University Policy 100
International Travel and International Visitors
Initially Approved: August 25, 2008 
Revised:  November 12, 2012 

Policy Topic:  Governance & Administration
Administering Office: Provost's Office

I. POLICY STATEMENT

Western Carolina University (WCU) is committed to the development of excellent international educational opportunities for its students, and collaborative international instructional/research opportunities for faculty. Additionally, WCU is becoming increasingly involved in regional economic development initiatives that have global impact. It is WCU’s policy to encourage and facilitate these international activities while at the same time ensuring compliance with various federal laws pertaining to export controls, state regulations and university procedures regarding public health/pandemics, and the Institute of International Education “open door” reporting requirements.

II. DEFINITIONS

“University Owned Equipment” is any university-owned Laptops, PDAs (including tablet devices), cell phones, or digital storage devices.

“Controlled Goods” includes, among other things, biological samples, research data, microcomputers, microprocessors, microcircuits, digital computers, encryption or proprietary software, telecommunication/transmission equipment, lasers, and laser sensors.

“Controlled Technical Information” includes, among other things, information required for the design, development, repair, testing or maintenance of controlled goods.

“Confidential University Data” includes, but is not limited to, student or employee Social Security numbers; credit card numbers or other financial information; protected health information; or student education records protected by Family Educational Rights and Privacy Act (“FERPA”).

III. PROCEDURES

1. WCU Student International Travel Procedures

A. Required Trip Approvals. All university sponsored and/or faculty-led international trips with students must be approved in writing by the Provost or his/her designee. This requirement applies to all International Programs and Services study abroad programs, all Educational Outreach summer programs, all Service Learning Programs, and any other faculty-led trip or program, irrespective of the award of university credit for student participation.

B. Required Documentation/Information. Faculty and departments planning international trips under this section must submit their request for approval to the Provost’s Office on the attached “International Travel Approval Form” (PDF), or similar form routinely utilized by International Programs and Services and approved programs such as the Jamaica Program. Travelers are encouraged to submit the required documentation at least three (3) months prior to the trip; however, the Provost’s office may consider other requests for good cause. The following information must be provided in any request:

·   The names of all WCU employees traveling with the students, including individuals from other universities or organizations;

·   Student identifying information, including name, gender, age, course/program, major, financial aid information, emergency contact information, and travel, accident, and international health insurance information, including medical evacuation and repatriation of remains;

·   Travel dates;

·   Travel destinations;

·   Travel itinerary, including foreign contacts;

·   Name of travel agent or host institution and contact information for the travel agent and international student advisor at the host institution; and

·   University-owned equipment, technologies, and technical or confidential data to be taken on the trip by students or faculty leaders

C. Approval Process. The Provost is ultimately responsible for approving all WCU international travel and has the authority to deny international travel requests for public health and/or safety purposes, federal export regulatory purposes, or other legitimate business purposes.

D. Administrative Matters. The Provost’s office is responsible for coordinating with International Programs and Services to ensure compliance with safety, risk management, and liability requirements for the proposed travel, to coordinate with the Student and Exchange Visitor Information System (SEVIS), and the Institute of International Education “open door” reporting requirements.

The Provost’s office will coordinate with the Graduate School and Research Administration with regard to export control management plan administration. The Provost’s office shall determine, prior to approving international travel, whether (1) the planned international travel involves sanctioned or embargoed countries or individuals; and (2) WCU employees are transferring controlled technologies/technical data to foreign nationals without appropriate licenses, license exemptions or regulatory exclusions.

The Provost’s office will coordinate with the university Pandemic Flu Coordinator to determine, prior to approving international travel, whether the World Health Organization and/or the Centers for Disease Control and Prevention have issued any travel notices in effect for the international travel destination(s).

The Provost’s Office will coordinate with the Controller’s Office to verify, in advance of the planned visit, that all fiscal requirements are met with regard to any necessary payments.

The Provost’s office is responsible for creating and maintaining such records as may be necessary to implement this Policy.

The Provost may delegate any of the administrative responsibilities set forth in this Policy to others having a direct reporting relationship to the Provost.

2. WCU Employee International Travel Procedures

A. Required Travel Approvals. All university business related international travel (unrelated to student group travel) must be approved in writing by the Provost or his/her designee.

B. Required Documentation/Information. Faculty and staff planning international trips under this section must submit their request for approval to the Provost’s Office on the attached “International Travel Approval Form” (PDF). Travelers are encouraged to submit the required documentation at least three (3) months prior to the trip; however, the Provost’s office may consider other requests for good cause. The following information must be provided in the request:

·   The names of all WCU employees traveling, including individuals from other U.S. universities or organizations and family members;

·   Travel dates;

·   Travel destinations;

·   Travel itinerary, including names of foreign contacts and contact information;

·   Name of travel agent or host institution and contact information for the travel agent or host institution; and
University-owned equipment, technologies, and technical or confidential data to be taken on the trip.

C. Approval Process. The Provost is ultimately responsible for approving all WCU international travel and has the authority to deny international travel requests for public health and/or safety purposes, federal export regulatory purposes, or other legitimate business purposes.

D. Administrative Matters. The Provost’s office is responsible for administering this Policy as described in Section 1.D above.

3. International Scholars/Others Visiting the WCU Campus

A. Required Approvals. Faculty and staff who intend to invite international scholars/others to visit the WCU campus must obtain the Provost’s approval, in writing, at least three (3) months in advance of the visit. The Provost’s office may consider other requests for good cause.

