STTR Research Data Policy
Effective Date: March 30, 2026 | Last Updated: March 30, 2026
This policy governs the collection, use, and protection of personal data for participants in Small Business Technology Transfer (STTR) research projects coordinated through DAKDAN Talent.
What is STTR?
The Small Business Technology Transfer (STTR) program is a federal initiative that funds collaborative R&D between small businesses and research institutions. DAKDAN Talent facilitates student/researcher placements in STTR-funded projects.
Data Collection & Use
Categories of Data Collected
Researcher/Student Data
- Name, contact information, academic credentials
- Research interests, technical expertise, publications
- University affiliation, department, advisor information
- Work authorization status (US Persons requirements)
- Security clearance (if applicable for DOD projects)
Project Data
- Grant proposal abstracts (public information)
- Research milestones and deliverables
- Collaboration agreements and NDAs
- Progress reports (de-identified for matching)
- Budget allocation (40/30 compliance tracking)
Purposes of Processing
Researcher Matching
Connect qualified researchers/students with STTR projects based on technical expertise and research interests
Compliance Tracking
Monitor 40/30 budget split requirements between university and small business partners
Grant Administration
Facilitate proposal submissions, budget planning, and reporting to federal agencies (DOD, NSF, NIH, etc.)
IP Management Support
Track invention disclosures and IP allocations per Bayh-Dole Act and project agreements
Outcome Reporting
Aggregate outcomes (publications, patents, commercialization) for federal reporting requirements
Security Clearances
Verify clearances for classified or export-controlled research (DOD, DOE projects)
Legal Basis for Processing
Federal Law & Regulation
- Bayh-Dole Act (35 U.S.C. § 200-212): IP and data retention requirements
- SBIR/STTR Policy Directive: Budget tracking and reporting mandates
- FAR/DFARS: Federal Acquisition Regulation for DOD contracts
- Export Control (ITAR/EAR): Restricted data for foreign nationals
Consent & Contract
- Explicit Consent: Researchers consent to data use for STTR matching
- Contract Performance: Processing necessary to fulfill grant administration services
- Legitimate Interest: Aggregate outcomes reporting for program improvement
Data Sharing & Disclosure
Who We Share With
Federal Agencies
De-identified aggregate data shared with granting agencies for program evaluation:
- • Department of Defense (DOD) - STTR Program Office
- • National Science Foundation (NSF)
- • National Institutes of Health (NIH)
- • Department of Energy (DOE)
- • NASA, USDA, EPA, and other participating agencies
Project Partners
Researcher contact info and CVs shared with small business partners and university principal investigators for matching. Requires signed NDA and collaboration agreement.
University Partners
Student placement data, progress reports, and IP disclosures shared with university tech transfer offices and sponsored research departments per institutional agreements.
What We Do NOT Share
- ✗Proprietary Research Data: Experimental results, formulas, trade secrets remain confidential per project NDAs
- ✗Personal Financial Data: Researcher salaries, stipends not shared externally
- ✗Classified Information: Security-cleared data handled in separate systems per NISPOM
- ✗Third-Party Marketing: No selling or renting of researcher lists to recruiters or vendors
Data Retention & Deletion
| Data Type | Retention Period | Legal Basis |
|---|---|---|
| Grant proposals & awards | 7 years after project completion | FAR 4.703, Bayh-Dole |
| IP disclosures & patents | Life of patent + 7 years | 35 U.S.C. § 202 |
| Researcher CVs & profiles | Active + 2 years inactive | Legitimate interest |
| Financial records | 7 years | IRS, FAR 4.705 |
| Export control documentation | 5 years | ITAR § 122.5, EAR § 762.6 |
| Aggregate outcomes data | Indefinite (de-identified) | Public interest research |
Early Deletion Requests
Researchers may request deletion of CVs and contact info at any time. However, grant-related records must be retained per federal law. We anonymize personal identifiers while retaining project data.
Security Measures
Data Protection
- AES-256 encryption for all STTR data at rest
- TLS 1.3 for data in transit
- Isolated database instances for federal projects
- Multi-factor authentication for all users
Access Controls
- Role-based access: project teams see only their data
- Background checks for staff handling sensitive data
- Annual ITAR/EAR compliance training
- Audit logging for all data access (7-year retention)
Your Privacy Rights
Researchers and students have the following rights regarding their STTR data:
Right to Access
Request a copy of your CV, project history, and IP disclosures
Right to Correction
Update your profile, qualifications, or contact information
Right to Deletion
Remove CV/contact info (grant records retained per law)
Right to Opt-Out
Stop receiving new STTR project matches
Right to Data Portability
Export your profile in machine-readable format
Right to Object
Object to specific data uses (e.g., outcomes reporting)
STTR Privacy Contacts
STTR Program Manager
sttr@dakdantalent.comData Protection Officer
dpo@dakdantalent.comExport Control Compliance
export-control@dakdantalent.comVersion: 1.0 | Effective Date: March 30, 2026 | Last Updated: March 30, 2026
Complies with: Bayh-Dole Act, FAR/DFARS, ITAR/EAR, GDPR, CCPA
Main Privacy Policy | Data Privacy Framework | Data Processing Agreement