Friday, November 5, 2010

The Defense Contractor FSO’s Well Rounded Security Training-Or How Contractors Prepare to Perform on Classified Contracts

Facility Security Officers (FSOs) are highly trained to meet the requirements of NISPOM. Training should reflect NISPOM requirements as reflected in the Contract Security Classification Specification (DD Form 254). If the FSO is in a non-possessing (no classified holding), the training requirements are baseline. However, possessing facilities have more requirements that the FSO should be prepared to meet. Objectives of the FSO Program Management Course are to prepare the FSO to implement and direct a NISPOM based security program in their cleared contractor facility. The training includes, but is not limited to the following topics:

Protecting classified material – The proper receipt, accountability, storage, dissemination and destruction of classified material. The FSO learns how to protect classified information in a cleared contractor facility.

Required cleared employee training – This instruction helps the FSO establish an ongoing training program designed to create an environment of security conscious cleared employees. The FSO learns to provide effective training to cleared employees, teaching them to properly protect the classified material and report questionable activity and violations. Such training includes initial security briefings and annual security awareness training.

Personnel security clearances – The FSO gains an understanding of the personnel security clearance request procedure, briefing techniques and maintenance of personnel clearances.

Facility clearance –The FSO learns how FCLs are established. They are also taught which records and activities are required to maintain the FCL.

Foreign Ownership Control and Influence (FOCI) – Organizations analyze foreign investments, sales and ownership on a regular basis. FSOs learn to interact with management and provide guidance and direction in preventing a foreign entity from unauthorized access to classified and export controlled information.

Exports compliance and international operations – International business opportunities abound in a global economy. FSOs receive instruction on how to prevent unauthorized disclosure of critical technology, controlled export and military classified information. Companies can thrive in such an environment provided they can advise or execute Departments of State and Commerce licenses and agreements as required.

Restricted areas – Setting up temporary environments for classified work. The restricted area is established to control temporary access to classified material. At the end of each work day, the classified material is returned to the approved classified holding area.

Closed areas – Government approved space is approved to store and work with classified material. This involves approved construction and limited accesses controls to prevent unauthorized disclosure during and after work hours.

Communications security (COMSEC) – Some contracts may require the establishment of a COMSEC account with the National Security Agency to facilitate secure communications via computer, telephone, facsimile machine or radio. This instruction provides basic information about how to perform under COMSEC requirements.

Duties of an FSO – The FSO should understand not only the job description, but how to communicate with management and fellow employees. Responsibilities include accountability while implementing and directing a security program to protect classified material and NISPOM requirements.

Contract security classification specification (DD Form 254) – This is the vital piece of the classified contract. The FSO cannot execute or allow access to a classified contract unless they possess the customer issued DD Form 254. The FSO also understands how the DD Form 254 is constructed and how to provide input to better meet security requirements.

Security classification guides – As the DD Form 254 provides authorization to execute a classified contract, the SCG provides the “how to” instruction. All employees performing classified work consult the guide to understand what is classified and how to provide the required protection.

Security administration and records keeping – This teaches the maintenance of facility and personnel security clearance information as well as all other accountability information management requirements. The FSO is expected to provide original documentation on Foreign Ownership Control or Influence, facility clearances, SF 312, training completion and classified inventory and disposition. Additionally, some records are not authorized for retention such as the completed Security Clearance application or SF 86 (as of 2006 they are destroyed once investigation is complete). The CSA reviews required documentation during the annual security inspection.

Sub contracting – The FSO will learn their role in subcontracting. Primary contractors are authorized to release classified information on a contractual basis. If approved to subcontract classified work, the contractor will provide a DD Form 254 to authorize the classified subcontract. They will also provide a security classification guide.

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