16-2 International Travel
1.1 The University recognizes that foreign travel is an integral part of the University’s educational and research mission. At the same time, however, measures should be taken to minimize risks, and international travel must be done in compliance with federal requirements. The purpose of this policy is to promote safety and regulatory compliance for both the protection of the traveler and the University.
2.1 This policy applies to all University faculty, staff, and students traveling out of the United States on University business or, in the case of a student, in connection with a University-sponsored program. “University business” refers to any activity that is related to the employment duties of the faculty or staff member.
3.1 The following procedures shall be followed at a reasonable interval before travel begins.
3.1.1 The traveler shall complete the TravelWayne travel request before the trip. For more information, consult fisops.wayne.edu/travel/. It is strongly encouraged that the traveler provide emergency contact information in their TravelWayne profile.
3.1.2 If the traveler plans to take his or her own electronic device out of the country, s/he must review and follow instructions posted on the Export Control Office (“ECO”) website (research.wayne.edu/export-control/) on how to avoid a data security breach or system. Alternatively, the traveler may obtain from the University a loaner laptop computer or mobile device that has security measures already installed. All international travelers will be required to complete the “risk assessment form” found on the TravelWayne website. The form consists of a series of questions designed to determine if the proposed travel presents a risk of violation of federal export controls regulations or disclosure of confidential, proprietary, or personally identifiable information. If the risk assessment form instructs the traveler to contact the ECO, he or she shall promptly do so. Consultation with the ECO is likely to be required if the traveler is taking abroad any of the following:
- information that is protected under the Health Insurance Portability and Accountability Act (HIPAA) such as patient medical records and confidential human participant research data,
- education records or data,
- information that is subject to a confidentiality agreement,
- data or information that is subject to publication restrictions,
- data or information concerning the development, production or use of encryption technology, or
- military, space, defense, or nuclear-related items, including software and data.
3.1.3 Some countries are sanctioned or embargoed by the U.S. Department of State or other federal agencies. The ECO shall keep an up-to-date list of these countries. Anyone requesting travel to a sanctioned or embargoed country must coordinate with the ECO before traveling.
3.1.4 Whenever a traveler is required by this policy to contact the ECO, the ECO shall evaluate the risks of the requested travel and may develop and recommend measures to promote compliance (“Compliance Travel Plan”). The traveler shall cooperate with the ECO and shall adhere to the Compliance Travel Plan.
4.0 Travel/Warnings and Alerts
4.1 The U.S. Department of State issues Travel Warnings for certain areas of the world. A Travel Warning is issued when the risk of traveling to the area is sufficiently high that the traveler should strongly consider not going to the area at all. A Travel Alert is issued for short-term events that a traveler should know about before visiting the area.
4.2 Prior to departure, international travelers are encouraged to enroll in the U.S. State Department’s Smart Traveler Enrollment Program (“STEP”). The program provides the latest news and updates regarding foreign travel destinations (including Travel Alerts and Warnings), and makes it easier for U.S. consulates and embassies to contact travelers while abroad in the event of an emergency.
4.3 Travel Alerts and Warnings change quite often. The ECO will help the traveler to identify potential risks involving their proposed international travel.
5.1 Any traveler violating this policy shall not be reimbursed for the expenses of the travel. Notice of the violation shall be sent to (a) the Provost, if the alleged violator is a member of the faculty, academic staff, or a student, or (b) the appropriate vice president, if the alleged violator is a staff member in another division. Such officials may, in their discretion, take additional administrative actions against the traveler, including limitations on future travel.
5.2 The Vice President for Research may prohibit travel that presents a significant risk of violation of federal export control regulations or other legal or contractual obligations. The President or designee may prohibit travel that presents a significant risk to the health or safety of the traveler or other persons. Any individual who engages in travel prohibited by the President (or designee) or the Vice President for Research does so at his or her own risk.
6.1 This university policy is revocable by the President at any time and without notice.
7.0 Effective Date
7.1 This university policy is effective upon issuance.
Signed by President M. Roy Wilson July 26, 2016