B. Required Documentation/Information. Faculty and staff planning visits under this section must submit their request for approval to the Provost’s Office on the attached “International Visitor Approval Form” (Word). The following information must be provided in the request:

·   The name and department of the WCU faculty/staff member extending the invitation, and the purpose of the visit;

·   Visitor name and home country;

·   Copy of visitor’s vita/resume;

·   Date of arrival/departure;

·   Type of visa on which the visitor is traveling (some visas do not permit payments to the visitor);

·   Destinations/departments and facilities to be visited (especially science and engineering labs);

·   Plans to provide university housing, office space, support, and services if required; and
University-owned equipment and technologies to be visited, and technical data to be shared

C. Approval Process. The Provost is ultimately responsible for approving all international travel to and from the university, and has the authority to deny international travel/visit requests for public health and/or safety purposes, other legitimate business purposes or state or federal regulatory purposes.

The Provost’s office will coordinate with the Graduate School and Research Administration with regard to export control management plan administration. The Provost’s office shall determine, in advance of the planned visit, whether (1) the international visitor is a sanctioned or embargoed individual; and (2) the international visitor will viewing or have access to controlled technologies/technical data.

The Provost’s office will coordinate with the university Pandemic Flu Coordinator to determine, in advance of the planned visit, whether the World Health Organization and/or the Centers for Disease Control and Prevention have issued any travel notices pertaining to the international visitor’s home country as well as any intermediate destinations prior to arrival in the U.S.

The Provost’s Office will coordinate with the Controller’s Office to verify, in advance of the planned visit, that all fiscal requirements are met with regard to payment of visiting scholars.

The Provost’s office is responsible for creating and maintaining such records as may be necessary to implement this Policy.

The Provost may delegate any of the administrative responsibilities set forth in this Policy to others having a direct reporting relationship to the Provost.

4. International and Exchange Students Visiting the WCU Campus

All international and exchange students/trainees who intend to pursue a course of study at WCU must submit an international student application to the office of International Programs and Services, and meet all requirements to obtain appropriate visa documents. Each academic year, International Programs and Services will provide to the Provost’s office, and update as necessary, documentation that includes the student’s name, country of residence, visa type (F or J), contact information, and course of study. International Programs and Services will coordinate with the Pandemic Flu Coordinator and the Graduate School and Research Administration regarding public health and safety concerns and export and deemed export control concerns.

5. General Information

A. Export Controls: Controlled Technology and Technical Data. Federal regulations prohibit the “export” of certain technology and information. It is imperative that international travelers disclose to the Provost’s office whether they intend to take University Owned Equipment, Controlled Goods, and/or Controlled Technical Information.   The Provost’s office will consult with the Graduate School and Research Administration regarding export control matters and the administration of the university’s export control plan.

Under federal law, U.S. individuals and companies are restricted or prohibited from exporting or providing services of any kind to any party contained in U.S. government export denial, debarment, and blocked persons lists. Accordingly, International Programs and Services shall perform or cause to be performed a Visual Compliance restricted party screening application for all potential parties to university export transactions. Specific screening will be performed as follows:

·   For international and exchange students: Visual Compliance screening prior to arrival in the U.S., and screening repeated every 3 months thereafter;

·   For international scholars and faculty authorized to teach, study, research or work at the university under J or H Visas: Visual Compliance screening prior to arrival in the U.S.;

·   For other international guests (e.g., parents of international and exchange students): Visual Compliance screening prior to arrival in the U.S.;

·   For all foreign contacts listed in Section 1.B and 2.B: Visual Compliance screening prior to arrival in foreign country.

When exporting commodities from the U.S., or releasing technology or source code to a foreign national in the U.S., under U.S. law it is the responsibility of the exporter to classify the items to determine if export licenses are required from any U.S. government agency. Graduate School and Research Administration shall perform a Visual Compliance Export Control Classification Number (ECCN) analysis to evaluate U.S. Department of Commerce export-licensing jurisdiction.

B.  University Owned Equipment.  The export of both tangible items such as University Owned Equipment and software, including but not limited to commercial software and encryption code which is installed on or otherwise executed by University Owned Equipment is subject to export control regulations.  The Export Administration Regulations (EAR), however, make an exception to license requirements for the temporary export or re-export of certain tangible items or software for professional use as long as specific criteria are met. 

Prior to traveling abroad with University Owned Equipment, the individual is required to complete a Temporary Export License Exemption form to certify that they are eligible for the exemption and will comply with the required criteria.  If the individual traveling abroad is unable to adhere to the exemption requirements, they should contact the Office of Research Administration to discuss alternative options for international travel with technology.

C. University Confidential Data. University employees traveling abroad must ensure that they do not travel with documents or computing devices (including laptop computers, BlackBerrys/Smart phones, PDAs, and removable memory devices/thumb drives) that contain Confidential University Data.

D. Registration with U.S. Embassies. All individuals traveling abroad are encouraged to register your travel plans with the State Department through a free online service at https://travelregistration.state.gov .

IV. POLICY REVIEW

This policy shall be reviewed and revised as necessary every two (2) years by the Office of the Provost.

V. RELATED POLICIES AND RESOURCES

UNC Policy Manual: http://www.northcarolina.edu/policy/index.php

University Policies

Academic Procedures and Regulations

Faculty Handbook 

One-Time Certification

 

 

 

 

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