US export controls prohibit the unauthorized release of controlled information and data to听certain foreign nationals. This prohibition includes听the release of data through an actual听electronic transmission (e.g.听email), 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 controls听may 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,听Google Docs,听G-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 CU Boulder OIS and OEC prior.听
CU Boulder 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.听One example of a CU service that maintains effective data security听is , which allows for the secure transfer of files.
The use of external cloud听computing 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)听the location of the relevant听servers and infrastructure, b)听how the provider will route traffic (particularly during peak- or off-times), c)听whether the provider's procedures prohibit access to your data by foreign nationals, and d)听the standard of encryption used for data in transit.听听
If your research is determined to be export-controlled, OEC will work with you to create a听Technology Control Plan, which will address the need for secure听storage and transmission of controlled data.听If you have questions, or need further guidance on data security, please contact OEC at听 exportcontrolshelp@colorado.edu.