Research security

Sensitive research can be defined as any theme of research that could generate results and technologies of dual-use (i.e., used for civilian and military applications), and this includes the following:

• Research that requires access to facilities or infrastructure that house or transfer sensitive data (i.e., sensitive personal data or large amounts of data that could be sensitive in the aggregate)
• Research related to critical minerals, critical infrastructure, or sensitive research areas as discussed in Annex A of the National Security Guidelines for Research Partnerships
• Research in areas covered by Canada's Export Control List and/or research in areas related to goods or technology identified in Canada's Controlled Goods List

Public Safety Canada is currently developing a list of sensitive research areas. It is expected to include:

• Energy technology (advanced)
• Artificial intelligence and big data technology
• Materials and manufacturing (advanced)
• Life science technology
• Sensing and surveillance (advanced)
• Neurotechnology and human machine integration
• Advanced weapons
• Quantum science and technology
• Aerospace, space and satellite technology
• Robotics and autonomous systems
• Digital infrastructure technology (advanced)

The government is yet to release the list of entities with ties to military, national defence or foreign state actors. Moreover, it is common understanding within the research security community that certain organizations listed on well-known sources online have a good chance of making the list. While we wait for the official list of entities, the following are sources the government may use in part to compile their final list:

• US Department of Commerce: Bureau of Industry and Security
  • Entity List: a US-based list of companies sorted by country that are subject to certain licensing requirements for federal contracts, and where there is a "Presumption of Denial"
  • Denied Persons List
• Russian Asset Tracker
• China Defense Universities Tracker

As the Research Security Unit (RSU) scales up, we will be able to provide some support on partnership diligence. It is always recommended that you do your own due diligence on potential partners while considering partnership. Faculty members and the research community can contact researchsecurity@uvic.ca for available support.

The Government of Canada has not yet released an official definition of affiliation. In light of research security, affiliation is expected to be linked to the list of entities that Public Safety Canada will announce in the future. Such list is expected to include universities, research institutes and laboratories connected to military, national defence or foreign state actors that pose a risk to Canada's national security. From what we gathered from various fora, the following scenarios could establish an affiliation:

• A researcher is receiving in-kind support from any of the entities on the list
• A researcher has some kind of status, such as adjunct professor, fellow or visiting scholar, at any of the entities on the list
• A researcher is part of an official talent program involving any of the entities on the list
• A researcher is receiving research funding from any of the entities on the list
• A researcher is in an active research collaboration with any of the entities on the list

Moreover, co-authorship of publications is not being viewed as having an affiliation. However, it is common understanding that some co-authorship could potentially translate to an affiliation at some point in the researcher's career.

If your research program is not in a sensitive area, and the researcher(s) involved do not have an affiliation with a restricted entity, the risk to an individual researcher or a given research program is low. If your research program falls into a sensitive research area, you may need to take precautions when leading or participating in research collaboration projects. As indicated in the February 2023 statement from Minister Champagne et al., proposed research in a sensitive area will not be funded if any of the researchers involved are affiliated with a restricted entity.

The potential risks we see from these regulations include:

• Access to funding: Being affiliated with, or accepting funds from one of these restricted entities could affect a researcher's ability to obtain other tri-council or federal government funding.
• Declaring affiliations: Attestations regarding affiliations will be required starting in the summer of 2023. There will be an extra burden to update these attestations in the event there are changes in the composition of the research team, or if the team members add affiliations during the term of a research program.

Equity, diversity, and inclusion are guiding principles to the implementation of these new measures, as with all research security measures that aim to safeguard Canada's world-leading research ecosystem. Freedom from discrimination is a fundamental and internationally recognized human right, that is necessary for all aspects of the research enterprise. The Government of Canada, the federal granting agencies, research institutions and researchers have a shared responsibility to ensure that these new measures do not lead to discrimination against or profiling of any member of the research community. This principle has been similarly reinforced in the Risk Assessment Form, which was updated in March 2023 and states that excluding any individual from participating in a research project on the basis of their citizenship or country of residence is not an acceptable risk mitigation measure. The Government of Canada and the federal research granting agencies will continue to support and to work with the research community, to safeguard Canada's research alongside our continued commitments to open science, international collaboration, and equity, diversity, and inclusion.