What is a Technology Control Plan?

A Technology Control Plan (TCP) helps ensure that controlled materials will not be accessed by unauthorized persons. The need for a plan occurs whenever ITAR, CCL or other controlled items or data are present on campus or when UB personnel are using controlled materials while not under the direct control of the provider.

The most common use of a Technology Control Plan (TCP) is to identify controlled materials or data and describe how these items will be secured while at the university. It includes plans for storing / housing the items and procedures for guarding against unauthorized access to the restricted items or information.

The plans are customized dependent on the security measures needed for the circumstances and situations. The PI is responsible for helping develop the TCP and for subsequent monitoring. TCPs protecting export controlled information generally address the following:

  • Operate in secured laboratory space or during secure times so you can prevent unauthorized persons from observing the activities.
  • Lock data, lab notebooks, hard copy reports and research materials in fireproof cabinets in rooms with key-controlled access.
  • Do NOT transmit export controlled information through email.
  • Encrypt electronic records on a stand-alone storage device that is not networked with other university computers. 
  • Limit your discussions about the project or work products to the identified contributing investigators and talk where unauthorized persons are not present.
  • Complete a signed confidentiality agreement before discussing with third-party subcontractors, such as identified manufacturing sites.

There is a cost to protecting controlled materials so please keep this in mind when preparing a budget for a grant application. If you encounter unanticipated costs or changes in research require more money, consider other options for covering the additional costs, whether for a separate computer, special storage facilities or separate work space. Be sure your project sponsor is aware of the need for additional security measures related to the project and could perhaps help locate revenue. In any case, controlled information, technology and materials must be protected; there is no other option.

Use the template below to begin your TCP. UB's export control office will help you complete the plan and then work to have it approved.

UB Technology Control Plan Template
Writing a Technology Control Plan

If you need to develop a TCP, download the template, complete as much as possible and email it to the export control office. 

Here are a few tips for putting together your TCP:  

  1. Start by completing one set with the PI's name. The last few pages eventually will be completed by each person on the project. 
  2. Leave blank those items that are not applicable.
  3. This is not a competitive endeavor like a grant application so keep it simple and direct using lay language.
  4. Don't try to anticipate what the export control office wants to hear, instead include the factual information that you know and security procedures that you can achieve. If your proposed procedures are adequate, usually they will be accepted.
  5. Focus on the current project scope, not what may occur later.
    • For example, if you need the current TCP to share preliminary data with a collaborator in order to develop a grant application, just focus on that. Don't include any potentially controlled hardware that might be part of the grant if/when you get it. You can develop a second TCP fairly quickly and easily based on the information / experience gained with the first TCP.