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Secure cross-border research by treating data sharing as a project-specific institutional risk decision—not as a one-size-fits-all technology purchase. Before a partner receives access, identify what the project will share, assess the people, systems, funding and legal conditions involved, agree on permitted use, and put proportionate controls in place. The applicable rules depend on the countries, data, funding and agreements involved.
Start with the project, not a presumed level of risk
International collaboration is not inherently unsafe, and not every project or partner presents the same risks. The goal is to protect research while enabling legitimate collaboration. NIST’s November 2025 Research Security Framework (IR 8484r1) takes a risk-balanced approach, includes a Research Security Risk Determination Matrix, and supersedes its 2023 report. It covers areas including researchers, travel, collaborations, products and services, software tools, and funding opportunities.
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Use your institution’s research-security review and escalation process to consider the project’s purpose, likely outputs, partners, funding, tools, proposed access and foreseeable onward sharing. NIST’s framework is U.S.-oriented guidance; it is not a determination that a particular project is subject to U.S. requirements and does not replace other countries’ laws.
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Inventory what the collaboration will expose
Make an inventory before deciding how to share. “Research data” can include more than files: code, samples, instrument access, technical know-how, interim results and derived datasets may all need consideration. Identify the authoritative copy, its custodian, and what may be published or reused.
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- Personal or sensitive information: participant records, identifiers, health information or other data that may require privacy safeguards.
- Confidential or restricted material: sponsor-controlled information, confidential partner contributions, or information subject to an agreement.
- Intellectual property: unpublished results, inventions, code or other material whose disclosure or reuse may be limited.
- Potentially controlled technology: equipment, software, technical data or know-how that may be subject to export controls.
- Project outputs: what can be shared publicly, with collaborators, or only after review or approval.
Do not infer the legal classification from the fact that something is research data. Ask the relevant institutional offices to help classify uncertain material.
Map partners, access and the exchange
Record which institutions and people are involved, each party’s role, the project’s funding and contractual terms, the tools and services to be used, and the intended publication and sharing plans. Map not just the initial transfer but also remote access, local copies, discussion of results and any later disclosure to another party.
NIST SP 800-47 Rev. 1 (July 2021) frames information-exchange protection as a lifecycle: identify the exchange, assess protections, and manage risks before, during and after exchange or access. It treats agreements as part of that risk management; it does not prescribe a particular transfer technology.
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Agree roles and terms before granting access
Work with the appropriate institutional offices to select the agreement or combination of terms that fits the project, such as a research agreement, data-use or processing terms, confidentiality and intellectual-property provisions, sponsor requirements, and ethics approvals. Put practical responsibilities in writing before access begins.
- Specify permitted purposes and who may access the material.
- Set rules for onward disclosure, reuse and publication, including any required review or approval.
- Define how incidents will be reported and who will coordinate a response.
- State how long access may continue and what happens to copies when the project ends, including any return, retention or deletion obligations.
Choose an approved way to share
Use an institution-approved environment and controls suited to the data and the risk assessment. Make access specific to named people or roles and their need to know; authenticate users, keep access records where appropriate, and review permissions when staff or project needs change.
A controlled repository with remote access may be appropriate when collaborators do not need a local copy. It can reduce unnecessary duplication, but it does not by itself satisfy a legal transfer requirement. Evaluate implementation options against the institution’s approval, data location and custody, identity and access controls, auditability, onward-sharing permissions, incident support, contractual terms and the project’s privacy and export-control obligations. There is no single product that resolves those questions for every collaboration.
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Check privacy and transfer rules for the countries and data involved
“International” alone does not establish which privacy laws apply. If the EU General Data Protection Regulation applies, its Article 44 sets the general rules for transfers of covered personal data to a third country or an international organization. Article 45 provides for transfers based on an adequacy decision. Confirm applicability and the permitted Chapter V transfer route with the institution’s privacy or legal officers before a disclosure or access that constitutes a transfer; assess onward transfers as well.
Do not assume that a research purpose, encryption, anonymization, consent or a contract automatically makes every transfer lawful. The applicable route and any conditions depend on the facts and current legal status. Other national laws, localization requirements, ethics approvals and funder terms may also affect the project.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Screen for export controls when U.S. rules may apply
For U.S.-connected work, ask the institutional export-control official whether equipment, software, technical data or know-how is controlled and whether a proposed disclosure or access by a foreign person is restricted. International participation alone does not establish that an item is controlled.
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NIST IR 8484r1 says EAR- or ITAR-controlled information or technical data must not be transferred unless authorized by the appropriate regulator. Where applicable, an export-control official may recommend a Technology Control Plan. NIST distinguishes that plan from computer-access information protection: controlling system access is not, on its own, a substitute for determining whether export authorization is required.
Maintain controls and close access deliberately
During the project, review access and partner changes, keep records appropriate to the project, and follow the institution’s incident-escalation procedures. At closeout, remove access and handle data according to the governing agreements, applicable law and institutional policy. Decide in advance who will confirm those actions and how continuing retention, return or deletion requirements will be met.
Know when formal research-security programs may be required
In the United States, NIST’s FAQ, updated March 24, 2025, says organizations receiving more than $50 million per year in federal research and development funding must establish research-security programs under NSPM-33 implementation guidance. Described program components include cybersecurity, foreign travel security and research-security training, and, as appropriate, export control and compliance. This is a U.S. threshold, not a universal requirement; confirm current funder-specific and institutional obligations.
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