Impact on teaching
Export Control survey
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Export Controls can impact on teaching in three principle ways:
1. Academic Technology Approval Scheme (ATAS) clearance
This applies to all non-exempt nationals subject to UK immigration controls seeking to study or undertake research in the UK in some STEM or MINT subjects, including certain MSci/MEng undergraduate courses, postgraduate degrees including doctorates (PhD, DPhil, EngD etc.).
2. Controlled items
Some teaching, especially remote classes and virtual events, can involve the transfer of controlled technology or software overseas and thus require an export licence.
3. End-use concerns
If there is knowledge or suspicion that a student or member of staff intends to misuse course contents for military or WMD purposes, the tutor must immediately suspend teaching and contact the Research Office for advice.
Academic Technology Approval Scheme (ATAS)
ATAS is operated by the Foreign, Commonwealth & Development Office (FCDO). The scheme aims to prevent the spread of materials and information that could be used in the proliferation of WMD and their means of delivery. Similar schemes are operated by other governments worldwide.
ATAS is designed to ensure that students and researchers who are subject to UK immigration control and who are applying to study or research in certain STEM or MINT subjects in the UK do not have existing links to WMD programmes. Such students and researchers must apply for an ATAS certificate prior to entry to the UK and commencement of their course or research. It is the responsibility of the student or researcher to apply for ATAS clearance. For further information, please see the ATAS pages on the College Registry’s website.
At present, students and researchers who are nationals (including dual nationals) of any of the following countries are exempt from ATAS requirements:
- Countries within the European Economic Area (EEA)
- New Zealand
- South Korea
ATAS clearance for an individual does not remove any requirement to apply for an export licence where items (goods, software, or technology) are controlled and an export is taking place, or where there are end-use concerns.
Normally, undergraduate teaching is outside the scope of export controls because:
- it generally does not involve goods, software, or technology that are controlled;
- the taught content is usually already in the public domain; and
- teaching often disseminates 'basic scientific research' which is exempt from export controls.
However, some undergraduate courses might be covered by export controls if they contain controlled software or technology (know-how and other information) or go beyond 'basic scientific research'. Please see the Do I need an export licence? pages to determine if your course contents are controlled, and see the Exemptions page to check if your course content might constitute 'basic scientific research'.
Export controls apply at the postgraduate and doctoral levels more frequently because they often go beyond 'basic scientific research'. Any exports of controlled goods, software, technology or information from the UK might require an export licence. In the context of teaching, this is likely to apply most commonly to remote classes or virtual events involving overseas participants. Please see the Do I need an export licence? pages to find out whether your course or event requires a licence.
Export controls can also apply to the transfer of materials and information within the UK. When a tutor or other member of staff has been informed, is aware, or has any reason to suspect that a student or staff member intends to use course contents for WMD purposes, they must suspend teaching immediately and contact the Research Office for further advice.
Exemptions from export controls for 'basic scientific research' and content 'in the public domain' do not apply when there are WMD End-use concerns.
To prevent the proliferation of knowledge that can be used in WMD and missile development, carefully consider how information communicated in your course could be misused. See our page on End-use concerns.
Examples of End-use Controls on teaching
- End-use controls would apply if a tutor became aware, through specific evidence, that one of their students intended to make use of their studies for a WMD programme, regardless of the student’s nationality.
- End-use controls would apply if a researcher became aware that their international partners intended to use joint findings for a WMD programme.
- End-use controls on transfers within the UK are not triggered simply due to a student being from a country of proliferation concern.
- End-use controls are not triggered simply because the subject of research had some utility for WMD development, e.g., chemical weapon precursors.