a) any teaching / research content is controlled
b) anyone granted access to the content is working from outside the UK
c) it is necessary to include controlled content in the teaching materials for remote teaching
If it is not necessary to include controlled content, then it is recommended that this should be removed. Should removing controlled material be impossible, then a licence application will be needed. To apply for a licence please complete an
Export Control Enquiry Form and submit this to
RDM@napier.ac.uk
Anyone teaching undergraduate or postgraduate courses who becomes aware, is informed or comes to suspect that the material they are sharing through the course will be used for a WMD purpose should seek advice by contacting RDM@napier.ac.uk.
Guidance on Remote Teaching and Export Control
It is possible for controlled technology to be shared with individuals overseas through remote teaching (e.g. through lecture notes, course materials, and slides). Most material used in teaching, particularly undergraduate teaching, will be in the public domain and therefore not controlled. In research-led post-graduate teaching, however, instances may emerge in which technology (i.e. information necessary for the development, production or use of controlled goods) that is not already in the public domain could be included in remote teaching and sent to individuals overseas.
To ensure that material is not inadvertently exported through remote teaching without the necessary licence, it is important that those running remote postgraduate teaching in relevant disciplines undertake due diligence to ensure that all materials sent to students overseas comply with export controls. The guidance below provides an overview of how to do so.
Due Diligence
Export controls are most likely to affect teaching in certain scientific and technical areas with potential military or WMD applications, for further information see the University website under the heading ‘Who is most likely to be affected?’. These areas are similar to those covered by the
Academic Technology Approval Scheme (ATAS)3 and any course covered by ATAS should also be considered of higher risk of being covered by export control.
If your teaching is in an area of higher risk, or if you have other reasons to believe that the information to be shared is dual-use, you should first consider whether the exemptions apply (i.e. is the material to be shared already in the public domain? Or is it limited solely to basic scientific research). If either exemption applies to all the material, then no further due diligence is required. If any of the material is not covered by either exemption then you must consult the
Export Control Organisation’s Goods Checker Tool and the
UK Strategic Export Control Lists to see whether any of the information that you intend to share with students based overseas is listed as controlled. You may seek advice from the contacts at the end of this guidance.
If you confirm that your teaching material includes controlled technology please consider whether the inclusion of that material in remote teaching is necessary to the course. If it is not, you are advised to remove the material from any remote teaching.
Should removing such material be impossible, then a licence application will be needed. To apply for a licence please complete an
Export Control Enquiry Form and submit this to one of the contacts below. For further information see the University’s Export Control webpage.
In addition, anyone running a course, either undergraduate or postgraduate who becomes aware, is informed or comes to suspect that the material they are sharing through the course will be used for a WMD purpose should seek advice from the contacts below.
Further Guidance: