Procedures for Reviewing Noncompliance with the Research Security Program

These procedures support Policy I.A.6 (“Policy”). Refer to the policy for contact information and applicable definitions.

Effective Date: October 1, 2026

I. Introduction

A. Pursuant to its assigned Responsibilities in the Policy, Research Security and Export Controls (RSEC) addresses concerns regarding a Purdue Associate’s failure to comply with the Policy and Purdue’s related research security program requirements.

B. These procedures apply to all Purdue Associates.

C. These Procedures do not limit the University from any precautionary, compliance, remedial, or mitigating action or consultation with law enforcement or regulators at any time (including during the pendency of any investigative process under these Procedures) in furtherance of the Policy and the RSEC mission.

II. Authority and Responsibilities

A. Chief Research Security Officer (CRSO): The individual designated by the President to serve in this role.

1. Reviews appeals and determines whether to uphold or overturn a noncompliance finding, a recommendation of Mitigation, and/or a recommendation for Disciplinary Action.
2. In the absence of the Research Security Officer, may execute any of the Research Security Officer’s responsibilities.
3. Refers a finding of noncompliance with the Policy to university leadership for institutional response.

B. Research Security Officer (RSO): The individual designated by the CRSO to serve in this role.

1. Directs preliminary inquiries and investigations.
2. Determines whether a formal investigation will be initiated.
3. Reviews investigative reports and recommendations.
4. Issues written findings regarding noncompliance investigations.
5. Directs corrective, remedial, or mitigating actions relating to a Policy objective.
6. Supervises the Research Security Investigator.
7. Ensures investigations are conducted fairly, thoroughly, and in a timely manner.
8. In the absence of the Research Security Investigator, may execute any of the RSI’s responsibilities.

C. Research Security Investigator (RSI): The individual designated by the RSO to serve in this role.

1. Gathers and reviews relevant information.
2. Conducts interviews.
3. Prepares inquiry summaries and investigative reports with findings and recommendations.
4. Performs other duties assigned by the RSO.

III. Definitions

Day: Calendar day.

Disciplinary Action: An employment, academic, appointment, or other personnel consequence imposed in response to substantiated misconduct, noncompliance, or other conduct warranting discipline under applicable university policy. Disciplinary action is determined and imposed by the university official or body with appropriate authority and is distinct from Mitigation measures taken by RSEC to address identified risk.

Mitigation: Measures taken to reduce, manage, correct, or prevent research security, compliance, operational, financial, reputational, or other institutional risk identified during or as a result of a research security review or research security investigation. Mitigation may include corrective, protective, or risk-reduction measures and is not, by itself, disciplinary in nature.

IV. Initial Inquiry

A. Upon receipt of information about a compliance concern within the scope of the Policy, the Research Security Officer (RSO) will designate a Research Security Investigator (RSI) to conduct the Initial Inquiry. The RSI will review the concern and gather additional information, as necessary. The Initial Inquiry may involve consultation with the Purdue Associate, involved dean, associate dean, department head, and others, as appropriate. The RSI may authorize requests for information from other university departments or officials, including formal preservation requests. All such requests will comply with university policies and procedures.

B. Within 30 Days of receipt of the compliance concern, the RSI will provide the RSO a written summary of the Initial Inquiry, including a recommendation as to whether a Formal Investigation is warranted. The RSO may, upon written request, approve an extension of time to complete the Initial Inquiry when warranted by the circumstances.

C. Within seven (7) Days of the RSI’s written recommendation, the RSO will make a finding as follows:

1. There is insufficient evidence of noncompliance with the Policy by a Purdue Associate and no cause for Mitigation. RSEC will document the Inquiry and the basis for the finding. RSEC may notify the parties involved in the Initial Inquiry.
2. There is sufficient evidence of noncompliance with the Policy by a Purdue Associate that can be fully addressed through Mitigation. In such cases, the RSO is responsible for identifying appropriate Mitigation and ensuring compliance with all such Mitigation. In such cases, the RSI will meet with the Purdue Associate to discuss the RSO’s findings and recommended Mitigation.
   
   If the recommended Mitigation is within the scope of RSEC’s responsibility, the RSO may authorize and direct RSEC staff to implement the RSO’s recommended Mitigation. Where the recommended Mitigation requires action from another unit of the University, the RSO will make a referral to or involve that unit. When appropriate, the CRSO and/or RSO will ensure that the department head and dean are apprised of the Mitigation. In the event Mitigation measures are attempted, but the Purdue Associate does not cooperate, the matter may be escalated to a Formal Investigation.
3. There is sufficient evidence that, if substantiated, the violation of the Policy by a Purdue Associate cannot be fully addressed through Mitigation alone. In such cases, the RSO will authorize a Formal Investigation, and the CRSO and/or RSO will notify other university officials, as appropriate. The officials may also be involved in making the determination that the investigation is warranted.

V. Formal Investigation

A. The RSO will notify the Purdue Associate of the determination to proceed to a Formal Investigation. The RSO may also notify the department head, dean, or others, as appropriate.

