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<p>As stories of international and domestic hacking and espionage
dominate the news cycle, it’s easy to forget that when it comes to trade
secrets, employees and business partners—not hackers—pose the biggest
threat. <em>See</em> David S. Almeling et al., <em>A Statistical Analysis of Trade Secret Litigation in Federal Courts</em>, 45 Gonz. L. Rev. 291 (2009/2010).</p>
<p>In a recent <a class="gmail-logclick gmail-ct_cont" target="_blank" href="http://employment.gordonreeswebinars.com/november-8-2016-non-competes-non-solicitations-can-you-protect-your-business-information-from-employee-theft/">webinar</a>,
Gordon & Rees addressed protection of trade secrets and proprietary
information from employee theft. Here, we address some steps to help
prevent business partners from misusing your trade secrets.</p>
<ol><li><strong>Identify your trade secrets and control access to them</strong></li></ol>
<p>Before any agreements are drafted or any information or documents are exchanged, be sure you have identified your <a class="gmail-logclick gmail-ct_cont" target="_blank" href="http://www.gordonrees.com/publications/2016/the-defense-of-trade-secrets-act-key-takeaways-and-recommendations-for-businesses">trade secrets</a> (see also the definition under the <a class="gmail-logclick gmail-ct_cont" target="_blank" href="https://www.law.cornell.edu/wex/trade_secret">Uniform Trade Secrets Act</a>).
You can’t protect them unless you know what they are. This sounds like
common sense, but surprisingly, in the hustle and bustle of everyday
work, not all companies take the time to do this until they’ve realized
their trade secrets have ended up in the wrong hands. (Unless it is
appropriate for your industry, referring to everything as a “trade
secret” is not helpful, either—for example, your business partners are
less likely to take your actual trade secrets seriously if you claim
that information you have made public are also trade secrets.)</p>
<p>A trade secret “registry” could be considered favorable evidence in
court—as long as it is timely updated and actually distributed to
employees. <em>See Schalk v. State</em>, 823 S.W.2d 633, 643 (Tex. Crim.
App. 1991). This registry will also help your own employees with the
marking the proper designations when such information is exchanged with a
business partner.</p>
<p>Securing your trade secrets in-house will not only help your case in
court, it also helps when it comes to disclosure to third parties,
particularly inadvertent disclosure. Chances are, not every employee
will require access to every trade secret. Secure physical and
electronic access to the appropriate trade secrets to the appropriate
personnel.</p>
<p>What measures are appropriate will depend on the circumstances and
will likely evolve with time and technology. Information stored on
secure servers that had three layers of physical security passwords,
256-character PuTTY keys, with portions possessed by only a single
person was found by a court sufficient evidence for a jury to conclude
that a trade secrets owner took appropriate measures to protect its
trade secrets. <em>Xtec, Inc. v. CardSmart Techs., Inc.</em>, No. 11-22866-CIV-ROSENBAUM, 2014 U.S. Dist. LEXIS 184604, at *26 (S.D. Fla. May 15, 2014).</p>
<p>On the other hand, where information was distributed to 600-700
people where at most only 190 people signed confidentiality agreements,
and where that same information was not stamped as “confidential,” a
court found that no reasonable jury could conclude that “reasonable
efforts” were made. <em>Tax Track Sys. Corp. v. New Inv’r World, Inc.</em>, 478 F.3d 783, 788 (7th Cir. 2007).</p>
<ol><li><strong>Draft tailored non-disclosure agreements (“NDAs”)</strong></li></ol>
<p>Before any information is exchanged with a business partner, have
your attorneys help you draft a non-disclosure/confidentiality agreement
tailored to the arrangement. Not only will this agreement help you in
case you need to litigate the matter, it will provide the protocols for
your business partner to follow.</p>
<p>Some provisions you and your attorneys will want to consider are the
return/destruction of trade secrets at certain stages (and certainly
when the relationship is terminated), a perpetual non-disclosure and
non-use clause when it comes to trade secrets (as opposed to an expiring
one), how trade secrets will be identified/marked (and the ability to
later identify/mark previously exchanged documents), and requirements
for the business partner’s employees to sign individual NDAs and/or
obtain training on how to handle trade secrets. This is not an
exhaustive list—work with your attorney to flesh out the agreement.</p>
<p>Be wary of stock or template agreements; many of them may not
contemplate the specific issues that may arise in your situation. Many
“standard” agreements also contain language that relieve the business
partner of its contractual obligations of non-disclosure and non-use as
soon as the trade secrets are made public—without specifying that such
public disclosure must have been authorized by the owner of the trade
secret, and without giving the owner the chance to mitigate the effects
and damage of the unauthorized disclosure.</p>
<p>But no matter how perfect the agreement, it won’t matter if it isn’t properly implemented.</p>
<ol><li><strong>Train your own employees</strong></li></ol>
<p>Identify all the employees who will be corresponding with the
business partner and make sure you train them. Let them know what
information can be exchanged, what cannot, which individuals from the
business partner they can exchange information with. Provide them with a
written checklist and designate a person most knowledgeable—or better
yet, a specialized team to direct their questions to. This team should
also conduct some “spot checks” throughout the relationship to make sure
protocols are being followed.</p>
<p>If the relationship with the business partner will span more than a
couple months, also have a plan in place to retrain your employees in
regular intervals.</p>
<ol><li><strong>Train the business partner’s employees</strong></li></ol>
<p>Even if you require individuals from the business partner’s company
to sign an NDA, that may not be enough. You may want to provide the
partner’s employees with the necessary training, or at least provide the
partner with the necessary materials to provide the training themselves
(and require them to do so as part of the NDA). Regularly communicate
with the partner to make sure they are protecting your trade secrets,
and have your employees and your specialized team pay attention to how
the business partner is using this information as well.</p>
<ol><li><strong>Create a contingency/emergency plan</strong></li></ol>
<p>Did an employee send a trade secret to the business partner without
marking it as such? Has the business partner communicated plans that may
violate the NDA? Has the relationship with the business partner begun
to go sour?</p>
<p>Your team should already have a contingency plan in place to deal
with these—and other—situations, and protocols to continually improve
security and access. Make sure you follow through on enforcing
contractual provisions, and make sure you act swiftly.</p>
<p>In closing, remember that when dealing with trade secrets or handling
other proprietary, confidential or otherwise private information,
nothing beats being prepared.</p>
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