Implementation of Section 889 of the National Defense Authorization Act (NDAA) for Fiscal Year 2019

Limitations on the Use of Certain Telecommunications Equipment or Services

Federal law places limits on the use of certain telecommunications equipment or services produced or provided by Huawei Technologies Company, ZTE Corporation, Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, Dahua Technology Company, and any subsidiary or affiliate of these entities. This list also includes telecommunications or video surveillance equipment or services of an entity that the U.S. Secretary of Defense reasonably believes to be owned or controlled by, or otherwise connected to, the government of the People’s Republic of China.

These requirements apply to Yale due to its receipt of federal grant and contract funds.

Accordingly, the university generally prohibits use of IT Systems** produced by, or incorporating any technology, equipment, or services from, one of these entities for university business unless approval is obtained from Yale’s Director for Export Controls. This general prohibition extends to IT Systems not owned by Yale. To ensure compliance with these requirements, Yale conducts periodic reviews of Yale’s network to help identify IT Systems potentially covered by this section. If members of the Yale community become aware of telecommunications equipment or services covered by this section being used or potentially used to conduct Yale business, or have any questions about these restrictions, please contact the Director for Export Controls (email: exports@yale.edu).

Yale business includes all activities undertaken within the scope of an individual’s employment or appointment at Yale. Departmental business offices should ensure faculty and staff with purchasing authority are aware of these restrictions.

Resources

• List of restricted telecommunications companies and their known potential subsidiaries and affiliates.
• 1607 Information Technology Appropriate Use (Policy 1607).
• 3220 Purchase of Restricted Items (Policy 3220).

** An “IT System” is defined as any equipment or device that can store, process, or transmit electronic Yale data. This includes, but is not limited to, servers, personal computing devices, applications, printers, networks (virtual, wired, and wireless), supervisory control and data acquisition (SCADA) systems, building control systems (BCS), phones and cell phones, tablets, video surveillance equipment, radio equipment, routers, online and offline storage media and related equipment, software, and data files that are owned, managed, or maintained by Yale University. For example, IT Systems include institutional and departmental information systems, faculty research systems, computer workstations and laptops, the University’s campus network, and computer clusters.