These guidelines are intended to inform UT Dallas employees about federal and state government restrictions and requirements on international travel activities and on best practices for protecting UT Dallas data, research, and technology during international travel. These guidelines also share requirements and practices for UT Dallas employees contributing to sponsored research activities.

These guidelines are applicable when UT Dallas employees are 1) engaging in university international travel, 2) carrying UT Dallas devices while travelling outside of the United States, and 3) traveling for personal reasons to a foreign adversary country.

These guidelines complement the existing policies and standards published by the International Risk and Safety Office and the Information Security Office.

• Travel Authorization and Reports
• Device and Information Security Abroad
• Restricted Countries

Definitions

Foreign adversary countries are defined by the Department of Commerce as the People’s Republic of China (including Hong Kong and Macau), Cuba, Iran, North Korea, Russia, and Venezuela.

Professional Travel is understood to mean business travel and other travel related to a person’s profession. This term is derived from Texas Executive Order GA-48.

Personal Travel is understood to mean travel that is not professional travel. This term is derived from Texas Executive Order GA-48.

Remote Work is completing the same work normally performed at a specified University worksite but performing the work from another approved location. See the Remote Work HR page.

Sponsored research activities means externally funded research, export-controlled research, controlled unclassified research, and other research involving regulated data.

University devices mean any equipment owned by UT Dallas, including laptops, tablets, instruments, and other university-issued technology.

University International Travel is defined by UTDPP1108 as “any educational or business travel that is UT Dallas-sponsored, UT Dallas-administered, UT Dallas-organized, or conducted within one’s capacity as a UT Representative, regardless of credit or funding”.

Key International Travel Rules for UT Dallas Employees

1. UT Dallas employees cannot engage in professional travel to foreign adversary countries.
2. UT Dallas employees cannot accept travel sponsorship and other gifts from companies, government agencies, and other organizations associated with foreign adversary countries.
3. UT Dallas employees cannot attend conferences or events hosted by sanctioned parties or foreign adversary government agencies.
4. International remote work is not permitted except when the work is directly tied to official university business and performed during the time periods of authorized University International Travel.
5. Remaining abroad for personal travel after you have completed authorized University International Travel does not permit continued university work during that time, even if a UT Dallas device is available. 
6. Devices and data that are related to UT Dallas sponsored research activities cannot be carried or accessed while on personal travel to foreign adversary countries except when authorized by Research Security.
7. UT Dallas employees contributing to export-controlled or controlled unclassified research must carry a loaner device while engaged in international travel.
8. Devices and data that are associated with export-controlled or controlled unclassified research cannot be carried or accessed on international travel except when authorized by Research Security.

Travel Restrictions by Destination and Travel Type

Destination and Travel Type	Travel Allowed?	Temporary Remote Work Allowed?	Carry UT Dallas device?	Use Personal Device for UT Dallas work?
Professional Travel, non-Foreign Adversary country	Yes	Yes	Yes, loaner device required for ECI/CUI researchers	Emergency use only
Professional Travel, Foreign Adversary country	No	No	No	No
Personal Travel, non-Foreign Adversary	Yes	No	No, except if travel is connected to University International Travel	Emergency use only
Personal Travel, Foreign Adversary	Yes	No	No	No

Guidelines and Best Practices

Before your Trip

1. Decide whether you need to carry a UT Dallas electronic device.
   1. Consult with Human Resources and your supervisor if you need guidance on whether your activities constitute international remote work and justify carrying and using a university device.
   1. Research Security and Ethics recommends that researchers contributing to sponsored research activities carry UT Dallas electronic devices outside of the United States only when required for University International Travel activities.
   1. Loaner devices should be used whenever possible instead of devices routinely used to store and process sponsored research data.
2. Consult with your Grant Specialist in the Office of Sponsored Projects to determine if your sponsored research activities include sponsor reporting or approval requirements for foreign travel, foreign collaborations, or foreign research activities.
3. Consult with your foreign partner or host to determine whether any government authorization is necessary to carry out scientific investigations within their country’s borders and coastal waters. Researchers are responsible for obtaining the required authorizations. Researchers can contact exportcontrol@utdallas.edu for assistance with navigating foreign research permits.
4. Consult with Research Security to determine whether any export control or research security regulations apply to your travel plans or the items, materials, data, and information you intend to take abroad.
   1. Research Security and Ethics will provide a pretravel security briefing to personnel who need to make any changes to their travel plans or follow a specific security protocol to mitigate risks to data or research. Research Security and Ethics recommends the following public resources on travel security:
   • Elicitation Avoidance Guidelines
   • Safe Travel Tips for Government Employees
   • Travel Security Guidance for Emerging Technologies
   • Personnel who work with export-controlled information or Controlled Unclassified Information are required to use a loaner device, or refrain from carrying any UT Dallas device, when traveling internationally.
5. Consult with the Information Security Office and your IT support team to determine appropriate safeguards for your devices before international travel. You can find comprehensive guidance in the ISO International Travel Standard about how to secure devices during international travel. At a minimum, the following best practices should be implemented for devices used to store or process sponsored research data:
   1. Ensure your operating system and software are up to date. Request a vulnerability scan if available.
   1. Back up all sponsored research data and confirm that your device is encrypted.
   1. Remove any files containing confidential, regulated, or sensitive information from your sponsored research.
   1. Minimize risk by uninstalling or logging out of applications that are not needed for your trip.
   1. Use the UT Dallas GlobalProtect VPN to securely access university systems and data needed for your travel activities.
6. Obtain travel authorization prior to international departure for University International Travel.
7. Submit a personal travel report if you are visiting a foreign adversary country, or if you are required to report personal foreign travel by a research grant or contract.

