Manuel B. Garcia

Manuel B. Garcia serves as the Senior Director for Educational Technology and Digital Learning at FEU Institute of Technology, Manila, Philippines. Read More

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Can One Collaborating Institution Prohibit an AI Tool That Another Institution Allows?

Research collaborators may face conflicting institutional AI rules when one university permits a tool that another restricts. Learn how to identify which policies apply, distinguish tool approval from data-processing authorization, resolve conflicts, and establish a defensible collaborative research workflow.

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Conflicting Institutional AI Policies in Research Guide 1001 of 1196
01 · The Question

Can One University Prevent Collaborators From Using an AI Tool Approved by Another University?

Researchers from two universities are collaborating on a study involving faculty interviews, survey responses, and unpublished institutional records.

University A provides its researchers with an approved generative AI service for research assistance. University B prohibits external AI processing of confidential research information unless a specific authorization has been obtained.

A researcher from University A proposes uploading the shared interview transcripts to the approved AI system for preliminary thematic analysis.

The collaborator from University B objects, explaining that their institution's research data agreement restricts such processing.

The first researcher argues that the tool has already been approved by their university. The second maintains that approval by one institution cannot override restrictions governing the shared dataset.

Both researchers may be correctly describing their own institutional arrangements, yet the proposed activity remains unresolved.

The central question is whether one collaborating institution can prohibit an AI tool that another institution allows, and how researchers should determine which restrictions govern shared research activities.

02 · The Short Answer

Can Institutional AI Restrictions Apply Across a Collaboration?

In Brief

Yes. One institution may impose restrictions on its researchers, systems, or research information even when another collaborating institution permits the same AI tool. Whether those restrictions govern the entire collaboration depends on the applicable institutional policies, research ethics approvals, data-sharing agreements, contractual obligations, and legal requirements.

Approval by one university does not automatically authorize every collaborator to process shared data through that tool. Researchers should identify the scope and authority of each requirement and establish a workflow that satisfies all applicable obligations before transferring restricted information.

03 · What You Need to Know

Resolving Institutional AI Policy Conflicts in Collaborative Research

Why Different Universities May Have Different AI Rules

Universities may adopt different AI policies because they operate under different institutional risk assessments, contractual arrangements, information-security capabilities, and research governance structures.

One institution may provide an enterprise AI environment with specific contractual protections. Another may restrict external AI processing until its information-security office completes an assessment.

These differences do not necessarily indicate that one institution understands AI better than another.

They may reflect different obligations, resources, and acceptable processing arrangements.

Research collaborators should therefore examine the substance of each policy rather than treat institutional disagreement as evidence that one rule must be unreasonable.

Permission to Use an AI Tool Is Not Universal Authorization

Institutional approval can have a limited scope.

A university may approve an AI system for public literature exploration, programming assistance, or administrative writing while prohibiting the upload of identifiable participant records.

Approval may also apply only to particular accounts, departments, or technical configurations.

For example, an institutionally managed AI service may operate under contractual terms that do not apply to a collaborator's personal account with the same provider.

Researchers should distinguish access to the tool from authorization to process particular information.

The relevant question is not merely whether the university allows the product, but whether the proposed research activity is permitted under the actual arrangement.

Which Institution's Policy Applies?

There is no universal rule that the lead institution's policy automatically overrides every other requirement.

The applicable obligations depend on who is conducting the activity, which institution controls the information, where processing occurs, and what agreements govern the research.

For example, University B may impose restrictions on data collected under its research ethics approval.

Those restrictions may remain relevant even when University A provides the technical infrastructure.

Conversely, University A may establish rules governing its own researchers and institutional systems that University B's collaborators must respect when accessing them.

Researchers should identify the authority and scope of each obligation rather than assume that institutional rank, project leadership, or technological ownership determines the answer.

Different Institutional Rules May Govern Different Activities

Requirement Potential scope Research implication
Institutional AI policy Staff, students, approved tools, and permitted activities May restrict particular AI uses
Research ethics approval Approved procedures and participant information May limit data processing or require amendments
Data-sharing agreement Access, transfers, permitted uses, and recipient obligations May restrict external AI processing
Information-security policy Systems, accounts, access, and data classifications May require an approved processing environment
Funder agreement Funded activities and contractual responsibilities May impose additional conditions
Applicable data-protection law Processing activities within its legal scope May require safeguards or impose restrictions
Journal policy Manuscript preparation, submission, and publication May establish disclosure or other AI requirements

Several requirements may apply simultaneously. The team should establish whether the proposed workflow satisfies each relevant obligation.

Why the Lead Institution Does Not Automatically Have the Final Say

A principal investigator may coordinate a project, but project leadership does not necessarily confer authority to override another institution's contractual or research ethics obligations.

