7000 International Research, Programs, and Activities
Policy Sections
7000.1 Covered International Research, Programs, and Activities
7000.2 Office of International Affairs
7000.3 International Operations & Compliance Committee
7000.4 International Research, Programs, and Activities Committee
Scope
This policy applies to all Yale-affiliated individuals (including faculty, post-doctoral appointees, visiting faculty, staff, trainees, and students) who engage in research, programs, or activities occurring outside the United States that involve the situations defined as Covered International Research, Programs, and Activities in Definitions, below. Procedure 7000 PR.01 International Research, Programs, and Activities: Consultation, Review, and Approval describes the required institutional consultation, review, and approval for Covered International Research, Programs, and Activities, and provides guidance for identifying the appropriate Yale offices for support.
This policy and Procedure 7000 PR.01 International Research, Programs, and Activities: Consultation, Review, and Approval do not apply to: (i) standard academic travel, such as participating in conferences, giving performances, attending workshops, meeting with colleagues, or visiting institutions, archives, or galleries; (ii) customary academic collaborations among individuals; or (iii) routine research activities, if such travel, collaboration, or research does not involve the situations enumerated in Procedure 7000 PR.01 International Research, Programs, and Activities: Consultation, Review, and Approval, Section 2.
Policy Statement
Before they may engage in Covered International Research, Programs, and Activities, Yale-affiliated individuals must first consult all appropriate offices, as determined by the nature of the Covered International Research, Program, or Activity, and obtain all applicable institutional review and approvals.
Reason for the Policy
Yale supports and promotes the extension of its mission into the global community through research, programs, and activities occurring outside the United States. International research, programs, and activities may, however, involve numerous considerations requiring consultation with, and review and approval by, several university offices to assure compliance with University policies and procedures, and with U.S. and foreign laws and regulations. This policy provides a framework for consideration of, and support for, Covered International Research, Programs, and Activities.
Covered International Research, Programs, and Activities
Any institutional collaboration, sponsored project, or third-party or University funded program or activity conducted outside the United States that involves situations enumerated in Procedure 7000 PR.01 International Research, Programs, and Activities: Consultation, Review, and Approval, Section 2.
Policy Sections
Prior to engaging in Covered International Research, Programs, and Activities, Yale-affiliated individuals must obtain the necessary consultation, review, and approval, as provided in Procedure 7000 PR.01 International Research, Programs, and Activities: Consultation, Review, and Approval.
Covered International Research, Programs, and Activities may require the support of multiple offices. Procedure 7000 PR.01 International Research, Programs, and Activities: Consultation, Review, and Approval provides information to assist in identifying appropriate offices and obtaining support. Additional detailed information and guidance for international research, programs, and activities may be found in Yale’s International Toolkit.
The Office of International Affairs (“OIA”) provides strategic guidance and support in connection with Covered International Research, Programs, and Activities.
The International Operations & Compliance Committee (“IOCC”) provides operational guidance and support in connection with Covered International Research, Programs, and Activities.
The IOCC includes representatives from the Office of the Provost, the Office of the Senior Vice President and General Counsel, the Office of Sponsored Projects, the Tax Office, Human Resources, the Office of International Affairs, and Risk Management.
The Vice President and Vice Provost for Global Strategy and the Vice Provost for Research convene the International Research, Programs, and Activities Committee (“IRPA Committee”) to review and approve Covered International Research, Programs, and Activities presenting particular compliance, legal, or reputational risks, including risks involving intellectual property, data security, research integrity, national security as identified by the U.S. government, and political, civil, or human rights.
The IRPA Committee includes representatives from the Office of Research Administration, the Office of the Senior Vice President and General Counsel, the Office of International Affairs, and select faculty members.
Special Situations & Exceptions
Exceptions to this policy require prior approval from the Vice President and Vice Provost for Global Strategy, in consultation with other responsible offices, as appropriate.
Roles & Responsibilities
Individuals Engaging in Covered International Research, Programs, and Activities
- Consult all appropriate offices and obtain all applicable reviews and approvals, as determined by the nature of the Covered International Research, Program, or Activity.
- Individuals should be aware that review and approval of Covered International Research, Programs, and Activities may take longer than a similar activity occurring on campus.
Office of International Affairs
- Provides strategic guidance and support.
Office of the Senior Vice President and General Counsel
- Provides guidance and support on legal requirements and implications.
Vice President and Vice Provost for Global Strategy
- Has primary responsibility for guiding the University’s global strategy.
- Co-chairs the International Research, Programs, and Activities Committee.
Vice Provost for Research
- Supports the research enterprise across the University.
- Co-chairs the International Research, Programs, and Activities Committee.
International Operations & Compliance Committee
- Proposes policies, procedures, and guidelines.
- Assists with review, approval, documentation, and implementation.
International Research, Programs, and Activities Committee
- Consults on Covered International Research, Programs, and Activities escalated for its review.
- Reviews and approves Covered International Research, Programs, and Activities presenting particular compliance or reputational risks.
- Provides risk mitigation strategies.