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Open Access Publications from the University of California

UC Comments in Response to Notice of Proposed Rulemaking on Provisions Pertaining to Precenting Access to the U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons (Docket No. NSD 104)

Abstract

This comment letter responds the DOJ's proposed rule on provisions pertaining to preventing access to U.S. sensitive personal data and government-related data by countries of concern or covered persons. UC supports DOJ’s goal of protecting sensitive personal and government-related data, but urges the agency to avoid impairing academic research, especially by adding an exemption for covered data transactions in non-federally funded research. UC also endorses COGR’s recommendations for clearer definitions, more detailed compliance guidance, practical tools, and sufficient implementation time so universities can comply consistently without undermining global research collaboration.