Technology Control Plans (TCPs)
A Technology Control Plan (TCP) is a document that outlines procedures to protect sensitive technologies, data, or materials from unauthorized access particularly by foreign nationals, in accordance with export control regulations. These plans are crucial for research institutions and other organizations dealing with export-controlled items, ensuring compliance with regulations like ITAR and EAR.
A Technology Control Plan (TCP) is required when research activities involve controlled information, technology, or equipment that must be protected under U.S. export control regulations or institutional security requirements.
You likely need a TCP if your project involves:
Controlled Unclassified Information (CUI)
- Handling, storing, or transmitting CUI
- Working under federal contracts with security clauses (e.g., DFARS, CUI requirements)
- Using or accessing a secure CUI environment or enclave
Export-Controlled Technology or Data
- Research subject to International Traffic in Arms Regulations (ITAR) or Export Administration Regulations (EAR)
- Use of controlled technical data, software, or equipment
- Sharing restricted information with foreign nationals (even within the U.S.)
Restricted Research Conditions
- Sponsor-imposed restrictions on publication or dissemination
- Limitations on who can participate in the project
- Requirements for pre-publication review or approval
Non-Fundamental Research
- Projects that do not qualify as fundamental research due to restrictions on openness or participation
- Industry-sponsored or defense-related research with access controls
Foreign National Participation
- Involvement of international collaborators, visiting scholars, or students where export-controlled technology is present
- Situations requiring a deemed export review
When research activities involve controlled information, technology, or equipment that must be protected under U.S. export control regulations or institutional security requirements, a Technology Control Plan (TCP) must be completed and submitted to the Export Control Officer for review and approval.
Please submit all TCP documents to: researchcompliance@smu.edu.
If you have any questions about TCPs, please contact Mary Travis, Export Control Officer, at: mtravis@smu.edu.
Export Control Flowchart Technology Control Plan (TCP) Template