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The Pentagon’s Recent Ban and How It Impacts DoD Contractors

 

How on earth did our  harmless habit of scrolling through TikTok on the toilet turn into a potential national security breach?

That is the question.

Do you remember a couple years ago when social media users all across the US were setting caricatures of themselves as their Facebook profile picture? Do you remember a few days into this wave when we all saw warnings spreading that the software used to get these pictures was actually Russian spyware.

The point is, it’s not uncommon for the average social media user to come upon a fad that later causes federal concern.

Which brings us to TikTok…

As many know, the US government has voiced suspicion around the TikTok platform since its unveiling. For years now, the Pentagon has urged against personnel downloading and accessing the app due to cybersecurity concerns and spying threats, which have been repeatedly raised.

Congress warned that data captured via the social media app could be shared with the Chinese government, which could ultimately become a national security threat.

They recently took this concern a step further—the DoD became one of three federal agencies to formally issue an interim rule to ban the “presence or use” of the social networking app TikTok from any devices that connect with government systems.

Perhaps the funniest part of the whole ordeal is the 1920s vibes the whole thing evokes as the media language around this ban often refers to the “prohibitions” implemented.

Now, before you go digging out your virtual “speakeasies” for your video addiction, maybe first think through whether defiance of these prohibitions is really worth it, or if maybe it might work out in your best interest to wait until these videos are shared on Instagram and Facebook reels like the majority of the 30+ demographic tend to do anyways.

Because the bottom line is whether you think your favorite voiceovers and gender reveal fail videos are a threat to national security or not, it doesn’t matter. This prohibition has been passed, and therefore you, as a contractor of the DoD, are required to act accordingly.

Which brings us to who it impacts…

Well, obviously, TikTokers will be wildly impacted by this guaranteed plummet in views as their broad demographic of federal contractors delete the app.

But, in all seriousness, this information should be heard and understood by anyone interested in doing business with the DoD. If a device is used AT ALL to service a government contract, then this rule applies. This includes:

Government Employees 

Anyone who is on the government payroll was impacted by these regulations even prior to the most recent announcement.

Government Contractors

If you are currently under contract to do work for the DoD, you must remove the TikTok app from all devices used to communicate about, store, or work on these projects.

Employees of Government Contractors

Even if an employee does not regularly work on government projects, they still fall under these prohibitions if they receive any work emails or other communications at all about government projects or maintain work-related channels on their personal devices.

Subcontractors of Government Contractors

Another possibly forgotten category of persons that fall under these regulations is any subcontractors assisting on government projects. If your company hires subcontractors or freelancers, it is important to ensure that TikTok is not downloaded on any devices used for this work.

In summary…  

To break it down, this prohibition applies to all devices used in relation to government work, whether the devices are owned by government

  • employees
  • contractors
  • contractors’ employees
  • contractors’ subcontractors.

Devices used for any kind of work linked to a government contract, even if it’s only a CC on email communications, are not to have TikTok or any successor application or service developed or provided by ByteDance Limited or by any entity owned by ByteDance Limited downloaded on it.

Which brings us to the exceptions…

The only personal devices that do not fall under this rule are those that are NEVER used for contract performance. This means that all work and personal functions on a phone must be separated, whether you have a separate work phone or you never conduct work matters or conversations over the phone or through any mobile apps.

Even a single phone call to discuss a federal contract would cause that cell phone to be subject to this prohibition.

Which brings us to the next steps…

Come on, it’s 2023; we’ve all done the “oh no, I’m out of storage” purge of apps we don’t use regularly. You know how to delete this app, and have absolutely no reason to ‘accidentally’ have it on your phone.

And this responsibility and expectation extends to anyone under you who is also impacted by this rule.

If your company is currently under contract with the DoD, it is important that you and all your employees take these steps to remain compliant with this new prohibition:

  1. Consult with your company’s IT professionals to get a better understanding of which devices may breach this prohibition.
  2. Identify all devices used in the performance of government contracts. This includes the personal devices of contractors and employees.
  3. Remove TikTok from all contractor IT, including but not limited to cell phones, tablets, laptops, desktops, etc.
  4. Remove TikTok from all personal IT devices if these devices are in any way used for contract work.
  5. Ensure that all company subcontractors are also aware of this clause and have removed TikTok from any relevant devices.

 

Our Advice 

At Long Capture, when it comes to the federal government, and particularly when it comes to national security and the DoD, we always lean on the side of caution.

We recommend that if there is any chance that you may ever use your personal device for work, even if you do have a device set up specifically for this use, you should go ahead and remove the app as suggested.

We’re sorry, but in our opinion no cat video, not even Nala that 10-year-old Siamese/tabby rescue, is worth the potential breach of a multi-million-dollar government contract.