Universities understand the importance of protecting potentially sensitive research for various safety and privacy reasons, and from parties that might use such research against our national interests. In some instances, there are other research inputs and products that may require additional security protections. AAU recommends that security ‘classification’ should be the primary mechanism for restricting access to research results when necessary.
AAU responds to the Department of Justice's NPRM regarding preventing access to U.S. sensitive personal data and government-related data by countries of concern or covered persons. AAU requests clarification on whether this applies to non-commercial basic research and agrees with COGR that various categories of ‘omic data encompass a wide set of measurements related to human physiological, pathological, or genetic measurements that are used to help understand basic mechanisms or functions of human health states and that do not contain identifiable information.
AAU and 4 other higher education organizations joined comments led by EDUCAUSE on the regulations proposed by the Cybersecurity and Infrastructure Security Agency (CISA) to implement the reporting requirements of the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA).
AAU, COGR, EDUCAUSE, APLU, and ACE comment letter in response to NIST Request for Public Comment on SP 800-171B.
Associations Comment on Compliance Requirements for Safeguarding Controlled Unclassified Information
Associations are concerned about the the compliance requirements for protecting CUI in non-Federal information systems.
Enclosed please find comments from the Association of American Universities, the Association of Public and Land-grant Universities, and the Council on Governmental Relations on the Department of Commerce Bureau of Industry and Security Revisions to Definitions in the Export Administration Regulations (RIN 0694-AG32). Our staff is available to provide more information or discuss these matters further should you have any questions regarding our comments.
Security Classification | Export Controls | Biological & Chemical Security | Memo | Science & Security
Comments from AAU, APLU, and the Council on Governmental Relations on the ITAR Amendment – Revisions to Definitions; Data Transmission and Storage (RIN 1400-AD70), August 3, 2015.
Comments | Security Classification | Export Controls | Biological & Chemical Security | Science & Security
AAU and COGR comment on the National and Archives Records Administration (NARA) proposed rule on Controlled Unclassified Information (CUI), RIN 3095-AB80, 2015.
AAU and COGR appreciate NIST’s responsiveness to concerns on the revised draft guidance concerning controlled unclassified information (CUI) outlined in NIST Special Publication 800-171.
AAU and COGR comment on the NIST Special Publication 800-171.
AAU and COGR respond to the June 29, 2011 Federal Register Notice of Proposed Rulemaking on Safeguarding Unclassified DoD information (DFARS Case 2011 D039).
Comments | Security Classification | Export Controls | Biological & Chemical Security | Science & Security