U of G Guide to Mitacs Research Security Requirements

Applicants must determine and indicate in their grant application whether their proposed research will aim to advance any of the listed Sensitive Technology Research Areas. 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.

Research should be identified as aiming to advance a STRA if, during the course of the grant, it 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 (click on the links below to explore specific subcategories) of the list of Sensitive Technology Research Areas.

The Named Research Organizations (NROs) list was developed by the government of Canada and is composed of research organizations and institutions that pose the highest risk to Canada’s national security due to their direct, or indirect connections with military, national defence, and state security entities.

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 Former affiliations that are no longer active are not in scope of this policy.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.

Critical minerals include:

Critical infrastructure includes:

For added context around FOOD:

1. “Yes” - It is suggested that researchers respond with “yes” if the project focus is on food security or the infrastructure is related to food production and supply chains. For example, food processing, distribution, safety and manufacturing/maintenance of the equipment and other infrastructure necessary to agricultural, aquaculture, and fishery production and distribution, food safety and food security, genomics related to food animals or crops, high value crops (e.g. wheat, barley, corn, rice, potatoes, soybeans, etc.) where there is significant, widespread potential impact (economic and/or food security), agriculturally significant disease/pest investigation or management where there could be significant, widespread impacts (economic and/or food security).
2. “No” - A “no” response would be suitable for projects focused on the food item itself. For example, development of new food ingredients/products, choice of packaging, shelf-life studies etc., minor uses/minor use crops/minor species, and therefore having lower relative potential economic or food security impacts, issues where the potential impacts are localized (e.g. pest or environmental conditions affecting a localized geographical area), issues where the potential impacts are focused on the farm-scale vs. sector-scale, fundamental environmental investigations (e.g. precipitation, humidity, soil conditions etc.), animal behaviour and welfare.

Additional Resources:

• Canada’s Critical Minerals List
• National Strategy for Critical Infrastructure and Action Plan for Critical Infrastructure

Examples of personal data include but are not limited to:

• Personally identifiable health or genetic (e.g., health conditions or genetic test results)
• Biometric (e.g., fingerprints)
• Financial (e.g., confidential account information, including expenditures and debt)
• Communications (e.g., private communications)
• Geolocation
• Personal data concerning government officials (including members of the military or intelligence community)

The sensitivity of a large dataset depends on the nature, type, and state of the information it contains, as well as how it may be used in the aggregate:

• Large datasets, especially if aggregated, may be analyzed to reveal patterns, trends, and associations, especially related to human behaviour and interactions.
• Large datasets, if identified as having ethical, commercial, or legal impact on the individual, domestic, or international level could be considered as a lucrative research area with national security considerations.

Additional Resources:

• List 2 of Annex A of the National Security Guidelines for Research Partnerships 
• Guidelines for Categorization and Security of Research Data
• U of G’s Research Ethics Board Guidance on Long-term Data Storage and Usage
• Consult Matt Frontini, Research Services Office’ Manager, Legal Review, mfrontini@uoguelph.ca on the need for a data-sharing agreement or additional clauses within the research contract with your partners.

Some fields of research (for example, nuclear, chemical, biological, radiological, or space applications) have a clear link to advancing military or intelligence capabilities and, therefore, have laws and regulations in place that must be followed for the conduct of research and export of any resulting knowledge.

For example:

• Research in areas relating to conventional weapons and dual-use goods may be subject to the Export Control List (ECL) of the Export and Import Permits Act (EIPA) and may require permits prior to transfer of technology to researchers outside of Canada.
• Research in areas related to missile and rocket technology, space technology and chemical and biological weapons and agents may also be subject to the ECL of the EIPA.
• Research in areas involving or applicable to nuclear programs are subject to the EIPA as well as the Nuclear Non-proliferation Import and Export Control Regulations;
• Research in areas related to goods or technology identified in the Schedule of the Defence Production Act (known as the Controlled Goods List) are sensitive and subject to the Controlled Goods Program;
• Research partnerships with institutions and/or researchers located in a country listed on the Area Control List of the EIPA (currently Democratic People’s Republic of Korea) must be authorized by an export permit issued by the Minister of Foreign Affairs regardless of the nature of the research.
• Research partnerships with entities sanctioned under the Special Economic Measures Act or the United Nations Act may require prior authorization from Global Affairs Canada.

The ECL defines which goods and technology are controlled for export from Canada to other countries, regardless of their means of delivery. If you are working with items that are included on the ECL as part of this research project, you must answer “yes” to this question, whether or not you plan to export such items to someone outside Canada.

Additional Resources:

• Nuclear Non-proliferation Import and Export Control Regulations
• Export and Brokering Controls Handbook if applicable.
• Search these direct links: Export Control List, the Import Control List, and the Area Control List.
• For support around export control requirements and controlled goods, contact Research Security at research.security@uoguelph.ca and visit the Office of Research webpage on Controlled Goods and Controlled Technology.

If you have questions about intellectual property, please contact research.services@uoguelph.ca with your question and request to be connected to the Mitacs lead in the Research Services Office. They will engage the Research Innovation Office team, as applicable.

If you have questions about intellectual property, please contact research.services@uoguelph.ca with your question and request to be connected to the Mitacs lead in the Research Services Office. They will engage the Research Innovation Office team, as applicable.

The applicant will need to explain why they answered yes. Typically, a few sentences will suffice. If there are subtleties that the applicants wish to explain, they may provide a longer explanation as appropriate. Additionally, if any steps are being taken by the applicant to mitigate the risk, those details can be included. If anything needs further clarification, Mitacs may also reach out to the applicants to request additional details or information.

Mitacs will assess potential research security risks and/or anticipated benefits to Canada. Mitacs will consider questions such as the following:

• Does the non-academic host organization have business operations, assets, and employees in Canada?
• Does the non-academic host organization have product or service offerings within Canada?
• Is the non-academic host organization owned or influenced by foreign governments?
• Is the non-academic host organization under Canadian sanctions or based in a country on the Area Control List?
• Has the non-academic host organization been identified by security agencies as a threat to Canada’s national security? Applicants should consider any potential research security risks associated with the nature of the proposed activities.

The Research Security Team reviews the application prior to submission to Mitacs. This review is aimed at replicating the research security assessment that Mitacs will conduct as noted above. This includes completing a Partner Due Diligence assessment and Researcher Due Diligence assessment, as applicable. Should concerns be identified, the applicant will be provided information on the risk and advice on potential mitigation measures.