TRUSTED RESEARCH

Due diligence is the investigation or the exercise of reasonable care that a business or person is expected to undertake before entering into an agreement or contract with another party.  It promotes good decision-making by enabling the University to evaluate the risks involved in a partnership or activity, ensure compliance with legislation, and ensure that decisions are transparent, robust and defensible. 

Due Diligence is an integral part of Northumbria University’s risk management approach as it facilitates the identification of risk and the implementation of proportionate mitigation measures at the earliest possible stage.  Northumbria University conducts due diligence on all third parties involved in research projects.  

The National Security and Investment Act (2021) gives the government powers to scrutinise and intervene in business transactions, such as takeovers, to protect national security, while providing businesses and investors with the certainty and transparency they need to do business in the UK. 

The Export Control Order (2008, Amended 2022) restricts the transfer or disclosure of sensitive goods, software, and technology (know-how and other information) to recipients and destinations outside of the UK. This includes physical exports, electronic transfers (via email, file sharing, virtual meetings, etc.), and transfers by any other means (verbal communication). 

Sanctions are put in place by international institutions countries, including the UK, because of threats to international peace and security, human rights abuses and other criminal conduct, to prevent the proliferation of weapons of mass destruction, and / or to help combat terrorism.   They are restrictions on dealings with individuals, entities, government and sometimes entire countries.  Sanctions restrictions can take many forms.  The two categories of sanctions restrictions of most likely relevance to research activities are financial sanctions and trade sanctions.  The Government publishes information on UK sanctions regimes currently in force.  

The Academic Technology Approval Scheme (ATAS) is a government program that requires students, at Masters of PhD level, and researchers from certain countries to gain approval before travelling to the UK to study or engage in research in specific sensitive technology related fields.   

Northumbria is committed to protecting the personal data of its staff, students, collaborators, and research participants in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, as well as adhering to all relevant local data protection legislation in the country in which our research is taking place.    

As part of our Trusted Research and due diligence processes, we recognise that international collaboration and research partnerships may involve the transfer, processing, or sharing of personal data across borders. To mitigate associated risks: 

• We assess data protection implications as part of our research due diligence and ethics review processes. 
• We ensure that any sharing of personal data with third parties, including international partners, is lawful, proportionate, and subject to appropriate safeguards and is compliant with both UK and local law. 
• We conduct Data Protection Impact Assessments (DPIAs) where research activities involve high-risk processing, including the use of sensitive personal data or international data transfers. 
• We require all research partners to adhere to data protection standards that are equivalent to those under UK law, and we include data protection clauses in relevant agreements and contracts. 
• Researchers are expected to engage with the University’s Data Protection. Legal and Research Ethics teams at the earliest opportunity to ensure that data protection considerations are fully integrated into project planning, agreements and delivery. 

Northumbria University apply a 'Security-mindedness' approach to its research, which helps to protect against loss of valuable commercial information, personal data and intellectual property.   

Risks primarily come from hostile states, a state whose democratic values and ethical values are different from our own and whose strategic intent is hostile to the UK. A hostile state may: 

• Seek opportunities to increase its own economic advantage, in particular to develop a research and innovation base to increase military and technological advantage over other countries. 
• Prioritise the stability of its regime and focus on preventing internal dissent or political opposition. 
• Seek to deploy its technological and military advantages against its own people in order to maintain the stability of the regime. 

International collaboration provides an opportunity for hostile states to benefit from research without the need to undertake traditional espionage or cyber compromise by providing access to people, IT networks and participation in research which may be sensitive or have sensitive or dual-use applications. 

Northumbria University's research due diligence processes also look to identify and mitigate risks relating to the reputation of the researcher and the University, as well as being subject to Ethics and Integrity processes.  

UKRI Trusted Research Materials 

NPSA Trusted Research Materials  

UUK Managing Risks in Internationalisation 

Trusted Research and Due Diligence Hub (Internal Use Only)