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ITAR Compliance

ITAR Technology Transfer Control Plan

Diffraction International (DI) receives ITAR controlled documents from its customers and potential customers. These documents typically consist of optical component drawings used by DI for purposes of designing custom diffractive null tests. Most controlled materials are received in the form of email attachments, although some paper documents are received.

Electronic Documents

ITAR controlled electronic documents are stored on a password controlled LAN. The servers are secured behind a door that locks upon closing. User accounts with LAN access to controlled documents are configured to display a screen saver after a few minutes of inactivity and to require a password or fingerprint on resume. LAN backups are password protected.

Documents are filed by customer name and quotation number in the case of RFQs or else by Job number in the case of contracts. Quotation documents are copied to Job Folders on award of contract. Folders can be marked for offline availability (MS Windows feature) when work must be performed offsite on laptop computers; currently, only Steve Arnold has offline access.

Job folders are retained indefinitely on our LAN server so that we can readily handle customer support questions.

Paper Documents

Our procedure is to mark up the electronic documents using Adobe Acrobat's commenting features, but sometimes there is a need to print paper working copies. These copies are shredded after use.

ITAR controlled paper documents are stored in a locked file cabinet. Paper quotation documents that do not result in a contract award may be destroyed after 3 years, or sooner if requested by the customer. Original paper documents that may be of archival importance to a Job are converted to electronic form. We are fairly ruthless in not retaining paper documents.

Technology Transfer

DI does not employ any non-U.S. persons. DI does not transfer ITAR controlled items or data to its subcontractors. Derivative information is transferred back to our customers in the form of optical prescriptions, sag tables and raytrace models.

Document Marking

Diffraction International has developed a system for marking of controlled documents. Almost all technical documents produced by DI are computer-generated from the OSLO optical design files. We therefore mark controlled OSLO files at the time of their creation. This marking then automatically propagates to any derived documents.

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Page updated: 17 October 2014

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