Parliamentary Committee Notes: Questions and Answers – Policy on Sensitive Technology Research and Affiliations of Concern

1. How was the NRO list formulated?

The NRO list was created to provide the long-time requested clarity and transparency to the research community to help them identify the risk associated with certain foreign partnerships.
The list aims to support the establishment of a strong and healthy research ecosystem by making it available to all parties in Canada.
Public Safety developed a set of indicators that were used to determine if a research organization is sufficiently connected to a hostile state security apparatus.
For an entity to appear on the list, we must have obtained some information that an organization has met some combination of the indicators we developed. We’ve also cross-referenced our Special Economic Measures list to ensure a uniform approach is being taken.
This list is meant to remain evergreen and we intend to update it regularly. We are aware that publishing a public list may cause our adversaries to divert their efforts to co-opt Canadian research to institutions that are not currently listed – Public Safety will be actively monitoring these efforts and will update the list in the future accordingly.

An example of one of our indicators is whether or not a public institution has stated publicly that they are conducting research at the behest of a foreign military or state security body.
We have several other indicators, however, we would like to keep them protected at this time as we do not wish for our adversaries to know our exact listing criteria.

As a result of the Russian invasion of Ukraine, we have seen virtually no collaborations between Canadian and Russian researchers on areas relating to sensitive technology. As a result, for the first draft of the list, we decided to focus our efforts elsewhere.

The Government has taken a country-agnostic approach to its overall policy on research security because we are aware that the threats to Canadian research can come from anywhere.
An outright ban on all research with institutions from any particular country would be counter-productive as there are several international collaborations on projects that could be mutually beneficial.

An early decision was taken to leave private sector entities off the list as we learn how the public listing of these institutions will impact our foreign relations.
We also have other tools that target partnerships with private sector entities of concern, namely the National Security Guidelines for Research Partnerships which specifically targets research collaboration with private sector companies.

The Government is taking a phased approach to the list. The first iteration has focused on the very highest risk research organizations that have been confirmed to have deep links with foreign state security apparatuses that pose a threat to Canada’s national security.
For subsequent iterations of the list, we will be looking to apply our listing criteria to other high-risk institutions and it is highly possible that those institutions could be part of a future update to the NRO list.

The US listing of the Wuhan Institute of Virology stemmed from an entirely separate issue than that which we are concerned with for the purposes of the Named Research Organizations List.
The Named Research Organizations List and the Policy on Sensitive Technology Research and Affiliations of Concern more broadly is meant to exist in a space where the exchange of information is unfettered – this applies to mostly academic collaborations.
In the case of the Wuhan Institute of Virology, because it operates several levels of biosafety laboratories, collaboration would be highly regulated by the Public Health Agency of Canada.

It is important to reiterate that this policy is not intended to target certain people, but will focus on problematic affiliations only. We wish for researchers who are affiliated with institutions on the NRO to cease collaboration with those institutions to remain eligible for federal funding.
This is why we have built in a grace period to allow researchers to end their problematic affiliations.
Much of Canada’s strength comes from its ability to attract talent from around the world – we wish to continue to be able to attract that talent. Punishing researchers for their past collaborations runs counter to that goal.

Canada, the US, and other likeminded allies are still in the earlier stages of building research security programs and we are all building off each other’s successes in this endeavor.
While the NRO list is 100% made in Canada, there is some alignment between the recently released US Department of Defense list which also uses listings from the US Bureau of Industry and Security’s export controls list.
Of the 103 institutions on the NRO list, 33 also appear on the US Bureau of Industry and Security entities list and 16 are also on the US Department of Defense list.

The Sensitive Technology Research Area list was adapted from work being done by the Government to develop a list of sensitive technologies. This effort was led by PS and involved 18 other federal departments and agencies.
This list has been vetted by both Government of Canada scientists as well as experts external to government to ensure that the technologies we have listed accurately represent the areas we wish to protect.
Technologies are listed where use by an adversary could either degrade Canadian or allied security or defence efforts or enhance an adversary’s security or defence efforts. The list does not include technologies that are already ubiquitous and widespread except where novel applications of those technologies are being explored.
The STRA will eventually be replaced by a more in-depth Sensitive Technology List which, like the NRO, will be an evergreen list that adapts to the ever-changing technological landscape.