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[The following article is a reprint from the Counterintelligence News and Developments, Volume 1, March 2000.]
Introduction
As more U.S. contractors are expanding from their traditional roles in the U.S. government arena into commercial ventures, they are increasing their contacts with foreign entities. These contacts take the form of joint ventures, joint research, hiring foreign national employees, and hosting foreign visitors. In addition, international inspections associated with agreements such as the chemical weapons treaty and the international standards protocols can expose companies to visits by foreign technology experts. By expanding their contacts with foreign entities, U.S. government contractors are increasing their vulnerability to the potential loss of classified, proprietary, and export-controlted information. The implementation of a technology control plan can significantly mitigate this increased vulnerability.
Technology Control Plan
A technology control plan (TCP) stipulates how a company will control its technology. The plan establishes procedures to protect classified, proprietary, and export-controlled information; to control access by foreign visitors; and to control access by employees who are non-U.S. persons. A TCP is a type of security countermeasure frequently overlooked by companies in the rush to secure business in the international marketplace. The National Industrial Security Program Operating Manual (NISPOM) and the International Traffic in Arms Regulations (ITAR) may require a TCP under certain circumstances. Thus, your TCP should contain procedures to control access for all export-controlled information.
What should be in a TCP?
A TCP should consist of the following six parts:
* Description of information to be protected. All employees of a company should know what they are required to protect. Although classified information is marked with classification caveats on each page, proprietary information, trade secrets, and export-controlled information are not always well...