B. The notice must include:

1. The basis for the Formal Investigation, including the allegations and Initial Inquiry determination;
2. The individual appointed to serve as the RSI for the Formal Investigation;
3. The timeframe when the Purdue Associate will be expected to meet with the RSI to provide response to the allegations; and
4. A clear statement of consequences should the Purdue Associate fail to cooperate or disrupt the Formal Investigation.

C. The RSI will conduct the Formal Investigation, which will include a review of all information the RSI deems necessary to complete a comprehensive investigation. The Purdue Associate is expected to comply with requests for information from the RSI. The Formal Investigation may involve consultation with the involved dean or associate deans of the college, department head and others, as appropriate. The RSI will also consult with the RSO and legal counsel about review steps when appropriate.

D. The Formal Investigation will be completed within 60 Days of the Formal Investigation notice. The RSO may, upon written request, approve an extension of time to complete the Initial Inquiry when warranted by the circumstances.

VI. Investigation Report

A. Upon conclusion of the Formal Investigation, the RSI will draft a report that compiles and describes (1) the cause for the Investigation, including reported or suspected noncompliance by a Purdue Associate, (2) the factual information gathered in the Investigation, and (3) any other evidence or materials relevant to the report. The RSI’s Investigation Report includes the RSI’s recommendation as to whether, based on a preponderance of the evidence, a violation of the Policy occurred, and, if so, any recommendations on appropriate Mitigation.

B. The Purdue Associate will be provided the opportunity to inspect the Investigation Report and meet with the RSI to discuss it.

C. Within five (5) Days of that meeting, the Purdue Associate may submit a written response to the Investigation Report. A brief extension may be granted at the discretion of the RSO.

D. The RSI will provide the Investigation Report to the RSO with a copy to the involved dean and department head.

VII. Determination and Recommendation

A. Within seven (7) Days of receiving the Investigation Report and response, if submitted, the RSO will provide the Purdue Associate a written determination. The RSO may consult with any university office in making the determination. The written determination includes:

1. Whether the Purdue Associate violated the Policy;
2. What Mitigation measures are required, and which Mitigation measures must be implemented prior to an Appeal; and
3. A recommendation on whether Disciplinary Action is appropriate.

B. Mitigation measures are not subject to appeal and may be implemented prior to any Appeal (or determination) if the RSO determines that immediate Mitigation is necessary. All other Mitigation measures will be implemented upon conclusion of the Appeal process, if any. If the recommended Mitigation is within the scope of RSEC’s responsibility, the RSO may authorize and direct RSEC staff to implement the RSO’s recommended Mitigation. Where Mitigation requires action from another unit of the University, the RSO will make a referral to or involve that unit. When appropriate, the CRSO and/or RSO will ensure that the department head and dean are apprised of required Mitigation.

C. The RSO will also provide the final report and written determination to the CRSO, who is responsible for determining whether to refer the Purdue Associate for Disciplinary Action (see Section IX, below).

VIII. Appeal

A. The Purdue Associate may appeal the RSO’s determination, except for Mitigation, on the following grounds:

1. There was a significant deviation from these Procedures that materially impacted the outcome; or
2. There is insufficient evidence to support the RSO’s finding of a violation of the Policy.

B. To appeal the RSO’s Determination, the Purdue Associate must submit a written appeal, with any supporting materials, within 10 Days of the date of the Determination. The written appeal must clearly outline the basis for the Appeal.

C. The RSO will provide the Purdue Associate with access to the Investigation Report during the Appeal period.

D. Within a reasonable period of time following receipt of the Appeal, generally not to exceed 15 Days, the CRSO will provide the Purdue Associate and the RSO with a written determination on the Appeal. The CRSO’s determination may uphold, reverse, or modify the RSO’s determination that the Purdue Associate violated the Policy. The CRSO has wide latitude to request information from the RSO or RSI and may consult with any university office or individual in making a decision on the appeal.

E. The determination of the CRSO on the Appeal is final.

IX. Referral for Disciplinary Action

A. Upon the conclusion of the Appeal process, or if no Appeal is timely received, the CRSO will determine whether to refer the matter for Disciplinary Action to the Provost and the Executive Vice President for Research, or their respective designees. In making this determination, the CRSO will carefully consider all available information, including the Investigation Report, the Purdue Associate’s written response, and the RSO’s Determination. Factors the CRSO may consider when making this determination include, but are not limited to, the seriousness of the underlying conduct, whether the Policy violation was intentional, prior documented concerns related to the Purdue Associate, the potential impacts to the University arising from the violation, and the RSO’s recommendation. The CRSO will provide the Provost and the Executive Vice President for Research, or designees, with the final Investigation Report, RSO written determination, and CRSO determination on Appeal, if any, to assist them in determining Disciplinary Action.

B. Any Disciplinary Action arising out of a finding that a Purdue Associate violated the Policy must be imposed by the Provost and the Executive Vice President for Research, or their respective designees. Any such Disciplinary Action is subject to the policy on Faculty Grievances (I.B.1) or Dispute Resolution (VI.D.1), as applicable to the Purdue Associate’s affiliation with the University; however, the underlying Determinations by the RSO and, in the case of an Appeal, the CRSO are not subject to the Faculty Grievances or Dispute Resolution policies.