For example, the lead university may host the shared dataset while a partner institution retains obligations concerning the participant information it contributed.

The research agreement may specify which organization is responsible for particular processing decisions.

Where responsibilities are unclear, the relevant institutional authorities should clarify them.

The team's governance arrangement should reflect actual legal and institutional responsibilities rather than informal assumptions about who leads the study.

Why Data Ownership Alone May Not Resolve the Conflict

Researchers sometimes assume that the institution owning a dataset can authorize any subsequent processing.

However, ownership, custodianship, contractual control, and personal data protection are distinct concepts.

A university may possess research records while remaining subject to participant consent, confidentiality obligations, or applicable privacy law.

Similarly, a collaborating institution may have access rights without unrestricted authority to transfer the information elsewhere.

The team should examine the actual data governance arrangement rather than rely exclusively on a general claim of ownership.

Can a University Prohibit AI Use by Researchers at Another Institution?

An institution ordinarily governs its own personnel and systems through its internal policies.

However, its restrictions may also affect external collaborators through contracts, data-sharing agreements, access conditions, or research protocols.

For example, University B may require that information it supplies be processed only through approved systems.

University A's researchers may need to comply with that condition when using University B's information, even if their own institution generally permits a wider range of AI tools.

Whether such a restriction is enforceable depends on the actual agreement and applicable law.

Researchers should not assume that an internal university policy automatically has unlimited extraterritorial authority.

Why the Strictest Policy Is Not Always the Complete Answer

Research teams may attempt to resolve disagreement by adopting whichever policy appears most restrictive.

This can be a useful precaution, but it is not a complete method for determining compliance.

For example, one institution may prohibit external data transfers while another requires specified retention and audit procedures.

Neither requirement can necessarily be reduced to a simple ranking of strictness.

The team must determine whether the proposed workflow satisfies all applicable obligations.

Where requirements are incompatible, researchers may need an alternative arrangement or formal institutional clarification.

How Should Researchers Evaluate the Actual AI Tool?

The assessment should examine the service configuration and processing arrangement rather than the product name alone.

Relevant considerations may include data retention, provider access, subprocessors, processing locations, access controls, and contractual protections.

Some services provide different conditions for institutional and personal accounts.

Consequently, approval of one configuration should not automatically be extended to another.

The related question of managing AI tools with different privacy policies requires examining actual provider terms and the information being processed.

What If the Shared Data Include Research Participants?

Participant information may be governed by approved research procedures, consent arrangements, confidentiality commitments, and data-protection requirements.

Introducing an external AI service may create a new processing arrangement.

For example, a research ethics approval may authorize interview analysis by named researchers using institutional systems without expressly addressing external AI processing.

Whether additional authorization is necessary depends on the approved protocol and institutional procedures.

Researchers should consult the relevant research ethics authority before implementing a material change.

Approval from another university does not automatically modify the original research ethics conditions.

Can Researchers Avoid the Conflict by Removing Identifiers?

Removing direct identifiers may reduce some confidentiality risks.

However, participants may remain identifiable through contextual details, combinations of characteristics, or unusual experiences.

Some data-sharing agreements also restrict processing of information that is not directly identifiable.

Researchers should therefore assess whether de-identification is sufficient for the particular purpose and processing environment.

It should not be treated as automatic authorization for a previously prohibited activity.

What If the Institutions Are in Different Countries?

International collaboration may introduce additional legal and contractual requirements.

For example, the European Union's General Data Protection Regulation establishes requirements concerning personal data processing and international transfers when it applies.

In the Philippines, Republic Act No. 10173 establishes a framework for personal information protection.

The applicability of these laws depends on the organizations, information, and processing activities involved.

Researchers should avoid assuming that one country's rules automatically govern every aspect of a multinational project.

Appropriate institutional or legal guidance may be necessary to establish the permitted data flows.

What Alternatives Are Available When an AI Tool Is Prohibited?

A restriction on one tool does not necessarily prohibit every form of AI-assisted research.

Depending on the applicable requirements, the team may use an approved institutional environment, perform certain tasks without AI, or restrict AI assistance to public and nonconfidential information.

For example, researchers might use synthetic data to explore general analytical code while processing the actual confidential dataset through authorized software.

However, synthetic data should be constructed and handled appropriately, particularly when derived from sensitive records.

Alternative arrangements must satisfy the same governing obligations as the original proposal.

Should Collaborators Standardize on One Approved Tool?

Using a shared authorized environment may simplify governance and documentation.

However, standardization is not always necessary.

Researchers may use different tools for public literature exploration, programming, and nonconfidential language editing while reserving restricted data processing for approved systems.

The appropriate arrangement depends on the research tasks and applicable requirements.

The objective should be authorized and accountable processing rather than uniform software use for its own sake.

What If a Collaborator Already Used the Prohibited Tool?

