Cyber Defense eMagazine December Edition for 2021
Will you stay one step ahead of Cyber Scrooge this year? Learn new ways to protect your family, job, company & data. December Cyber Defense eMagazine: Cyber Deception Month is here...Defeat Cyber Scrooge! Cyber Defense Magazine December Edition for 2021 in online format #CDM #CYBERDEFENSEMAG @CyberDefenseMag by @Miliefsky a world-renowned cyber security expert and the Publisher of Cyber Defense Magazine as part of the Cyber Defense Media Group as well as Yan Ross, US Editor-in-Chief, Pieruligi Paganini, International Editor-in-Chief and many more writers, partners and supporters who make this an awesome publication! Thank you all and to our readers! OSINT ROCKS! #CDM #CDMG #OSINT #CYBERSECURITY #INFOSEC #BEST #PRACTICES #TIPS #TECHNIQUES See you at RSA Conference 2022 - Our 10th Year Anniversary - Our 10th Year @RSAC #RSACONFERENCE #USA - Thank you so much!!! - Team CDMG CDMG is a Carbon Negative and Inclusive Media Group.
Will you stay one step ahead of Cyber Scrooge this year? Learn new ways to protect your family, job, company & data. December Cyber Defense eMagazine: Cyber Deception Month is here...Defeat Cyber Scrooge!
Cyber Defense Magazine December Edition for 2021 in online format #CDM #CYBERDEFENSEMAG @CyberDefenseMag by @Miliefsky a world-renowned cyber security expert and the Publisher of Cyber Defense Magazine as part of the Cyber Defense Media Group as well as Yan Ross, US Editor-in-Chief, Pieruligi Paganini, International Editor-in-Chief and many more writers, partners and supporters who make this an awesome publication! Thank you all and to our readers! OSINT ROCKS! #CDM #CDMG #OSINT #CYBERSECURITY #INFOSEC #BEST #PRACTICES #TIPS #TECHNIQUES
See you at RSA Conference 2022 - Our 10th Year Anniversary - Our 10th Year @RSAC #RSACONFERENCE #USA - Thank you so much!!! - Team CDMG
CDMG is a Carbon Negative and Inclusive Media Group.
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GAO’s decision in L-3 Services, Inc. 3 , demonstrates how a subcontractor’s existing contractual<br />
relationships can cause an OCI <strong>for</strong> a prime contractor. The bid protest involved a contract to consolidate<br />
operations and maintenance requirements <strong>for</strong> networks at seven operating bases. The protester argued<br />
that the awardee had an unequal access to in<strong>for</strong>mation OCI and a biased ground rules OCI because<br />
another company affiliated with the awardee’s subcontractor had provided technical guidance <strong>for</strong> the<br />
protested requirement and had access to unredacted copies of contracts, core communications<br />
requirements, internal agency in<strong>for</strong>mation about upgrading communications and IT infrastructure, and<br />
proprietary in<strong>for</strong>mation of other companies.<br />
After the protest was filed, the agency argued there was no unequal access to in<strong>for</strong>mation OCI because<br />
(i) the in<strong>for</strong>mation was not competitively useful and (ii) the in<strong>for</strong>mation used to develop the solicitation<br />
was disclosed to all offerors. GAO rejected these arguments, finding neither the contractor nor the<br />
agency had tracked what in<strong>for</strong>mation the affiliated company had access to over the course of<br />
per<strong>for</strong>mance. GAO surmised that the affiliated company likely had access to nonpublic in<strong>for</strong>mation the<br />
agency was not aware of and that was never disclosed to offerors. Notably, in overturning the award,<br />
GAO did not base its decision on whether or not the prime awardee actually had access to the<br />
in<strong>for</strong>mation. Instead, GAO held that access by an affiliate of a subcontractor was sufficient to create an<br />
OCI.<br />
GAO also held there was a biased ground rules OCI because although the subcontractor’s affiliate did<br />
not draft the specifications, the affiliated company participated in the business/mission case development.<br />
GAO also noted the affiliated company’s research became part of the source in<strong>for</strong>mation used to develop<br />
the requirement. GAO sustained the protest, recommended the awardee’s subcontractor be excluded<br />
from the completion, and recommended the procuring agency conduct a new OCI investigation and<br />
determination.<br />
Mitigating an OCI<br />
As the cases discussed above illustrate, an OCI can be devastating <strong>for</strong> a company. However, in many<br />
situations, the adverse effects of an OCI can be avoided by proactively implementing an OCI mitigation<br />
plan. To be effective, a mitigation plan must be tailored to a specific contract opportunity and the<br />
circumstances that give rise to the actual or potential OCI(s). Nonetheless, there are some general<br />
principles that may guide the development of a plan:<br />
• An unequal access to in<strong>for</strong>mation OCI is the easiest type of OCI to mitigate. The objective is to<br />
limit access to and dissemination of competitively useful nonpublic in<strong>for</strong>mation. Mitigation<br />
techniques include nondisclosure agreements, firewalls, document controls, and restricting<br />
personnel assignments.<br />
• An impaired objectivity OCI is more difficult to mitigate. A firewall or other types of in<strong>for</strong>mation<br />
controls will not mitigate an impaired objectivity OCI. Using a separate division to per<strong>for</strong>m<br />
problematic tasks will not mitigate the OCI. Instead, an impaired objectivity OCI may be mitigated<br />
by using a firewalled subcontractor who reports directly to the government or using objective<br />
3 L-3 Services., Inc., B-400134.11, B-400134.12, Sept. 3, 2009, 2009 CPD 171.<br />
<strong>Cyber</strong> <strong>Defense</strong> <strong>eMagazine</strong> – <strong>December</strong> <strong>2021</strong> <strong>Edition</strong> 90<br />
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