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Pursuant to 18 CFR Section 358.7(e)(2)
Building and 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 Employees.
The following employee-staffed facilities are shared by certain Transmission Function Employees for DGT and Marketing Function Employees:
One Williams Center
The Marketing Function Employees reside in an office space that is separated from the locations of the Transmission Function Employees for DGT.
DGT’s main office facility is located at 2800 Post Oak Blvd., Houston, Texas. No Marketing Function Employees share this facility. A card key is required to access the office space that DGT’s TFEs occupy in its main facilities in Houston. The card key access system prohibits access by a Marketing Function Employee to DGT’s Houston facilities. Marketing Function Employees, as with non-affiliated visitors, may enter DGT’s office space after registering with a receptionist and providing identification, but no card key is provided and they must be escorted by DGT personnel.
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 information.
Computer 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.
SharePoint 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.
The 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.
DGT 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.