U of G Guide to the Sensitive Technology Research and Affiliations of Concern (STRAC) Policy
On February 14, 2023 [1], the federal government announced its intent to adopt an enhanced posture regarding Canada’s research security. On January 16, 2024, a follow-up statement [2] and the Policy on Sensitive Technology Research and Affiliations of Concern [3] (STRAC) were published.
Following the STRAC Policy, grant applications submitted by a university or affiliated research institution to the federal granting agencies and the Canada Foundation for Innovation (CFI) involving research that aims to advance a Sensitive Technology Research Area [4] will not be funded if any of the researchers involved in activities supported by the grant are currently affiliated with, or in receipt of funding or in-kind support, from a Named Research Organization [5].
The federal granting agencies are implementing the STRAC Policy in a harmonized manner, to funding opportunities that were launched on or after May 1, 2024. Tri-agency guidance on the Policy on Sensitive Technology Research and Affiliations of Concern (STRAC Policy) [6] describes the granting agencies’ harmonized approach, as well as agency-specific information, where necessary, as it pertains to the list of funding opportunities in scope of the policy (see relevant FAQ [7]), the individuals that are required to complete attestation forms, and other agency-specific procedures.
Funding opportunities that apply STRAC
Innovation:
- Alliance grants including Alliance International, special calls, and joint funding opportunities.
- Idea to Innovation
Discovery:
- Discovery Grants including Subatomic Physics and Supplements
- DND/NSERC Discovery Grant Supplements
- Discovery Horizons
- Research Tools and Instruments including Subatomic Physics
- Ship Time
- Subatomic Physics Major Resources Support
- Subatomic Physics Project Grants
Training:
- Collaborative Research and Training Experience
Promotion and Prizes:
- Gerhard Herzberg Canada Gold Medal for Science and Engineering
- NSERC John C. Polanyi Award
- Brockhouse Canada Prize for Interdisciplinary Research in Science and Engineering
- NSERC Donna Strickland Prize for Societal Impact of Natural Science and Engineering Research
- Arthur B. McDonald Fellowships
- Synergy Awards for Innovation
The policy will apply to all CIHR grant programs, excluding those focused solely on knowledge mobilization or individual awards (including, but not limited to, the Institute Community Support program, Café Scientifique, Travel grants, Planning & Dissemination grants, Capacity Building Workshops, Knowledge Synthesis grants, Prizes, etc.).
The program requirements for each funding opportunity launched on or after May 1, 2024, will be confirmed through the application process.
The following funding opportunities in the social sciences and humanities:
-
Insight Research
- Insight Development Grants
- Insight Grants
-
Research Partnerships
- Partnership Engage Grants
- Partnership Development Grants
- Partnership Grants (Stage 1 and 2)
-
Specific Strategic and Joint Initiatives
- Where the policy is referenced within the funding opportunity description
- Impact Awards
The STRAC Policy also applies to the following funding opportunities administered by the Tri-agency Institutional Programs Secretariat (TIPS), housed at SSHRC:
-
New Frontiers in Research Fund
- Exploration
- Transformation
- International
- Special Calls
- Canada Research Chairs
- Canada Excellence Research Chairs
- Canada First Research Excellence Fund
The STRAC policy will apply to every CFI funding program except the College Fund. CFI will implement these requirements according to the timeline in the table below. They are expected to apply to any new CFI funding program.