The team should establish what information was processed, which service received it, and which requirements may have been affected.

If restricted data were transferred without authorization, the responsible institution's information-security or research ethics incident procedures may apply.

Relevant authorities may need to assess containment, provider contact, notification, or other corrective measures.

Deleting a conversation does not necessarily establish that all processed information has been removed.

The team should avoid concealing the incident or assuming that the absence of immediate harm eliminates reporting obligations.

How Should the Conflict Be Documented?

The team should preserve an accurate record of the applicable requirements, proposed AI activity, institutional clarification, and final decision.

For example, a decision record may identify that external AI processing of interview transcripts was not authorized and that an approved alternative was selected.

Documentation should be proportionate and should not unnecessarily reproduce confidential research information.

It may be incorporated into the project's data-management plan or research team AI-use agreement.

Material changes should be communicated before collaborators implement the revised workflow.

Who Should Resolve the Disagreement?

The principal investigator may coordinate discussions, but the relevant institutional authorities should resolve questions within their respective responsibilities.

These may include research ethics committees, information-security offices, data-protection personnel, research governance offices, or legal advisers.

For example, an information-security office may assess a technical processing environment, while a research ethics committee determines whether a proposed procedure is consistent with the approved protocol.

The precise allocation of authority depends on institutional arrangements.

Researchers should not rely on an AI-generated interpretation of institutional rules as the final decision.

Why Institutional Restrictions Should Be Reviewed Over Time

AI tools, provider agreements, institutional policies, and research activities may change.

A tool prohibited for confidential data processing at one point may later become available through an approved institutional arrangement.

Conversely, changes to a service or project may introduce new restrictions.

Researchers should review the applicable conditions before materially changing the workflow.

However, later authorization does not automatically make earlier unauthorized processing compliant.

Institutional requirements should be evaluated according to the conditions applicable when the activity occurred.

What Is the Research Integrity Implication?

The European Code of Conduct for Research Integrity emphasizes reliability, honesty, respect, and accountability.

These principles support accurate representation of research procedures and responsible handling of confidential information.

However, institutional policy conflicts should not automatically be characterized as misconduct.

A disagreement may arise from legitimate differences in governance arrangements or uncertainty about authority.

The appropriate response is to clarify obligations, protect the research, and follow applicable procedures.

Research integrity requires more than selecting a technically capable AI system. It also requires using that system within the conditions governing the research.

04 · A Practical Example

Resolving an AI Tool Conflict Between Two Collaborating Universities

Hypothetical Example

A Joint Study of Faculty Experiences With Generative AI

Researchers from University A and University B conduct confidential faculty interviews.

University A provides an approved AI service for selected research tasks. University B's research agreement prohibits external AI processing of its participant information without specific authorization.

The team wants to use AI for preliminary thematic analysis of the combined transcripts.

1. Identify the proposed activity

The team establishes that identifiable interview material would be submitted to an external AI processing environment.

2. Review governing requirements

Collaborators examine institutional AI policies, the approved research protocol, and the data-sharing agreement.

3. Clarify the scope of approval

University A confirms that its tool approval does not independently override restrictions attached to information supplied by University B.

4. Consult authorized offices

The team seeks guidance from the relevant research ethics and data-governance authorities.

5. Select an authorized workflow

Until appropriate authorization is established, the team avoids uploading the restricted transcripts and uses permitted analytical procedures.

6. Document the decision

The collaborators record the applicable restrictions, authorized processing arrangements, and responsibilities.

7. Review future changes

Any proposed introduction of a new AI environment is assessed before restricted data are transferred.

The example illustrates why institutional approval should be evaluated in relation to the specific information and research activity.

Neither institution's general position on AI automatically resolves every obligation governing the collaboration.

05 · What Researchers Often Get Wrong

Misconceptions About Conflicting Institutional AI Policies

Misconception

The Lead University Always Determines Which AI Rules Apply

Project leadership does not automatically override obligations established through other institutions, research ethics approvals, or data-sharing agreements.

Misconception

If One University Approves a Tool, All Collaborators May Use It

Approval may be limited to specific accounts, purposes, personnel, or data categories. Other applicable restrictions remain relevant.

Misconception

The Institution Owning the Dataset Can Authorize Any Processing

Ownership does not automatically eliminate confidentiality, participant consent, contractual, or data-protection obligations.

Misconception

The Strictest-Looking Policy Always Resolves the Conflict

Different requirements may govern different aspects of processing. The workflow should satisfy all applicable obligations rather than rely on a superficial ranking.

Misconception

Removing Names Automatically Makes Prohibited Processing Acceptable

Re-identification risks and separate contractual restrictions may remain. De-identification does not replace authorization.

Misconception

Conflicting AI Policies Mean Collaboration Is Impossible

Researchers may be able to establish approved environments, limit processing, or use alternative methods while satisfying the governing requirements.

