What is a Technology Control Plan (TCP)?
A TCP is a type of data management plan that outlines how export-controlled information, technology, software, or items will be managed, kept secure, and protected. The export of certain technologies, software, and hardware is regulated and controlled by Federal law for reasons of national security, foreign policy, prevention of the spread of weapons of mass destruction, and for competitive trade reasons.
Why should I write a TCP?
A TCP is intended to prevent unauthorized access by foreign nationals to export-controlled information and technology under the International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR), and the Office of Foreign Assets Control (OFAC). Under these regulations, persons who engage in unauthorized exports can be subject to civil and criminal penalties including fines and imprisonment.
When should I write a TCP?
TCPs are implemented on a case-by-case basis in collaboration with the Export Control Officer (ECO) and the Principal Investigator. Examples of situations in which a TCP is required include but is not limited to:
- Receiving export-controlled technology from a sponsor or collaborator
- Engaging in research subject to government-imposed national security controls
- Sending or carrying export-controlled technology outside of the United States
Please contact exportcontrol@utdallas.edu for assistance in evaluating your research or technology for export control obligations. Please provide the following in your request:
- Statement of Work (SOW)
- Description of existing technology to be used in the project
- Identify if foreign nationals or foreign collaborators will be involved in the project
- Identify if information, technology, software, or items will be sent outside of the United States
How do I write a TCP?
Although researchers have the option to download the UT Dallas DMP template as a word document, it is highly encouraged that researchers use the DMPTool to craft their DMP. DMPTool is a free online web application that researchers can use to create DMPs using UT Dallas and funder specific DMP templates. Researchers can create, store, share, and request reviews of their plan all through one interface. Learn more about the DMPTool or visit our how-to guide.
What do I have to address in a TCP?
Although DMP structures may very across funding agencies, in general, a DMP can be broken down into 5 main sections:
Project Details
- UTD Project ID & Agreement Type
- Project Dates
Data Collection
- What data will you collect or create?
- How will the data be collected or created?
- Describe the information, data or materials that will be disclosed.
- Describe when technology exchanges will begin, and how often such exchanges will occur throughout the project.
- Describe how the controlled information, data, or materials will be transmitted or transferred to you/UTD.
- Describe how the controlled information, data, or materials will be used or studied at UTD.
Documentation & Metadata
- What documentation and metadata will accompany the data?
Ethics & Legal Compliance
- How will you manage any ethical issues?
- How will you manage copyright and Intellectual Property Rights (IP/IPR) issues?
Physical Security
- Locations Covered by the TCP (add additional rows as needed).
- How will you manage physical access and security?
Information Security
- How will the data be stored and backup during the project?
- How will you manage information security and access?
- What UTD equipment will be used and supported by Information Security to process, store, or access the data?
- What UTD equipment will be used to transmit controlled information between UTD and the disclosing entity?
Data Sharing
- How will you share the data?
- What are the restrictions on release or dissemination of the data?
- Who will have access to the data?
Selection & Preservation
- Which information, data, software, or items are of long-term value and should be retained, shared, and/or preserved?
- Which information, data, software, or items must be destroyed or returned to the Disclosing Entity at the termination of the project?
How do I request feedback on a TCP?
In the DMPTool, researchers may simply click the “Request Feedback” button under the “Request Feedback” tab and the Data Management Services team will be notified automatically.
Once a TCP is reviewed by the Data Management Services team, the Principal Investigator will receive the final version of the TCP and the Technology Control Plan Certification form. All project personnel are required to read, understand, and sign the TCP prior to beginning work on the project.
The TCP will be approved by the Export Control Officer and the Chief Information Security Officer.
TCP Examples
Documentation
