Policy overview
1 Purpose
To set out the principles which guide the University's compliance with Australian national security laws and mitigating risks of Foreign Interference at the University.
2 Scope
This policy applies to all University Members and Students who engage in any interactions with Foreign Entities. These interactions may involve certain risks or legal obligations related to issues like Foreign Interference, Foreign Influence, Foreign Arrangements, and compliance with the Defence Industry Security Program (DISP), as well as Autonomous Sanctions and Export Controls.
This policy should be read in conjunction with the University's National Security Procedure, Sanctions and Export Controls Procedure, Enterprise Risk Management Policy, and Enterprise Risk Management Procedure.
3 Policy Statement
The University is committed to proactively managing the threat of Foreign Interference to help safeguard the University, protect Academic Freedom, demonstrate compliance and understanding of national security interests, maintain confidence and support of partnerships, and ensure the University can maximise the benefits of education and Research endeavours.
The University is committed to maintaining legislative compliance with Australian national security laws, including but not limited to:
- National Security Legislation Amendment (Espionage and Foreign Interference) Act 2018
- Foreign Influence Transparency Scheme Act 2018
- Australia's Foreign Relations (State and Territory Arrangements) Act 2020
- Autonomous Sanctions Act 2011
- Defence Trade Controls Act 2012.
The University Foreign Interference Taskforce (UFIT) Guidelines on Countering Foreign Interference in the Australian University Sector provide additional regulatory guidance for the University sector.
4 Principles
The University will assess and manage potential risks and legislative compliance obligations associated with its Foreign Interactions by:
- Providing a reporting framework.
- Raising awareness and identifying potential risks of Foreign Interference amongst University Members and Students and the types of activities that should be reported. For example, through educational programs, training, and awareness activities.
- Conducting due diligence, proportionate to the risk of the activity, when engaging in partnerships and other arrangements with a Foreign Entity.
- Ensuring all arrangements with Foreign Entities are robust and address potential risks.
- Identifying Research that may require additional due diligence or oversight due to the nature of the Research or partnership.
- Implementing cyber security strategies that understand and proportionately mitigate the cyber business risks.
4.1 Reporting
The University has established the following resources to ensure compliance with its statutory reporting obligations under the Foreign Influence Transparency Scheme Act 2018, Australia's Foreign Relations (State and Territory Arrangements) Act 2020 (Cth), Autonomous Sanctions Act 2011 (Cth), and Defence Trade Controls Act 2012 (Cth).
- Foreign Arrangement Scheme Management framework;
- Sanctions Compliance Form;
- Foreign Influence Register;
- Foreign Interactions in Research Due Diligence Checklist;
- Foreign Interactions Due Diligence Form.
The associated processes are outlined in the National Security Procedure and Sanctions and Export Controls Procedure as applicable.
5 References
Australian Cyber Security Centre
Australian Security Intelligence Organisation (ASIO)
Counter Foreign Interference Coordination Centre
6 Schedules
This policy must be read in conjunction with its subordinate schedules as provided in the table below.
