What is a Technology Control Plan (TCP)?

A TCP is a document that formalizes the procedures that UNH will use to control access to and release of export controlled items, information, materials, etc. in accordance with federal export regulations.  A TCP is also a mechanism for documenting that research personnel are aware of their compliance responsibilities.

When do you need to use a TCP?

A TCP should be used when:

• A project or activity involves the receipt of Sensitive Unclassified Information (SUI) from an outside party or sponsor under a nondisclosure agreement or sponsored research agreement
• Projects or activities are not considered Fundamental Research; or
• Projects or activities involve technology and software associated with export-controlled equipment.

TCPs need to be completed and approved prior to handling export-controlled information associated with a research project.

What are the elements of a TCP?

A TCP generally includes:

• A statement of institutional commitment to complying with applicable regulations;
• Commodity Jurisdiction (which agency has authority) and classification (what type of item/information is involved);
• A description of physical security measures;
• A description of information security measures;
• Personnel requirements; and
• Administrative elements (i.e., inspections, training, recordkeeping, etc.)

The Office of Contracts and Export Controls (CEC) provides a project-specific TCP template to serve as a starting point, with the intention that it will be adapted to comply with the specific regulatory requirements and to accommodate the particular University project or program.

The completed TCP should be sent to CEC for review and comment BEFORE collecting the required signatures on the TCP Certification. Once CEC has approved the safeguards and confirmed the eligibility of the identified users the PI will be notified. At that point the PI will need to distribute the TCP to the authorized users and have them sign the TCP Certification. Once all of the user signatures have been obtained the signed form(s) must be returned to CEC for final approval.

Contact us if you have any questions regarding Export Controls at UNH.

Victor Sosa
Director
Contracts & Export Controls
Victor.Sosa@unh.edu
(603) 862-2001

Melissa McGee
Compliance officer
Research Integrity Services
Melisa.McGee@unh.edu
(603) 862-2005