During your Trip

1. Be alert that a foreign adversary representative could try to recruit you while you are traveling. Being approached in person or online before or after a meeting, or during a conference could be the start of a recruitment attempt. If you experience any suspicious interactions, you should let Research Security and Ethics know as soon as possible.
2. Be mindful of personal and professional conversations. Avoid discussing sensitive or confidential topics in public or with unverified individuals. Don’t overshare personal information with new acquaintances.
3. Politely deflect inappropriate inquiries. Do not share personal or UT Dallas-related information unless you are certain the person is authorized to know it.
4. Be especially alert to unsolicited conversations, urgent requests, or too-good-to-be-true opportunities during your travel.
5. Foreign adversary representatives could gain access to your hotel rooms and can get into hotel safes. Hotel safes can be used for the storage of valuable items but should not be used to store sensitive information.

After your Trip

1. Report to Research Security and Ethics if you suspect that UT Dallas technologies, data, or equipment may have been accessed, shared, or compromised during your travel. This includes:
   1. Unintended exposure of export-controlled research or Controlled Unclassified Information (CUI).
   1. Unauthorized discussions or transfers of sponsored research data.
   1. Interactions with foreign individuals or entities seeking access to unpublished sponsored research data.
   1. Any uncertainty regarding compliance with export control regulations during your trip.
2. Report any ethics concerns to Research Security and Ethics:
   1. Suspicious requests for sensitive or unpublished UT Dallas data.
   1. Gifts, honoraria, or travel support received from external entities during your trip. Use the Activity and Interest Report form when needed to comply with university and funding agency policy.
   1. Offers of positions or affiliations with external organizations made during your trip. Use the Activity and Interest Report form when needed to comply with university and funding agency policy.
3. Report any security incidents or suspected compromises of university data to the Information Security Office, including:
   1. Hacking or account compromise.
   1. Social engineering incidents where someone attempts to deceive, manipulate, or coerce you into disclosing sensitive information or providing access to university resources. This includes in-person approaches, phishing emails, pretexting (impersonating someone you trust), blackmail, intimidation, or scams.
   1. Situations involving theft, unauthorized access, sabotage, or tampering with UT Dallas devices or data. This includes suspicious attempts to handle or observe your equipment, deliberate damage, physical proximity-based intimidation, or break-ins where university materials were at risk. Even if you’re unsure whether a device was accessed, report the incident to initiate a security check.

Personal Devices

Use of your personal devices for university business may pose security risks to your university data. UT Dallas employees are strongly discouraged from using personal devices to access or process data related to UT Dallas sponsored research activities while on personal travel to foreign adversary countries.  In addition to the guidance in the ISO International Travel Standard, researchers should follow these recommendations to help mitigate risk:

• Uninstall or log out of any apps that process or store UT Dallas sponsored research data before travel.
• Remove any files containing confidential, regulated, or sensitive information related to your sponsored research.

Contact Information

For questions or guidance, please contact the appropriate office.

Office of Research Security and Ethics (ORSE): For questions regarding export control regulations, conflict of interest disclosures, and compliance with research security requirements.

Information Security Office (ISO): For inquiries related to information security, device security, and other cybersecurity risks during international travel.

International Risk & Safety Office (IRSO): For assistance with travel planning, safety protocols, and risk management while traveling abroad.

Office of Sponsored Projects (OSP): For assistance with the terms of research funding awards and executing agreements for foreign research collaborations, materials transfer, and data use.

Relevant Policies

• University International Travel
• Remote Work
• Information Security and Acceptable Use
• Export Control Compliance
• Conflicts of Interest and Commitment
• Foreign Talent Program Guidelines
• Gift Guidelines
• Sanctioned Organizations and Persons