7 Policy Information
| Accountable Officer | Vice-Chancellor |
| Responsible Officer | Deputy Vice-Chancellor (Enterprise Services) |
| Policy Type | Governance Policy |
| Policy Suite | |
| Subordinate Schedules | |
| Approved Date | 13/2/2025 |
| Effective Date | 2/12/2024 |
| Review Date | 2/12/2029 |
| Relevant Legislation | Australia's Foreign Relations (State and Territory Arrangements) Act 2020 Autonomous Sanctions Regulations 2011 Charter of the United Nations Act 1945 (Cth) Charter of the United Nations (Dealing with Assets) Regulations 2008 Defence and Strategic Goods List 2021 Defence Trade Controls Act 2012 Foreign Influence Transparency Scheme Act 2018 National Security Legislation Amendment (Espionage and Foreign Interference) Act 2018 Weapons of Mass Destruction (Prevention of Proliferation) Act 1995 |
| Policy Exceptions | |
| Related Policies | Corrupt Conduct Reporting Policy Enterprise Risk Management Policy |
| Related Procedures | |
| Related forms, publications and websites | Attorney-General's Department - Foreign Influence Transparency Scheme Public Register Australian Security Intelligence Organisation- Counter Espionage and Foreign Interference Australian Security Intelligence Organisation- Think Before You Link Countering Foreign Interference (UniSQ SharePoint page) Department of Home Affairs - Countering Foreign Interference |
| Definitions | Terms defined in the Definitions Dictionary |
| Academic Freedom comprises: the freedom of Employees, in the course of their academic activities, to educate, discuss, or research and to disseminate and publish the results of those activities; the freedom of Employees and Students, in the course of their academic activities, to engage in intellectual inquiry, to express their opinions and beliefs, and to contribute to public deba...moreAcademic Freedom comprises: the freedom of Employees, in the course of their academic activities, to educate, discuss, or research and to disseminate and publish the results of those activities; the freedom of Employees and Students, in the course of their academic activities, to engage in intellectual inquiry, to express their opinions and beliefs, and to contribute to public debate, in relation to those activities; the freedom of Employees and Students to express their opinions in relation to the University; the freedom of Employees, without constraint imposed by reason of their employment by the University, to make lawful public comment on any issue in their personal capacities; the freedom of Employees to participate in or speak on behalf of professional or representative bodies and associations; the freedom of Students to participate in or speak on behalf of student societies and associations; and the autonomy of the University in relation to the choice of Academic Programs and Courses, the ways in which they are taught and the choices of research activities and the ways in which they are conducted. Public comment is not made in a personal capacity where: the comment includes a reference, express or implied, to the University; or the Employee identifies their employment or any affiliation with the University, refers to their position in the University. Sanctions as defined in the Autonomous Sanctions Act 2011 , the Defence Trade Controls Act 2012 , the United Nations Act 1945 or the Weapons of Mass Destruction (Prevention of Proliferation) Act 1995 and any other sanctions from time to time in force in accordance with the laws of the Commonwealth of Australia....moreSanctions as defined in the Autonomous Sanctions Act 2011 , the Defence Trade Controls Act 2012 , the United Nations Act 1945 or the Weapons of Mass Destruction (Prevention of Proliferation) Act 1995 and any other sanctions from time to time in force in accordance with the laws of the Commonwealth of Australia. Defence Industry Security Program (DISP) The Defence Industry Security Program (DISP), managed by the Defence Industry Security Office (DISO), supports Australian businesses to understand and meet their security obligations when engaging in Defence projects, contracts and tenders. It is essentially security vetting for Australian businesses....moreThe Defence Industry Security Program (DISP), managed by the Defence Industry Security Office (DISO), supports Australian businesses to understand and meet their security obligations when engaging in Defence projects, contracts and tenders. It is essentially security vetting for Australian businesses. A person employed by the University and whose conditions of employment are covered by the Enterprise Agreement and includes persons employed on a continuing, fixed term or casual basis. Employees also include senior Employees whose conditions of employment are covered by a written agreement or contract with the University....moreA person employed by the University and whose conditions of employment are covered by the Enterprise Agreement and includes persons employed on a continuing, fixed term or casual basis. Employees also include senior Employees whose conditions of employment are covered by a written agreement or contract with the University. Export Controls refers to the control of the supply, export, publication or brokering of military and dual-use goods and technology. Australia's Export Controls include the physical export of controlled goods and technology from Australia; the intangible transfer (e.g., emails) of controlled technology from Australia to overseas; the publishing of controlled military technology; and th...moreExport Controls refers to the control of the supply, export, publication or brokering of military and dual-use goods and technology. Australia's Export Controls include the physical export of controlled goods and technology from Australia; the intangible transfer (e.g., emails) of controlled technology from Australia to overseas; the publishing of controlled military technology; and the brokering of controlled military goods and technology. It also includes 'catch all' (or 'end-use') controls. In the context of Foreign Interference, Foreign Actors include persons of any nationality, including Australian, acting on behalf of a non-Australian....moreIn the