How does the CFSP protect a facility’s information?
The protection of identifiable and confidential materials is critical to the RMI and to participating SORs. The CFSP secures confidential information using an array of procedures and agreements, including:
- Non-Disclosure Agreements (NDAs), also known as Agreement for Exchange of Confidential Information (AECIs), are established between the audit firms, RMI staff, ARC participants, and SORs.
- Auditors are required to protect details of the facility information assessed onsite during the audit (e.g. export certificates, transportation documents). If a facility requires an NDA with the auditor, it must arrange that outside of discussions with the RMI. Such an NDA cannot conflict with the auditor completing their audit tasks.
- Note that the audit report reflects the results of the onsite documentation analysis and the mass balance summary. The ARC is provided a copy of the LIS created by the SOR for comparison to the mass balance summary.
- Audit reports are the property of the SOR. The auditor provides a copy of the report to the RMI Staff for distribution to the ARC for the purposes of the audit review and compliance determination.
- During the onsite audit, the SOR should make sufficient effort to obtain the necessary origin and chain of custody documents from traders or other suppliers but may have difficulty in doing so due to business confidentiality concerns. In such cases, the smelter may request that the trader or other supplier provide the necessary documents directly to the CFSP auditor for review. This process should be an interactive process between the smelter, the auditor, and the smelter's supplier. This should be considered an exception process as delays in receiving the required documentation may incur cause higher audit costs for the smelter.
- In the case where origin and chain of custody information is held within a third-party upstream assurance system, the upstream assurance system may send this information to the CFSP auditor directly in order to both address confidentiality issues and increase efficiency.
- All questions regarding SORs that are not on the public RMI list will be directed back to the SOR as they are best positioned to communicate their participation and status within the CFSP to their customer base.
- Aggregate numerical indicators are maintained on RMI’s website to publically indicate program participation over time.