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Commercial radio signals routing overseas – should you be concerned / CS Webinar today
October 25, 2023
Commercial radio routing overseas – should you be concerned
                 I have been using a little commercial fire radio for about 6 months now. With all the ransomware issues going around my IT guy was checking our systems and traced the units’ IP reporting.   Incredibly, these signals are routed all the way over near Ukraine, through Bulgaria, an Eastern European block country. (I’m assuming the cell signals are too.)
                  If my alarm signals are routed outside the US am I incurring more liability issues, like if something happens and signals are slowed down getting to my central station, or cut off by bombing or some political stuff?? 
                 Also, as a security provider for local government buildings, banks and such, does using this radio jeopardize these accounts?  Should I be worried?
                 This sounds like a question for the central stations and UL and NRTL experts.  Good thing we’re in the middle of the central station webinar series; I hope someone brings this issue up for discussion.
                Some, maybe all, government agencies do not permit monitoring by overseas central stations.  These agencies include defense industry facilities; that’s federal requirements.  There are also state agency requirements that prohibit central stations outside the US.  I believe the requirement is so comprehensive that not only can’t defense facilities have overseas monitoring but anyone doing business with the defense department cannot have their facility monitored by overseas central stations.  I haven’t studied the rules, but here is the source if you want to read them:
PART 117—NATIONAL INDUSTRIAL SECURITY PROGRAM OPERATING MANUAL (NISPOM) Authority:32 CFR part 2004; E.O. 10865; E.O. 12333; E.O. 12829; E.O. 12866; E.O. 12968E.O. 13526E.O. 13563E.O. 13587E.O. 13691Public Law 108–458; Title 42 U.S.C. 2011 et seq.; Title 50 U.S.C. Chapter 44; Title 50 U.S.C. 3501 et seq. Source:85 FR 83312, Dec. 21, 2020, unless otherwise noted.
                    With this in mind I think there could be a problem with communications passing overseas and then back.  The Standard Form Agreements do not address overseas operators, overseas central stations or remote operators working from home.  I suspect that expect government agencies and those working with them who are covered by restrictions regarding foreign involvement in monitoring raise the issue.  Typically dealers who contract with government agencies and those affected by their doing business with government agencies will require the dealer to sign it’s vendor agreement which will address the specific requirements or restrictions on central station monitoring ownership or where the central station or operators can be located.
               If a dealer or a central station believes that communication signals traveling outside the US and back, or foreign operators, present additional risk to the monitoring service then the dealer or central station should be informing the customer of this added risk. 
              Overseas communication with US subscriber facilities is just one issue that may arise by overseas operations.  A dealer may want to consider if operator training or operator criteria is different than US based and staffed central stations and in facility operators.  For example, dealers would not expect a US central station to be staffed with child labor or coerced labor, such as prisoners or others being forced involuntarily.  That expectation may be illusory or not met in a foreign country with different laws or customs. 
                What about this radio situation which is automated?  Well I suppose it’s true that operators aren’t involved.  However, someone is maintaining the communication systems, repeaters, receivers and transmitters at foreign locations.  Who are these mechanics and how are they vetted?  Probably hard to figure out when you don’t even know where the signals are traveling through.
                 Probably safer to use American made equipment, made here in the US, owned and controlled by US citizens, monitored by US located central stations with in-facility US citizen operators.  What to do about Chinese or other foreign made components is another topic for another day.

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Central Stations series: Why You Should Be Monitored By Our CS
Hear from the leading central stations and “Why you should be monitored by” that central station.  The topic of remote operator monitoring from outside the central station facility and the dynamics that issue presents is sure to come up. 
October 25, 2023 noon ET, Dynamark Monitoring
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Ken Kirschenbaum,Esq
Kirschenbaum & Kirschenbaum PC
Attorneys at Law
200 Garden City Plaza
Garden City, NY 11530
516 747 6700 x 301