context of Foreign Interference, Foreign Actors include persons of any nationality, including Australian, acting on behalf of a non-Australian. Foreign arrangements are written arrangements, agreements, contracts, understanding or undertakings between the Australian State and Territory entities and foreign entities. They may be legally binding or not legally binding. A Foreign Arrangement is an arrangement between: a) a State/Territory entity; and b) a Foreign Entity; whether or not other entities are also a party to the arr...moreForeign arrangements are written arrangements, agreements, contracts, understanding or undertakings between the Australian State and Territory entities and foreign entities. They may be legally binding or not legally binding. A Foreign Arrangement is an arrangement between: a) a State/Territory entity; and b) a Foreign Entity; whether or not other entities are also a party to the arrangement. Foreign Entity includes a foreign country, its national government and a department or agency of that national government, as well as sub-national level governments in foreign countries, departments of those sub-national level governments, public entities established under the authority of a foreign country or its national or sub-national government, universities without institutional ...moreForeign Entity includes a foreign country, its national government and a department or agency of that national government, as well as sub-national level governments in foreign countries, departments of those sub-national level governments, public entities established under the authority of a foreign country or its national or sub-national government, universities without institutional autonomy and any other entities prescribed by the rules. A Foreign Government includes a foreign national or sub-national government (including a department, agency or other public authority of that government)....moreA Foreign Government includes a foreign national or sub-national government (including a department, agency or other public authority of that government). All governments, including Australia's, try to influence deliberations on issues of importance to them. These activities, when conducted in an open and transparent manner, are a normal aspect of international relations and diplomacy and can contribute positively to public debate....moreAll governments, including Australia's, try to influence deliberations on issues of importance to them. These activities, when conducted in an open and transparent manner, are a normal aspect of international relations and diplomacy and can contribute positively to public debate. Foreign Interaction refers to any interaction between an Australian State and Territory entity and a foreign entity, which may or may not lead to a Foreign Arrangement....moreForeign Interaction refers to any interaction between an Australian State and Territory entity and a foreign entity, which may or may not lead to a Foreign Arrangement. Foreign Interference occurs when activities are carried out by, or on behalf of a Foreign Actor, which are coercive, clandestine, deceptive or corrupting and are contrary to Australia's sovereignty, values and national interests....moreForeign Interference occurs when activities are carried out by, or on behalf of a Foreign Actor, which are coercive, clandestine, deceptive or corrupting and are contrary to Australia's sovereignty, values and national interests. Research is the creation of new knowledge and/or the use of existing knowledge in a new and creative way to generate new concepts, methodologies, inventions and understandings. This could include the synthesis and analysis of previous research to the extent that it is new and creative....moreResearch is the creation of new knowledge and/or the use of existing knowledge in a new and creative way to generate new concepts, methodologies, inventions and understandings. This could include the synthesis and analysis of previous research to the extent that it is new and creative. A person who is enrolled in a UniSQ Upskill Course or who is admitted to an Award Program or Non-Award Program offered by the University and is: currently enrolled in one or more Courses or study units; or not currently enrolled but is on an approved Leave of Absence or whose admission has not been cancelled....moreA person who is enrolled in a UniSQ Upskill Course or who is admitted to an Award Program or Non-Award Program offered by the University and is: currently enrolled in one or more Courses or study units; or not currently enrolled but is on an approved Leave of Absence or whose admission has not been cancelled. The term 'University' or 'UniSQ' means the University of Southern Queensland....moreThe term 'University' or 'UniSQ' means the University of Southern Queensland. Persons who include: Employees of the University whose conditions of employment are covered by the UniSQ Enterprise Agreement whether full time or fractional, continuing, fixed-term or casual, including senior Employees whose conditions of employment are covered by a written agreement or contract with the University; members of the University Council and University Committees; visiti...morePersons who include: Employees of the University whose conditions of employment are covered by the UniSQ Enterprise Agreement whether full time or fractional, continuing, fixed-term or casual, including senior Employees whose conditions of employment are covered by a written agreement or contract with the University; members of the University Council and University Committees; visiting, honorary and adjunct appointees; volunteers who contribute to University activities or who act on behalf of the University; and individuals who are granted access to University facilities or who are engaged in providing services to the University, such as contractors or consultants, where applicable. | |
| Definitions that relate to this policy only | |
| Keywords | Foreign, International, Overseas, Collaboration, Partnership, Research, Arrangement, Interference, Influence, Defence, Australia, Country, Sovereign, Risk, Threat, Counter, Terrorism, Autonomous |
| Record No | 19/1279PL |