Security of Government, Personal
and Corporate Information

Standard Practice and Procedures (SPP) for
National Security Information

In-Depth Engineering has entered into a Security Agreement with the Department of Defense in order to have access to information that has been classified because of its importance to the National Defense. Many of our programs and activities are vital parts of the Defense and Security systems of the United States. Our responsibility and obligation as an organization involved in such programs is to safeguard all information and material related to these classified programs.

We have developed a Standard Practice and Procedures (SPP) Manual which is the official publication for policy and procedural details relating to the In-Depth Fairfax and Fulton site security program. The policy and procedures outlined in the SPP are intended to supplement and clarify certain requirements of the National Industrial Security Program Operating Manual (NISPOM) and to assist employees in applying the provisions of the NISPOM to the business environment. These procedures apply to the handling and safeguarding of classified information transmitted to us, of which we are obligated to protect in the interests of National Defense. Each of us is required to read and certify that we have read the SPP.

Failure to comply with the SPP, the NISPOM, and the In-Depth security training requirements must be reported to both the FSO and ethics officer and may result in remedial action, disciplinary action, and/or termination of employment, as deemed necessary and appropriate.

Protecting Personally Identifiable Information (PII)
and Proprietary Information

We routinely collect, generate, and utilize proprietary information, personally identifiable information (PII), and sensitive information (a subset of PII) in our day-to-day work.

“Personal data” or “personally identifiable information” (PII) is defined as data from which In-Depth customers and personnel (and, where applicable, their immediate family members) can be identified. Personal data includes a person’s first name and last name or first initial and last initial in combination with any one or more of the following data elements that relate to the person: (a) Social Security Number; (b) driver’s license number or state-issued identification card number; (c) mailing address; (d) email address, (e) passport number or identification number issued as official identification by a Federal, State, or Local authority; or (f) financial account number, or credit or debit card number, with or without the security code, access code, personal identification number or password, that would permit access to a person’s financial account; provided, however, that “personal data” shall not include information that can lawfully be obtained from publicly available information, or from federal, state, or local government records lawfully made available to the general public. “Sensitive information,” is a special category of PII revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, criminal convictions, or personal data concerning health.

While the collection and retention of PII is required for the execution of normal business function (e.g. payroll and taxes), our files do not contain any sensitive information other than as provided by In-Depth personnel pursuant to their express, informed consent. In-Depth will explicitly request and receive permission from any individual to further process or otherwise use that individual’s sensitive information.

Proprietary Information is non-public sensitive information that is owned by In-Depth that gives us a certain competitive advantage and is critical to the survival of our business. Proprietary information includes, but is not limited to, information concerning our research or development efforts, methods, trade secrets, technical data, designs, know-how, inventions, mask works, discoveries, processes, technology, engineering information, computer software, product or marketing plans, information concerning our vendor or customer relationships or finances, cost and price information, investments, and other information concerning our operations or affairs. Proprietary information includes information that the Company has received, or in the future will receive, from third parties and is protected to the same extent as if such information was developed by or for the Company.

Employees who have received or have access to PII, sensitive information, or proprietary information must take care to keep this information private in accordance with the In-Depth PII Policy as well as relevant laws. Disclosure of this type of information requires proper authorization.

In the course of normal business activities, customers, and competitors may divulge proprietary, sensitive, or PII information to us with regard to their business. We may only accept such information if use or acceptance complies with a signed Non-Disclosure Agreement. Employees who receive such information from a customer or competitor, without an NDA, must immediately bring this to the attention of the Ethics Officer.

Employees must not steal or use trade-secret information, and must not suggest or ask others to disclose trade secrets, especially new employees hired from a competitor. New hires may not bring papers or computer records from prior employers, if those papers or records contain proprietary, PII, or sensitive information belonging to their prior employer.

Company Information

All records and files of In-Depth are property of the organization and considered proprietary. No Employee is authorized to copy or disclose any such file or record. This information includes, but is not limited to, all letters, e-mails, or any other information concerning transactions with customers, DOD, sub-contractors,, financial records of the organization, all records pertaining to purchases from vendors or suppliers, correspondence and agreements with customers, manufacturers or distributors, and documents concerning operating procedures of In-Depth.