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particularly striking example of the pitfalls entailed in formulating policies of such wide breadth and vague scope, it is elsewhere provided that "members of the University community may not undertake activities on behalf of an intelligence organization which in any way extend beyond or are inconsistent with their normal University activities." The above restriction seems to us to be especially noteworthy in three respects: 1) as previously noted, it singlés out for special and more stringent standards intelligence organizations; 2) the words "extend beyond" seem to effectively preclude any privately pursued outside activity on behalf of CIA, no matter how innocuous, and including open as well as confidential relationships; and 3) since it specifically applies to conduct which extends beyond or is inconsistent with University-related activities, the restriction, if read literally, has the anomalous and presumably unintended effect of tacitly allowing activities on behalf of an intelligence organization which flow from and relate to an individual's "normal" University activities.

Although our disagreement with these and certain other aspects of the University of Pennsylvania's proposed policies arc clearly significant, we need not belabor these differences at this time. CIA appreciates the fact that the draft statement recognizes and makes a sincere effort to deal with the difficult and complex problem of maintaining a balance between the intellectual independence of academe on the one hand and the needs of the nation and the rights of individuals on the other. We believe that reasonable people may honestly disagree on whether any type of assistance made by a member of the U.S. academic community to an intelligence organization is advisable or proper. In the final analysis, however, it seems to us that the ultimate decision must be left to the individual to make.

Again, we thank you for your consideration in allowing us the opportunity. to offer comments on your draft statement.

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The information in your letter of December 1, 1977 concerning your public disclosure of Subproject 130 of Project MKULTRA and its connection with Columbia University was most helpful to us and I thank you for it. While protection of the identities of institutions notified of MKULTRA activities rakes lit.le sense ir. circumstances where the institutions themselves have publicly acknowledged their involvement, we shall continue to protect, to the utmost of our ability, the identities of all individuals associated with this work. Consequently, please advise Professor Thetford that we do not intend to make any disclosures with respect to him personally.

We have examined the information you have furnished concerning the research activities you have described as relating to human behavior and funded through various medical research foundations and which you suspect were secretly sponsored by CIA. As I stated in my earlier letter to you, the recollections and records available to you apparently are more complete than ours and we have no evidence that CIA was involved in any of these activities, except of course for Subproject 130 which is listed first in your compilation. As to the remaining activities, given the generalized nature of the research as you have described it, it must be remembered that each of the funding mechanisms utilized by the Agency for Project MKULTRA also had something of an independent life. For the purpose of strengthening their credibility as sources of research funds, and because they received many private donations for medical research, these organizations provided support to many legitimate research activities having no connection whatever to MKULTRA or CIA. Also, as you may know, the Geschickter Fund for Medical Research, Inc., continues to be an independent source of funds for medical research. Thus, apart from the deficiencies which I described to you previously concerring our remaining records as to MKULTRA, it is not unreasonable to suggest that these activities might not, in fact, have been funded by CIA.

Another possible explanation which has developed as a result of your information concerning the nature of the additional research, at least as toel a research activities noted in your table as items two, three and four. is provided by reference to Subproject 77 of MKULTRA. This activity, the record of which includes no reference whatsoever to Columbia University, was conducted in conjunction with another private organization during the period between approximately 1957 and 1962. An estimated $110,000 was expended through one of the research foundations in this subproject to explore the basic elements of two personality theories in order to develop a unified theory. Because of the correspondence in both time and subject matter it may be that the work at Columbia was somehow related to this larger project::

Be that as it may, let me once again assure you that, to the best of our knowledge and information based upon records available here at the Agency there is no evidence of research grants, other than that connected with Subproject 130, made to Columbia University by CIA without the knowledge of the University. In addition to the three research studies you described in your letter, there appears to have been a classified contract in 1967-69 which I prefer not to describe in this letter; however, this activity and CIA support of it were not matters of which University officials were unaware or disapproving. As I stated in my previous correspondence to you, Executive Order 11905 and current regulations now require that all classified and unclassified contracts and other similar arrangements between CIA and U.S. institutions of higher learning must be made known to senior management officials at the institution.

Your letter expressed a conclusion, which you asked me to correct if it was mistaken, that CIA does not have "current secret contractual arrangements with any member of the faculty of Columbia University for research or any other personal or professional service." That is not a conclusion that I am prepared to either affirm or deny. CIA enters into personal service contracts and other continuing relationships with individuals in many walks of life, including academics. As a matter of Agency policy, all such individuals are made aware that they are dealing with CIA, so that under no circumstances do we seek or obtain services or assistance from such individuals on an unwitting basis. On occasion security considerations preclude the disclosure of these relationships. More frequently, however, these relationships remain confidential at the insistence of the individuals themselves, their concerns being that they might otherwise be exposed to harassment or other adverse consequences. In the case of academic staff and faculty, as in other cases, we see no reason and feel no responsibility to overrule these individual preferences by requiring that relationships be disclosed to the institutions. Rather we believe that the decision as to disclosure should be left to the discretion of the individuals involved. If I were to affirm or deny

your conclusion with respect to Columbia University faculty, I could hardly follow a different course in relation to similar requests that I might receive from other universities. I would then have set in motion a sequence of events that would result in a breach of trust with those who had chosen, as I think was their right, to deal with us in confidence, and I am unwilling to accept that result.

Your persistence is, of course, understandable and I am not unsympathetic to your efforts to acquire a full and complete statement of this Agency's retation ships with Columbia.. We have attempted to be as forthcoming as possible in connection with MKULTRA because of our recognition of the likelihood that his tutions such as your own would be extremely vulnerable in the face of adverse publieity. without prior knowledge of the underlying facts. We have shared with you all. such facts within our possession, but we cannot share the other information you requested without seriously compromising our own interests or the interests of persons to whom we owe obligations of confidence.

Yours sincerely,

/s/ Stansfield Turner

STANSFIELD TURNER

APPENDIX IX

UNIVERSITY OF CALIFORNIA

THE ACADEMIC SENATE

July 28, 1978

Senator Walter D. Huddleston

United States Senate Select Committee on Intelligence
Washington, D. C. 20510

Dear Senator Huddleston:

On behalf of the University of California Committee on Academic Freedom, I wish to thank you for the invitation and opportunity to address the U.S. Senate Select Committee on Intelligence last Thursday (July 20, 1978) on the subject of S. 2525.

We are all gratified by the sensitivity of the Senate Committee to the problems of the academic community. In turn, we appreciate the difficulties you must be having in balancing the legitimate needs of intelligence-gathering agencies with the requirements for intellectual honesty among academicians.

We recognize that S. 2525 may not include as much protection for the academic community as we should desire. Insofar as you may find it impossible to endorse altogether our requirements that no member of the academic profession allow him/herself to be drawn into covert activities on behalf of intelligence agencies, academic institutions must be permitted to enforce their own standards of professional ethics, in defense of the essential activities of scientists, scholars, artists, and students. I share President Derek Bok's indignation over the CIA director's assertion that the CIA will not respect the Harvard Guidelines on faculty consultations with the CIA; but I can understand that the CIA is devoted to a task which, in its own terms, may appear to justify transgressions upon another institution's responsibilities. On the other hand, that merely requires that universities redouble their efforts to enforce their own standards of proper behavior. To these ends, I should like to repeat my plea that your committee add to S. 2525 a provision that guarantees the universities' power to discipline their own members in defense of their own standards of ethical or professional behavior.

There is danger, I believe, that various government agencies may single out for penalties any institution that applies sanctions against any of its members discovered to be violating professional obligations, specifically obligations

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