Store Export Controlled Information and Items 

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Physical  

Any items controlled under the International Traffic in Arms Regulations (ITAR) (and certain items controlled under the Export Administration Regulations (EAR)) need to be physically secured so that unauthorized physical inspection does not occur. 

Allowing a foreign national physical access to such items can lead to a Deemed Export that would require a license from the federal government. Taking actions such as the use of designated and secured spaces (i.e., not common areas), locking doors and limiting access to the keys, maintaining visitor logs, and (in some cases) using video surveillance can all help mitigate the risk of such a violation.  

Anytime you suspect you have an export controlled item in your lab space, contact the Export Controls Compliance team for further analysis.  If warranted, a Technology Control Plan will be created to safeguard the items in question from unauthorized physical access.

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Cloud 

Many mail servers as well as file sharing solutions store information in the cloud.  Under the Export Administration Regulations there is a carve out for transmission of controlled data (technology) within a cloud service infrastructure - BUT there are many stipulations and exclusions furthermore this does NOT apply to controlled technical data under the International Traffic in Arms Regulations (ITAR).

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File Share

Not all file sharing solutions are export compliant. Some solutions save information to a local server while others save information to an off site server.

Contact the Export Control Compliance team if there is export controlled information that needs to be shared in a file share.  The Export Control Compliance team will work with the faculty member and DoIT to set up a solution and create a Technology Control Plan. 

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