Misconception

Later Tool Approval Automatically Resolves Earlier Unauthorized Use

Compliance should be assessed against the requirements applicable when the processing occurred. Subsequent approval does not necessarily resolve an earlier incident.

06 · What This Means for You

How to Resolve Institutional AI Policy Conflicts

Researchers should identify the actual obligations governing a proposed AI activity before deciding which processing arrangement is permissible.

The process should be evidence-based and coordinated through appropriate institutional authority.

A simple decision framework

If institutions have different general AI policies
Identify which requirements apply to the researchers, systems, and information involved.
If one institution approves a tool but another restricts shared data processing
Do not assume tool approval overrides the data restriction; seek authoritative clarification.
If the proposed processing affects an approved research protocol
Consult the responsible research ethics authority before implementing the change.
If the requirements cannot be satisfied through the proposed tool
Use an authorized alternative or avoid the restricted processing.
If unauthorized processing may already have occurred
Follow the applicable institutional incident-response procedures promptly.

Identify the Relevant Authority

Determine which institutions, agreements, and research approvals govern the proposed activity.

Do not assume that project leadership alone determines compliance.

Examine the Actual Processing Arrangement

Review the tool configuration, account conditions, information category, and intended use.

Distinguish general access permission from authorization for restricted data.

Seek Written Clarification Where Necessary

Consult the appropriate institutional offices and preserve the resulting decision.

Clarification should address the specific research workflow rather than AI use in the abstract.

Adopt a Compliant Alternative

Where the proposed system cannot be authorized, consider approved environments or methods that do not require the restricted transfer.

Review the Arrangement as the Project Develops

Reassess permissions when new data, AI tools, institutional agreements, or processing purposes are introduced.

07 · A Quick Checklist

Have You Resolved the Institutional AI Policy Conflict?

Before using AI across collaborating institutions, check:
Have we identified the AI policies of all relevant institutions?
Do we understand which researchers, systems, and activities each policy governs?
Have research ethics approvals and data-sharing agreements been reviewed?
Is the proposed AI system authorized for the specific information category and task?
Have relevant contractual and legal obligations been considered?
Have conflicting requirements been referred to the appropriate institutional authorities?
Is there an authorized alternative if the proposed processing is restricted?
Has the final processing decision been documented and communicated?
Are procedures established for reviewing changes or responding to unauthorized processing?
08 · Frequently Asked Questions

Common Questions About Institutional AI Policy Conflicts

Can one university prohibit an AI tool that another university allows?

Yes. Institutions may impose restrictions on their researchers, systems, or information. Whether those restrictions affect the broader collaboration depends on applicable agreements and other governing requirements.

Which university's AI policy takes priority in a joint study?

There is no universal priority rule. Researchers should identify the authority and scope of each applicable requirement and establish a workflow consistent with those obligations.

Can the principal investigator override a collaborating institution's AI restriction?

Not automatically. Project leadership does not necessarily override institutional, contractual, or research ethics requirements.

Does institutional approval of ChatGPT or another AI tool authorize processing all research data?

No. Approval may be limited to particular accounts, data categories, and processing purposes. The specific research activity must be assessed.

Can researchers use an approved AI tool with de-identified data?

Potentially, but de-identification does not automatically eliminate confidentiality obligations or re-identification risks. Applicable authorization remains necessary.

What if the collaborating institutions cannot agree?

Researchers should seek clarification from the responsible governance offices and consider alternative workflows. Restricted processing should not proceed without the required authorization.

Can institutional AI policies change during a research project?

Yes. Teams should review material changes and determine how they affect future processing. Later authorization does not automatically resolve earlier noncompliance.

Does a disagreement over AI policy constitute research misconduct?

Not automatically. A policy disagreement is different from a formal misconduct finding. Actual violations must be evaluated under applicable definitions and procedures.

09 · The Bottom Line

Institutional AI Approval Does Not Override Every Collaborator's Obligations

The Bottom Line

One collaborating institution may restrict AI activities that another institution permits, particularly when shared research information is governed by separate contractual, ethical, or legal obligations. Researchers should determine which requirements apply and establish authorized processing arrangements before using AI with restricted data.

Institutional differences need not prevent collaboration, but they require careful coordination. The defensible approach is to clarify authority, document the permitted workflow, and avoid treating one university's general AI approval as permission for every researcher or dataset.

10 · Sources and Further Reading

Research Governance, Data Protection, and Institutional AI Risk Guidance

11 · Cite this Guide

How to Cite This Guide

This guide is intended to be read, shared, and used in research, teaching, and academic work. If you draw on its ideas, explanations, or other content, please acknowledge the source by citing the guide. Doing so gives appropriate credit and helps your readers locate the original resource.

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