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TikTok Research Policy

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TikTok Research Policy

Policy Number: 12007


Effective Date:
Sep 10, 2024

Last Updated:
Sep 10, 2024

Responsible Office:
Division of Information Technology

Responsible Administrator:
Vice President for Information Technology

Policy Contact:

Kate Stoan
Director, Research Security and Compliance
kstoan@umsystem.edu

Categories:

  • General Administration
  • Information Technology

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Prohibition on a TikTok (ByteDance) Covered Application

Scope

Applies to all University employees, including students in employment status, and recognized volunteers and all other appointments (paid or unpaid) who are performing services in connection with a federal contract acquiring goods or services, regardless of whether their role involves performing research or other services on a federal contract or supporting the negotiation and execution of a federal contract.  For example, application of the policy extends not only to individuals performing research or services called for by a federal contract, but also to individuals who provide supporting services (including but not limited to business, compliance, and research security services) for the negotiation or execution of federal contracts. Federal research grants, cooperative agreements, and other federal funding agreements will fall outside the scope of this policy unless they contain specific clauses similar to those addressed below.

Reason for Policy

The U.S. Department of Defense, General Services Administration, and National Aeronautics and Space Administration issued an interim rule implementing the No TikTok on Government Devices Act, applicable to any contract solicitations the agencies issue, The Federal Acquisition Regulatory Council determined that the presence or use of TikTok on covered IT poses "an unacceptable level of risk" to national security. The Federal Acquisition Regulation (FAR) has been amended to include a new contract clause, FAR 52.204-27, Prohibition on a ByteDance Covered Application, which will be included in federal contracts to implement the interim rule.

For federal contracts containing FAR 52.204-27, the interim rule prohibits government contractors and subcontractors, such as the University, from having or using the TikTok application (or any successor application or service provided by ByteDance Limited: 1) on any information technology (IT) equipment owned or managed by the Government, or on 2) IT equipment used or provided by a contractor under a government contract, whether the IT is owned by the contractor or by a contractor employee.

The University is a recipient of federal contracts and must comply with this prohibition when included in federal contracts.

Policy Statement

  1. With regard to any federal contract acquiring goods or services:
    1. The University prohibits the presence or use of the TikTok application (app), or any successor app developed or provided by ByteDance or a subsidiary, on IT equipment used in contract performance, including IT equipment owned by an employee which is used in performance of the contract.
    2. The University requires employees to ensure that the TikTok app or any successor app developed or provided by ByteDance or a subsidiary is not installed or is uninstalled:
      1. On any University-owned IT equipment used or provided by the University in performance of a federal contract;
      2. On any IT equipment leased or otherwise acquired by the University that is used or provided by the University in performance of a federal contract; and
      3. On any personally owned IT equipment used in performance of a federal contract.  This includes, but is not limited to, personally owned cell phones or tablets used in performance of a federal contract. 
    3. Under this policy, IT equipment is considered to be used in the performance of a federal contract if it is used in performing research or services called for by a federal contract or providing supporting services (including but not limited to business, compliance, and research security services) for the negotiation or execution of the contract.  For example, this includes, but is not limited to, an individual’s personally owned cell phone that is used to re