US export controls prohibit the unauthorized release of controlled information and data toÌýcertain foreign nationals. This prohibition includesÌýthe release of data through an actualÌýelectronic transmission (e.g.Ìýemail), as well as sharing of information that could enable unauthorized foreign access to controlled data stored in the cloud.


Basic "off the shelf" cloud computing resources do not offer secure storage and transmission without upgrading directly with the provider. Using these resources for information that is subject to export controlsÌýmay result in unintended technology transfer as well as legal liability for you and for CU. Examples of providers that require additional steps prior to use include: Dropbox, iCloud,ÌýGoogle Docs,ÌýG-mail, Hotmail, Yahoo mail, etc. It is not sufficient to add a VPN or certain types of encrypted channels if the companies involved in providing that service are not cleared by ¾«Æ·SMÔÚÏßӰƬ OIS and OEC prior.Ìý

¾«Æ·SMÔÚÏßӰƬ has IT infrastructure solutions to secure data and information according to standards required by U.S. export controls. CU IT policies ensure that facilities are located in the US and employees are US citizens or permanent residents. When you use unapproved external resources to store or transmit controlled data, you lose control, and can be liable for any access to that data or software by unauthorized foreign nationals. This is the case even if unintentional, and even if you were not aware of the access occurring.ÌýOne example of a CU service that maintains effective data securityÌýis , which allows for the secure transfer of files.

The use of external cloudÌýcomputing services, without an enforcible data security agreement, creates an unacceptable risk to the University. Prior to using an external provider for controlled data, you must, at a minimum, know: a)Ìýthe location of the relevantÌýservers and infrastructure, b)Ìýhow the provider will route traffic (particularly during peak- or off-times), c)Ìýwhether the provider's procedures prohibit access to your data by foreign nationals, and d)Ìýthe standard of encryption used for data in transit.ÌýÌý

If your research is determined to be export-controlled, OEC will work with you to create aÌýTechnology Control Plan, which will address the need for secureÌýstorage and transmission of controlled data.ÌýIf you have questions, or need further guidance on data security, please contact OEC atÌý exportcontrolshelp@colorado.edu.