For updates see: Research security | Canada Foundation for Innovation [8]
Funding program | When will STRAC requirements be implemented? |
---|---|
Biosciences Research Infrastructure Fund – Partnership with Stage 2 of the Canada Biomedical Research Fund | Not applicable |
College Fund | Not applicable |
Exceptional Opportunities Fund | Beginning with any new proposal submitted after May 1, 2024 |
Innovation Fund | Beginning with proposals submitted to the 2025 competition |
2023 Innovation Fund competition | Not applicable. |
John R. Evans Leaders Fund (affiliated) | To be determined. Check back CFI website for updates. |
John R. Evans Leaders Fund (unaffiliated) | Beginning with any new proposal submitted after June 25, 2024 |
Major Science Initiatives Fund | To be determined. Check back here for updates. |
Northern Fund | Beginning with any new proposal submitted after May 1, 2024 |
Responsibilities of researchers
Applicants must determine and indicate in their grant application whether their proposed research grant will aim to advance any of the listed Sensitive Technology Research Areas [4]. This list is composed of several high-level technology categories, where the sub-categories indicate the specific Sensitive Technology Research Areas (STRA) of concern. For these areas, the specific concern is the advancement of a technology during the course of the research. Research that will merely use, but not advance, an existing technology is not within the scope of this policy. In addition, areas of research not covered by the sub-categories of the list are not currently considered sensitive for the purposes of this policy.
A grant should be identified as aiming to advance a STRA if the research supported during the course of the grant will aim to support the generation or discovery of knowledge that contributes to progress in the development of a technology described in the sub-categories of the list of Sensitive Technology Research Areas [4].
- If the research grant will not aim to advance any of the listed Sensitive Technology Research Areas [4], then no further steps are required under this policy.
- If the research grant will aim to advance any of the listed Sensitive Technology Research Areas [4], then the next step required is to check researchers’ affiliations and complete attestation forms for each researcher with a named role in the grant application (proceed to Step 2).
At the application stage, researchers with named roles in the grant application are individually required to complete the form-fillable Attestation Form [9] PDF and submit it as part of the grant application (see relevant FAQ [10] below for details on how to submit the form).
Researchers with named roles in the grant application: Examples of named roles include, but are not limited to, the Applicant, the Co-applicant, and the Collaborator, as defined by each granting agency. These roles are identified at the application stage, and they are described and defined in Appendix 1 of the Tri-agency Guide on Financial Administration [11]. The named roles may differ according to the granting agency and funding opportunity (definitions are provided below). Researchers (including HQP) are not considered to have a named role in the grant application if they are simply named or listed as part of the body of a grant application. Researchers who are not ‘named’ do not need to submit an attestation, but must comply with the STRAC policy for the duration of the project.
NSERC - Eligibility requirements for faculty to apply for or hold grant funds (nserc-crsng.gc.ca) [12]
Applicant - The principal investigator on an application. Leads the direction of the proposed research/activities, as well as coordinates the financial and administrative aspects of the application and grant.
Co-applicant - Member of a research group applying for a team grant. May lead some of the proposed research/activities.
Collaborators or participants may take part in a research team but will not have access to grant funds. Must be qualified to undertake research independently and will be expected to contribute to the overall intellectual direction of the research project or program of research. Refer to specific funding opportunities for detailed eligibility requirements.
Glossary of Funding-Related Terms - CIHR (cihr-irsc.gc.ca) [13]
Applicant (nominated principal) - The role on a CIHR funding application responsible for coordinating the financial and administrative aspects of the grant/award, as well as leading the intellectual direction of the proposed activities. CIHR funding opportunities and application forms may use other terms to refer to this applicant role.
Applicant (principal) - The role on a grant application for individuals who are responsible for leading the intellectual direction of the proposed activities. CIHR funding opportunities and application forms may use other terms to refer to this applicant role.
Co-applicant - The role on a grant application for individuals who are expected to actively participate in the proposed activities but not to direct them. CIHR funding opportunities and application forms may use other terms to refer to this applicant role.
Collaborator - CIHR defines a Collaborator as an individual whose role in the proposed activities is to provide a specific service (e.g., access to equipment, provision of specific reagents, training in a specialized technique, statistical analysis, access to a patient population, etc.).
Definitions of Terms (sshrc-crsh.gc.ca) [14]
Applicant (principal investigator / project director) - the applicant is the principal investigator / project director. This means they have primary responsibility for the overall intellectual direction of the research, research-related activity or partnership. They are also accountable, with the host institution, for coordinating the grant’s overall financial and administrative aspects.
