Trade Compliance

Technical Data and Microsoft Teams

Frequently Asked Questions

 

In an effort to provide clear and concise guidance to comply with U.S. and international export control laws, this document intends to communicate a few examples of appropriate use cases for Microsoft Teams.  Based on the current Microsoft M365 Teams environment and support in the commercial cloud, NO TECHNICAL DATA subject to U.S. or international export controls can be uploaded, stored, shared, communicated and/or recorded in Teams.

 

What is the intended use of Microsoft Teams at Mercury Systems?

The intent and use of Microsoft Teams is to enable business collaboration that does not include technical data.

 

What is technical data?

  • Information in any form (e.g., written, electronic, visual or verbal) that is required for the design, development, production, manufacture, assembly, operation, repair, overhaul, refurbishing, testing, maintenance, use, installation or modification of any item subject to control under United States or international export control laws. These limitations apply equally to commercial technical data as well as technical data related to military goods. 
  • This includes information pertaining to raw materials, parts (including purchased parts), components, end-items, test fixtures, production equipment and tooling.

 

What happens if technical data is included within the Teams environment?

  • The moment technical data is uploaded and/or discussed within the M365 Teams commercial cloud environment, it is presumed to be a release of technical data to a non-U.S. person, which equates to a violation of applicable export control laws. The Microsoft service model for the commercial cloud assumes non-U.S. person Microsoft admins may have access to the content of the file(s) and data redundancies/backups may be hosted outside the U.S.

 

What should I do if I, or someone within a Team, include or discuss technical data within the Teams environment?

  • Notify the Mercury meeting host at once so appropriate corrective action can be taken. Alternatively, contact the Mercury IT Service Desk at  ServiceDesk-Support@mrcy.com or 1-978-967-3000.

 

What are some examples of technical data?

Technical data examples include, but are not limited to:

  • Drawings/Blueprints/Specifications/Functional Diagrams/Schematics/Interface Control Drawings/Block Diagrams
  • Models/Solid Models /Thermal Models
  • Design Memos/Trade Studies/Algorithms/Change Requests
  • Test Data/Failure Reports/Test Data/Test Procedures
  • User/Operating Manuals
  • Software/Firmware/Device Drivers
  • Bill of Materials (that include more than just a list of parts)
  • Pictures that reveal technical information (e.g., traces on a printed circuit board, etc.)
  • Discussions related to any of the above

 

What information is not considered technical data?

Examples of what is not considered technical data are:

  • Information regarding general engineering principles not applied to a particular product/program
  • Information in the public domain (e.g., VITA standards, MIL standards, ISO standards, FAA standards, etc.) not applied to a particular product/program
  • Descriptions of top-level capabilities and basic marketing information on function, purpose or general system descriptions
  • Outline/envelope drawings, product exterior dimensions
  • Program schedules, pricing, delivery information, non-technical business communications (announcements, business strategy, goals, financial information, contracts)