Policies and Procedures

All Virginia Tech employees and students are subject to U.S. export and sanctions regulations. The physical export outside the United States of university commodities, software, or technology is subject to control under U.S. export control laws and regulations. In most cases, university employees may take common items, software, and technology subject to the Export Administration Regulations (EAR) outside of the United States under a “No License Required (NLR)” declaration, provided the items are not exported to comprehensively sanctioned jurisdictions, including Cuba, Iran, North Korea, Syria, or embargoed regions such as Crimea, Donetsk, and Luhansk.

• The Office of Export and Secure Research Compliance (OESRC) DOES NOT require notification for the temporary export to a non-sanctioned country of commercially available laptops, tablets, and/or cell phones with standard commercially available software because no license is required.
• For export of ANY OTHER types of university commodities, software, or technology, please contact oesrc@vt.edu prior to your travel to ensure no export license is required. 
• Published information, fundamental research, open source software, and other information in the public domain are not subject to these regulations and may be discussed and shared freely.  We recommend that you do not export confidential/proprietary technical data, as it may be subject to export control and may require an export license or other government approval.  
• OESRC offers services such as loaner laptops and restricted party screening, as well as travel tips/best practices available on OESRC’s international travel page.
• Please be aware that a number of universities have reported installation of malicious software in employee computers when left unattended in foreign countries. If you have reason to believe the computer you take with you (whether your workstation or the OESRC-loaner) has been compromised, please contact OESRC immediately upon your return and prior to connecting the computer to any university networks. 
• Contact: oesrc@vt.edu or 231-6642 for any questions or concerns.

• The Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (20 USC § 1092(f)) requires U.S. colleges and universities that participate in Title IV federal student financial aid programs to disclose information about crime on and around their campuses, or in non-campus facilities (e.g., hotel, rented spaces) as described by the Act.
• The “Clery Act” is named in memory of Jeanne Ann Clery, a university freshman who was raped and murdered in her campus residence hall in 1986.
• A major intention of the Clery Act is to provide accurate and timely safety information to the public, parents, and students about the level of crimes, student alcohol incidents, and drug violations that occur on a campus. This means making all incident data readily available in a complete and accurate manner for all parties who inquire at your institution, thus enabling them to make an informed decision about their safety.
  
• Failure to comply with the policy requirements can result in substantial fines for an institution (in the tens of thousands of dollars) or in an extreme case, in the loss of all participation in Title IV federal financial aid programs.

• Before Departure
  • Program leaders must provide the Global Education Office with the full address(es) of all lodging locations. GEO will provide to the Clery Coordinator.
  • Virginia Tech’s Clery Compliance Coordinator will use the information to follow up with local authorities regarding crime reporting statistics.
• While Abroad
  • In your capacity as a Campus Security Authority (CSA), you must report to the VTPD any crime that is directly reported to you as soon as possible.
  • Provide as much detail as possible to assist law enforcement in addressing and categorizing the crime, including the exact physical address of the offense (e.g., inside hotel, outside hotel, 3rd floor hallway, etc.). Your report should include personal identifying information if available to avoid double-counting crimes. If the victim does not want the report to go any further than the CSA, the CSA should explain that he or she is required to submit the report, but it can be submitted without identifying the victim.
  • Let the victim know about resources available to them, regardless of whether they want the incident investigated or not. However, in an emergency situation, the CSA should contact the VTPD or 911 as appropriate.
  • CSAs are not responsible for investigating or reporting incidents that they overhear or learn about in an indirect manner.

• Program leaders (credit and non-credit) should complete and upload the Clery Act Reporting Spreadsheet to their program’s SharePoint Health and Safety Folder at least 30 days before program departure. 
• The VT Global Safety office will provide the Clery lodging spreadsheets to the Clery Office on an annual basis, in January.
• For access or if you have questions, please email VTGlobalSafety@vt.edu.