Canadian Controlled Goods Program (CGP) security plans are a requirement for work sites where goods are examined, possessed, or transferred. This is a requirement for all companies registered in the CGP as described in section 10 of the Controlled Goods Regulations.
Controlled goods are primarily items, components and technical data that have been designated as having military or national security significance including International Traffic in Arms Regulations (ITAR) items. These goods are controlled by the Canadian government under the Defence Production Act. Controlled goods can be in the form of tangible items such as parts or components, printed material or electronic data.
Developing a Security Plan
A unique plan must be implemented for each business location of the registered organization. The plans must be based on a risk assessment for each location based on the specific goods stored, location of site, and levels of criminal activity in the area. This security assessment will allow for informed decision making as to the extent of measures to be taken.
The security plan should include a list of security responsibilities that identifies the individuals involved in those activities. It should include procedures to control the transfer, possession, or examination of controlled goods. It should also include documented procedures for reporting security breaches. Additionally, the plan should include training programs for export compliance team members.
Security briefings for visitors who be on site to examine, possess, or transfer controlled goods should be described in procedures. Visitors not exempt from the program must not be allowed access to controlled items.
Documented Procedures for Monitoring Controlled Goods
It is essential to document what specific controlled goods the company is working with. These should be categorized as components, physical objects, written documents, or digital information. The procedures must then identify how those items are to be received, stored, and transferred.
Security breaches that result int the theft, loss, unlawful examination, transfer, or possession of controlled goods must be reported. Documented procedures must be in place that describe the investigative steps the company will take in response to these incidents.
Putting the Plan in Action
Once a plan has been created, it must be approved by a compliance inspector. The inspector will guarantee that the plan complies with the regulations set forth by the Controlled Goods Regulations and is suitable for the company and its particular location.
A security plan must be in effect during the entire period that the organization is registered with the Controlled Goods Directorate. As with any management plan, the security plan must be regularly reviewed to ensure effectiveness. Upon review, where deficiencies or opportunities for improvement are identified, the program should be updated accordingly.
CVG Strategy Export Compliance Management Programs
Establishing a CGP security plan is an important part of this complex set of export regulations. Failure to follow these regulations can result in fines, penalties, and imprisonment. CVG Strategy export compliance experts can help you establish and maintain a viable Canadian Export Compliance Management Program.
CVG Strategy has been helping our clients with their export compliance programs for over a decade. We can also assist with product Export Control Classification Determination. Our experts can also provide guidance and the essential training to ensure that your personnel understand these important laws.