Research – If your research involves human subjects, have you also considered the best practices for working with human subjects and vulnerable populations in the context of the political climate? In addition, has the research proposal been approved through the U-M IRB process? 
• Research Guidance – Do you have access to a colleague who has conducted similar research in your travel destination and can provide guidance on safety precautions? If so, what precautions do they recommend? 
• Conducting Research Securely– Are you able to conduct your research in a location and in a way that is necessarily discrete?  What are some steps you can take to lower your profile while traveling? If you are conducting Critical Technology Research in a Country of Concern, have you followed all travel security protocols as outlined on the International Travel and with Technology web page?
• Assess your international partners and Understand the Parameters of the Engagement – When assessing potential collaborators and collaborations, whether foreign or domestic, it is important to understand and establish the parameters of the engagement. Have you reviewed the questions to consider listed on the U-M Know Your International Partners page?
• Local contacts – Do you have local contacts whom you trust to knowknowing about your research? Do these local contacts have profiles that may endanger you by association? Before travel, determine how these local contacts can support you in staying safe while traveling and determine how they can support you if issues arise.
• Sanitize Your Digital Footprint and Devices – Have you read the Committee to Protect Journalists Digital Safety Kit to determine your digital footprint risk (including having social media or other online content that identifies you as someone who has perceived politically sensitive affiliations, endangering views, or sensitive research publications)? Have you taken steps to reduce risk? Have you taken steps to travel with clean electronic devices as described in the U-M Safe Computing for International Travel site and within the OSAC Risk Mitigation Practices for Journalists? 
• Communication – Are you able to communicate while in-country using an encrypted communication platform that cannot be intercepted? Is an encrypted device even legal in your destination? Also, are you able to communicate in a way that does not convey the sensitive nature of your research, even if these communications are intercepted? 
• In-Country Safety Plan – Do you have a plan in the event that you are harassed or detained? A plan can include establishing regular check-in communications and establishing a call protocol in the event you are missing or do not meet the established check-in routine. Do your in-country partners, collaborators, or acquaintances familiar with your research know how to advocate for you and contact U-M in the event you need support? See What to Do: Detention or Arrest While Abroad.
• U-M Travel Requirements – Have you registered travel, obtained GeoBlue, signed all necessary travel pre- departure documents within your travel registration, and reviewed travel travel resources provided on the Global Michigan page for your country? For students traveling to a U-M Travel Warning or Restriction destination, have you completed a Safety Plan and received International Travel Oversight Committee approval? See Travel Health Plan & Safety Plan Process for details.
• Providing U-M with Detailed Contact Information – Have you provided an accurate and detailed travel itinerary in the U-M Travel Registry? Have you provided a local contact number and addresses to all of your accommodations in the “How to Find Me” section of your Travel Registry? Have you shared a local contact person or collaborator that U-M can contact in the event that you are detained or unavailable while traveling? U-M will verify that you have completed these steps if you are completing a Safety Plan. 
• Maintaining Contact with U-M – Do you have regular check-in procedures with a faculty or staff member at U-M, e.g. a daily or weekly email? Have you and your contacts formed a plan in the event they do not hear from you for your regular check-in cadence? U-M contacts should know how to get ahold of Global Engagement Team members for non-emergencies (global.safety@umich.edu) and emergencies by calling DPSS. Details are on Global Michigan. 
• Exit Plan – Have you established a risk threshold of unacceptable risk? What is it? If you are abroad and your risk threshold is met or exceeded, and you still have the ability to leave the country, what is your exit strategy? Is this exit strategy realistic from financial and logistic perspectives? 

1. Think of each scenario that could occur because of the nature of your Sensitive Research or Critical Technology Research (secondary inspection at immigration, denial of entering the country, denial of future visas, exit ban, detention, arbitrary arrest, intellectual property theft, harassment, intimidation, violence, kidnapping, etc). Be as specific as possible.
2. Based on your understanding of risks, plot each scenario on this chart based on the likelihood of occurrence at your destination and the potential severity / impact.
3. Determine your comfort level with this result, since risk tolerance varies by individual. 
4. If the risks are not acceptable and you are not comfortable with travel:
   1. Can you take active steps to mitigate risks to your level of acceptability?
   2. Can the travel location be altered or risk mitigated to reduce the severity / impact or likelihood to your level of acceptability?
5. Travel only if the risk level is acceptable to you as the traveler AND
6. Travel only after following all U-M International Travel Policy guidelines and following the Office of the Vice President for Research International Engagement guidelines as it relates to Critical Technology Research, if applicable. 

• U-M GeoBlue Travel Abroad Health Insurance
• U-M Global Michigan: Country Risk Ratings
• U-M International Travel Policy SPG 601.31
• U-M Office of Research: Research Integrity and Compliance
• IRB Approval Process
• International Engagement
• University of Michigan Policy Prohibiting Participation in Malign Foreign Talent Recruitment Programs
• U-M Traveling Safely With Technology
• ITS’ Security Guidelines for International Travelers
• U-M International Travel and Export Controls
• U-M Know what you are taking with you
• U-M Safety Considerations for Independent Study & Field Research Abroad
• U-M Register Travel
• U-M Travel Health Plan & Safety Plan Process
• U-M What to Do: Detention or Arrest While Abroad

• Committee to Protect Journalists Digital Safety Kit
• Crisis24 Location Intelligence Brief (sign-in or follow these account registration instructions to access the Crisis24 Horizon platform)
• National Critical Technologies List
• National Science Foundation NSPM-33 Definitions
• OSAC Country Security Report
• OSAC Risk Mitigation Practices for Journalists
• U.S. Department of State Travel Advisories
• University of College London: Sensitive Research