Technology Control Plans
ECTS utilizes Technology Control Plans (TCP) to manage access to export-controlled technology at MSU. A TCP specifies the security measures that will be used from the point that the technology is delivered to, or is generated by, MSU through the lifecycle of the project, until disposal of the technology at the completion of the project.
- Export-controlled “Technology” managed under a TCP could include:
- Equipment (including parts, systems, and components)
- Software (source/object code)
- Materials, toxins, & chemicals
- Defense Services (e.g., training & instruction)
- Data or information about an item or material
TCP’s are created by ECTS with the help of the PI, and signed by all MSU personnel who have access to the export-controlled technology. TCP’s are stored in MSU’s Export Control Dashboard for record keeping. PI’s and project team members who have access to export-controlled Technology at MSU sign copies of their TCP and are audited on an annual basis.
Security Requirements
A TCP includes specific information about the security requirements that are necessary for each project. The security requirements include:
Physical Security
- Controlled Materials - Describes what export-controlled Technology will be provided and how it will be delivered
- Location - Describes the physical location of each Technology and how spaces will be secured from access by unauthorized persons
- Item Marking - Describes how export-controlled Technology must be clearly identified and marked
- Safe Storage - Describes how all export-controlled Technology will be securely protected from unauthorized persons
- Disposition of Controlled Materials - Describes how export-controlled Technology will be returned or destroyed upon completion or termination of your project.
Information Security
- Conversation Security – Describes what measures you will take to ensure that all discussions of export-controlled information are conducted in secure areas by authorized personnel
- IT Security Plan - Describes the security for electronic data and protocols for other export-controlled information
- Storage & Transmission Protocols - Describes whether export-controlled information will be stored and/or transmitted electronically or physically, and the protocols for secure transmission
Personnel Certification
The TCP will list the principal investigator, any participating investigators and any other MSU personnel who have access to export-controlled Technology.
- All MSU personnel (scientific or administrative) must identify and verify their citizenship
- All MSU personnel will be screened against international export sanction lists
- All MSU personnel must complete export controls training
Annual TCP Reviews
Technology Control Plans are reviewed annually. The TCP annual review is a rolling process where the PI of any TCP that has been untouched for more than 12 months is contacted and required to review the contents of their TCP for any changes or updates. If there are changes needed to the TCP, then a TCP Amendment will be processed.
Technology Control Plan Export Control Training
Training specific to your TCP will be provided by MSU’s Office of Export Control and Trade Sanctions at the time your TCP is written. A presentation of pdf slides will be required to be viewed by all participants that will be listed on the TCP.