Guidance regarding international travel with MIT data and materials
August 5, 2020
Although all international MIT travel remains suspended due to the Covid-19 pandemic, we are writing regarding recent reports that Customs and Border Protection (CBP) officials are questioning individuals at U.S. airports about research data on electronic devices and/or research materials in carry-on or checked luggage. We are writing to:
- Remind all members of the MIT community of their obligations when traveling with MIT data or materials.
- Recommend a format for documenting evidence of your travel authorization to present to CBP, if requested.
- Share links to MIT resources to help ensure your international travel is safe and without interruption.
You should always discuss your plans on international travel with your MIT principal investigator before traveling abroad with MIT data. You and the principal investigator must discuss appropriate protocols, including information security protections for certain data. You and the principal investigator must consult MIT’s Travel Abroad Checklist and specifically the information provided by IS&T on securing your computer and its data. It is also prudent to secure your own personal data and any other data unrelated to your MIT position. You and the principal investigator must also ensure compliance with any commitments you may have made to third parties regarding data confidentiality and use.
In addition, you should not bring MIT research materials or specialized equipment (i.e., other than laptops and personal electronic devices) with you while traveling internationally unless in exceptional circumstances. Instead, such materials should be shipped through third-party carriers to ensure proper compliance with environment, health and safety regulations, export control clearances, and other procedures. On those rare occasions, when traveling with hand-carried research materials or specialized equipment is required for your work, you must have authorization from your principal investigator and the MIT export control office.
Once your international travel with MIT data or materials is appropriately authorized, you should obtain written documentation to present to Customs and Border Patrol officials, if requested, to minimize the chances of travel disruption. We suggest that this be in the form of a letter on institutional letterhead from your principal investigator (or if you are the principal investigator, your department head or supervisor). The letter should describe with specificity: the data and materials being carried; the purpose for traveling with these items (e.g., to continue thesis or article writing or to attend a joint research meeting with a specific collaborator); the dates and destination of your travel; and contact information for the person issuing the letter.
If any of your devices or materials are appropriated by government officials during transit, you should immediately inform your principal investigator and department head, who should then contact MIT’s Office of the General Counsel for further guidance.
As a reminder, in addition to the above guidance, if you are permanently leaving your lab, you must also comply with your lab’s existing off-boarding procedures, including returning data, materials, and equipment and the submission of any required documentation.
Maria T. Zuber
Vice President for Research
Richard K. Lester