July 22, 2019

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New Defense Security Service Electronic Communications Plan Released

The Defense Security Service (DSS) has released an updated Electronic Communications Plan (ECP) template for use by facilities cleared under foreign ownership, control or influence (FOCI) mitigation. This version replaces the template previously released on June 28, 2010.

The ECP template revisions were made in response to an internal review of the document, and feedback from directors, proxy holders, and industry professionals. DSS provides that the following changes were implemented:

  • Clarification on teleconference and video teleconference requirements. Sections 1, 17.1, and 17.3.
     
  • Monitoring configuration changes and specifying which changes require prior approval by DSS. Section 8.1 and the addition of attachment 4, "ECP Revision Log."
     
  • Export Control Procedure. Section 16. Specifically, the addition of the sentence, "If a third party provider is administering the Company’s network, please describe the Company's procedures in place to ensure that export control violations do not occur with respect to the third party provider's administration of the Company's network."
     
  • In attachment 3, the user acknowledgement language now provides that employees must be briefed on the purpose of ECP and their responsibilities under the plan.

A copy of the updated "Electronic Communications Template" is available at http://www.dss.mil/isp/foci/foci_info.html.

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About this Author

Brian E. Kaveney, Litigation, Attorney, Armstrong Teasdale, Law firm
Partner & Security Clearance Team Leader

Brian Kaveney is an experienced business litigator whose practice includes advising defense contractors on compliance matters and assisting companies and individuals in obtaining and maintaining the proper security clearance.

The founder and head of Armstrong Teasdale’s Security Clearance and Facility Clearance Task Force, Brian guides companies, key management personnel, and employees through the process of obtaining and keeping the approval that is required to work with the Department of Defense, the military services and other agencies. He anticipates issues and concerns and...

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