International Travel and Conferences

Guidance to Faculty and Principal Investigators Regarding International Activities

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When should travel accommodations or travel expense reimbursements be reported?

With regard to financial conflict of interest (fCOI) reporting, which is required if you apply for external funding through MIT, sponsored travel expenses must be reported by investigators funded by agencies under the U.S. Public Health Service (PHS), including NIH, FDA, CDC and AHRQ. 

Certain federal funding agencies require disclosure of travel support. In addition, please pay special attention to federal progress report requirements, which may necessitate disclosure of international travel related to your project whether reimbursed or not. Please be sure to carefully review the applicable funding opportunity instructions and agency-specific guidance to determine if your travel expenses or international travel itself must be reported. If you have specific questions regarding federal funding agency disclosures, please contact the research-compliance-help@mit.edu mailbox to discuss your individual situation.

February 19, 2021

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If I, or someone whom I supervise, is traveling internationally, what should be done to prepare for traveling with MIT data?  Should the traveler remove their MIT e-mail from their devices?

It is each MIT community member’s obligation to take proper care in protecting MIT data (i.e. data or information a person has access to by virtue of the person’s MIT activities, including, without limitation, research data, pre-publication manuscripts, Institute financial records, employee and student records, etc.). This obligation applies at all times, and it is particularly important to consider data implications when planning international travel.  MIT’s Information Protection website has guidance on classifying data as “low risk” (e.g. public information), “medium risk” (e.g. unpublished research papers and other information not intended to be freely available), and “high risk” (e.g. information protected by law, such as certain health, student, and personally identifiable information, as well as export controlled information). This website also describes steps to take to protect MIT data based upon risk classification. 

Before traveling abroad with MIT data, the traveler should discuss the traveler’s plans, including data protection considerations, with their supervisor and/or the MIT principal investigator for their project, who should consult with IS&T resources as necessary.  When traveling, particular care should be taken with respect to “high risk” information, which may be prohibited from being taken outside the country or downloaded from the “cloud” onto local servers outside the U.S. If MIT community members have questions regarding export control restrictions on MIT data, they can contact the export control team (exportcontrolhelp@mit.edu). The traveler and project principal investigator must also ensure compliance with any commitments made by MIT to third parties regarding data confidentiality and use, such as through a non-disclosure agreement with a research sponsor covering the sponsor’s proprietary information. 

To aid in travel preparation plans, IS&T provides resources on securing computer hardware and data when traveling, and MIT GSR’s Travel Abroad Checklist provides overall travel preparation advice. If MIT data is stored in an e-mail program, then that data may need to be deleted or moved prior to travel to comply with the information security protections noted above. The traveler does not necessarily need to remove the e-mail program completely. However, the traveler may also contact their local IT support provider to ask if a sanitized loaner computer and/or mobile device is available for use while traveling. Taking a sanitized device equipped with only ordinary, recognizable software and minimal data can help reduce travel delays and the consequences of lost data.

It is also prudent practice to similarly protect personal data and any other data unrelated to MIT activities.

Please note that U.S. government officials possess broad discretion to search electronic devices (including any content on them) and other belongings when a traveler is leaving or entering the U.S. MIT community members may review more detailed international travel guidance prepared by MIT’s Office of the General Counsel.

February 19, 2021

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How can I learn more about my rights and responsibilities if U.S. Customs and Border Protection (CBP) officials seek to question me or search my electronic devices or other belongings while I am leaving or entering the country?

MIT community members may review detailed international travel guidance prepared by MIT’s Office of the General Counsel. This guidance provides recommendations for minimizing the chances of travel disruption, including an example of documentation to procure if it is necessary to travel with MIT data or materials.

February 19, 2021

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May I attend and present at international conferences?

Yes, in most countries, except those countries that the U.S. has comprehensively sanctioned — Iran, Cuba, North Korea, Syria and the Crimea region of Ukraine. Please contact exportcontrolhelp@mit.edu if you are planning to present at a conference in one of these sanctioned countries.

Generally, a presentation to an international audience should be limited to the following: information that is already published; information already in the public domain; and/or information consistent with that conveyed by instruction in catalog courses and associated teaching laboratories at U.S. institutions of higher education. However, certain sensitive information (e.g. defense or nuclear-related or subject to export controls) cannot be shared via open conference or webinar outside the U.S., so please contact exportcontrolhelp@mit.edu to discuss your specific situation.

Please see the response to "How should my outside activities and compensation be disclosed?" if you receive compensation for conference presentations for information about outside professional activity (OPA), financial conflicts of interest, and federal reporting requirements.

February 19, 2021

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May I host a public webinar/web conference on my research?   Can it be open to the international community?

Yes, you may host a public webinar on your research. If your webinar will be open to the international community, please see the additional guidance below.

  • Information released at an open conference, meeting or webinar is considered published and excluded from U.S. export controls. “Open” means that all technically qualified members of the public are eligible to attend, and attendees are permitted to take notes or otherwise make a personal record (not necessarily a recording) of the proceedings and presentations. An “open” conference can charge a registration fee reasonably related to cost, and can limit actual attendance, as long as attendees are admitted either on a “first come-first served” basis or are selected on the basis of relevant scientific or technical competence, experience, or responsibility.  However, certain sensitive information (e.g. defense or nuclear-related or subject to export controls) cannot be shared via open conference or webinar, so please contact exportcontrolhelp@mit.edu to discuss your specific situation.
  • In addition, please contact exportcontrolhelp@mit.edu if you may have attendees or participants from countries that the U.S. has comprehensively sanctioned—Iran, Cuba, North Korea, Syria or the Crimea region of Ukraine— as special restrictions may apply.
  • Generally, a presentation to an international audience should be limited to the following: information that is already published; information already in the public domain; and/or information consistent with that conveyed by instruction in catalog courses and associated teaching laboratories at U.S. institutions of higher education.
  • Please see the response to "How should my outside activities and compensation be disclosed?" if you receive compensation for conference presentations for information about outside professional activity (OPA), financial conflicts of interest, and federal reporting requirements.

February 19, 2021

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