Pursuant to 18 CFR
Building Services – Pursuant
to §358.7(e)(2) of the Commission’s Regulations, the following is a complete
list of the employee-staffed facilities (excluding facilities where individuals
do not typically transact business) shared by any Transmission Function
Employees (TFEs) for Discovery Gas Transmission (DGT) and Marketing Function
employee-staffed facilities are shared by certain Transmission Function
Employees for DGT and Marketing Function Employees:
2800 Post Oak
office facility is located in Houston, Texas. The Marketing Function
Employees reside in Tulsa but periodically travel to the Houston office.
While at the Houston facility Marketing Function Employees reside in an
office space that is separated from the locations of the Transmission
Function Employees for DGT.
Williams employees who have access to DGT’s
non-public Transmission Function Information are responsible for securing
such information from unauthorized disclosure using properly secured
information/processing systems and for similarly securing hard copy
Systems - Transmission Function Employees of
DGT and Marketing Function Employees share telephone systems, electronic mail
systems, SharePoint and related servers, cloud based applications such as
Office 365, and the wide area network which connects Williams various
locations, as well as access to servers on which corporate support-related
systems reside, such as the human resources system, and the financial
enterprise resource planning system (which supports finance, accounting,
planning and forecasting, and reporting functions). Access to the systems
that contain Transmission Function Information (including non-affiliated
shipper information) is subject to strict access controls such as user ids
and passwords or other appropriate information security requirements as
necessary to maintain compliance with the Standards of Conduct.
sites that may include Transmission Function Information are identified and
labeled as potentially having non-public regulated data. These sites
will contain a prominent warning regarding information sharing and no-conduit
rules. Overall security access for MFEs is regularly reviewed by the Williams
FERC Compliance Officer or their designee.
remaining servers where Transmission Function Information is maintained are
not shared with Marketing Function Employees. Access to those servers is
restricted by access control mechanisms (such as user ids, passwords, FERC
deny flag for Windows servers, visibility restriction of FERC IT components
in the access control system). Additionally, a firewall restricts MFE
computer, internet and printer access and will deny-by-default access to any
area not approved. IT procedures require Williams FERC Regulatory
Compliance approval for firewall access changes.
follows the Williams Access Control process under which DGT ensures that
Marketing Function Employees do not have preferential computer access to
non-public Transmission Function Information. Marketing Function Employee
system access is regularly reviewed by the Williams FERC Compliance Officer.
Any transfer by a Transmission Function Employee to a Marketing Function
position is treated as a termination for access purposes, where old access is
revoked prior to granting any new access.