Co-applicant (co-investigator) - An individual, participating in a grant application, who makes a significant contribution to the intellectual direction of the research or research-related activity, who plays a significant role in the conduct of the research or research-related activity, and who may also have some responsibility for financial aspects of the research. Eligibility requirements may vary between specific funding opportunities.
Collaborator - An individual, participating in a grant application, who may make a significant contribution to the intellectual direction of the research or research-related activity, and who may play a significant role in the conduct of the research or research-related activity.
Research security | Canada Foundation for Innovation [8]
Each project/team leader and team member who is named in the proposal must complete an attestation form to be submitted with the proposal.
In the context of CFI research infrastructure projects, project/team leaders and team members are subject to requirements under the STRAC policy. Users of the research infrastructure are not subject to requirements under the STRAC policy.
Completing the Attestation
Affiliation: Individuals are considered affiliated to any organization at which they are employed, appointed, or conduct research. In cases where individuals hold multiple affiliations, all must be considered when ensuring compliance to this policy. The policy only applies to current affiliations. Former affiliations that are no longer active are not in scope of this policy.
If you are unsure of what constitutes an affiliation, then please refer to the STRAC Affiliations Questionnaire, a self-assessment tool to help you determine whether or not you are affiliated with, or receiving funding or in-kind support from a Named Research Organization [15].
Merging and Submitting the Attestation(s)
Researchers with named roles in the grant application [16]must download the form-fillable Attestation Form PDF template [9] and save the file as “read-only”. For this purpose, one option is to save the file as a PDF. To fulfill application requirements, the lead applicant must collect all the necessary attestation forms from researchers with named roles in the grant application and combine all documents into a single PDF file (see directions below). The applicant must then upload the single PDF into the “Attestation Form” module in the grant management system. Specific instructions will be provided at the agency level, for each grant management system.
How to merge pdfs in Adobe Acrobat and Reader
- Save all Attestation forms as a PDF in a folder.
- Open Adobe, select Combine Files.
- Click on Select Files and add all the Attestations.
- Once all files are loaded on the screen, click on Combine.
- Save the new file.
More information is available here: Combine or merge files into a single PDF, Adobe Acrobat [17]
Conduct completeness check and review for common errors:
-
Have all the Attestations been filled in correctly?
- Has the date been included?
- Has the researcher included their affiliation and email address?
- Has the researcher ticked the Attestation Statement box at the end?
- Have all the Attestations been merged into one PDF?
Should the grant application be funded, additional requirements will apply for the duration of the grant.
- Grant recipients must inform the corresponding granting agency and their institutional officials if the nature of their research evolves and is now advancing a Sensitive Technology Research Area (see this FAQ [18]) or if the composition of the research team changes (see this FAQ [19]).
-
Grant recipients should ensure that all prospective research team members [20] are aware of their individual responsibilities with regards to compliance with the STRAC Policy.
- The University of Guelph has an internal Confirmation form similar to the Attestation form, that can be used as a tool by the lead applicant to confirm team members compliance with the policy for those who were not required to complete the attestation (go to the Definitions [7] section for more information on exactly who needs to complete the Attestation form and who doesn’t need to complete the Attestation form but is still required to comply with the policy).
- All research team members involved in the activities funded by a grant that was identified as aiming to advance a STRA are individually responsible for ensuring that they do not hold an active affiliation or receive funding or in-kind support from any of the listed Named Research Organizations [5], following the versions of the lists that were publicly available on the date that the grant application was submitted. This requirement applies for the duration of their involvement in the activities supported by the grant, regardless of whether an attestation form was required from a research team member at the time of application.
Additional Resources
- Sensitive Technology Research and Affiliations of Concern [21]
- Tri-agency guidance on the Policy on Sensitive Technology Research and Affiliations of Concern (STRAC Policy) [6]
- Canada Foundation for Innovation Research Security [8]
- Internal University of Guelph Confirmation form [22]
- STRAC Affiliations Questionnaire
If you are unable to find answers to your questions or have specific University of Guelph questions, then please contact research.security@uoguelph.ca [23].