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POI/CWR Policy Update: Sept. 1

 

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Our Compliance team recently announced an upcoming adjustment to our process for both Persons of Interest (POI) and Contingent Work Relationships (CWR). Individuals identified as POI and CWR are not employees of UT Southwestern but maintain a working relationship with our organization (e.g., contract workers, third-party vendors, etc.).

Beginning Sept. 1, 2025:

Additional information required

All new POI and CWR requests must be submitted using PeopleSoft and will require additional information, including:

  • Company affiliation (if applicable)
  • Business purpose for the POI/CWR relationship
  • DOB, address, personal email address, and phone number of POI/CWRs

Requests will go through a multistep review process

All POI/CWR requests will be reviewed by Compliance, Research Security, and HR to verify information accuracy, ensure compliance, and strengthen institutional safeguards:

  • Verifying all information is accurate
  • Ensuring contractual, legal, and regulatory requirements are met prior to granting access
  • Strengthening institutional safeguards related to research security, data integrity, and workforce safety

Approval timeline

Please submit requests early to avoid delays and allow up to one week for review and approval. 

New access controls

  • Inactivity termination: POI/CWR accounts with no logins or facility access for 60 consecutive days will be automatically terminated.
  • International access: Accounts attempting to access UTSW systems from outside the U.S. will be immediately terminated unless international access has been preapproved and the request complies with export control and information security policies.

Note: For POIs/CWRs currently working outside the U.S., sponsors must complete the POI/CWR International Request Form prior to Sept. 1.

If you have any questions, please visit our POI/CWR SharePoint Site or poi-cwrcompliance@utsouthwestern.edu our Compliance team.

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