SECURE EQUIPMENT ACQUISITION TASK FORCE POLICY ALTERNATIVE: EXCLUSION OF FOREIGN SOURCE ADPE

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP91-00280R000100130035-1
• Release Decision: RIFPUB
• Original Classification: U
• Document Page Count: 5
• Document Creation Date: December 23, 2016
• Document Release Date: September 11, 2013
• Sequence Number: 35
• Publication Date: October 2, 1981
• Content Type: MISC

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WORKING PAPER
2 October 1981
SECURE EQUIPMENT ACQUISITION TASK FORCE
POLICY ALTERNATIVE: EXCLUSION OF FOREIGN SOURCE ADPE
DEFINITIONS
a. Foreign Source ADPE means automatic data processing equipment
(ADPE) either manufactured on foreign soil or manufactured by
a firm under foreign ownership, control or influence.
Foreign source ADPE also includes ADPE marketed by a firm
under foreign ownership, control or influence.
1. ADPE manufactured on foreign soil means ADPE in which
critical subsystems or components are manufactured, or
final assembly occurs, outside the continental U. S.,
Alaska or Hawaii; i.e., an area where it may be presumed
manufacturing personnel are predominantly foreign
nationals. ADPE criticals subsystem or
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components include, but are not limited to, those that
perform logic, communcations, memory, control or display
functions and through which data would flow in the normal
operation of the ADPE. Also included are those
subsystems or components essential for the operation of
the ADPE, irrespective of function.
2. A corporation shall be considered under foreign
ownership, control or influence when any foreign investor
has acquired a direct or indirect beneficial ownership
interest of 5 percent or more of any class of stock in
that corporation.
Policy
It is Agency policy not to procure foreign source ADPE for
use in Agency automatic data processing systems. Program office
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management may request that an exception to this policy be made.
Requests for an exception should demonstrate the existence of a
critical requirement which can only be satisfied by foreign
source ADPE or an overriding operational or cost advantage in the
use of foreign source ADPE. Exceptions to this policy require
the concurrence of the Directors of Security and Logistics.
Procedures
1. Prior to an ADPE procurement action, a prospective vendor wil
be required to fill out a "Certificate Pertaining to Foreign
Interest and Manufacture*
2. A preliminary evaluation will be performed by the Contracting
Officer and Contracting Officers Technical Representative
(COTR). If required a Security Evaluation Team, comprised of
representatives from the Offices of Security and Logistics
*To be developed, but patterned on DD Form 441s (1 Sept 1976),
"Certificate Pertaining to Foreign Interests."
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and the program office, will be convened to evaluate vendor
responses. Further information may be requested from
vendors. The team will issue a findings memorandum which
will state that the proposed ADPE is acceptable or
unacceptable from a foreign source standpoint and provide the
rationale for its decision. If the ADPE is evaluated as
unacceptable, the vendor may appeal or the program office may
request an exception.
. .
3. Vendors for which an exception is requested will be required
to submit a satisfactory Security Management Plan prior to
final approval to use foreign source ADPE. The plan will
outline action taken by the vendor to minimize security
vulnerabilities associated with foreign source ADPE.
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4. A request for an exception by program office management
should demonstrate the existence of a critical requirement
which can only be satisfied by foreign source ADPE or an
overriding operational or cost advantage in the use of
foreign source ADPE.
5. A vendor may appeal an adverse foreign source finding to the
Directors of Security and Logistics. Concurrence of both
directors is required to overturn an adverse finding.
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