Wednesday, August 17, 2011

Classified storage approval... Three Steps to Prepare Defense Contractors for Closed Areas

As a Facility Security Officer, you take the lead in creating a security program designed to protect classified information. You are at the cutting edge of your cleared contractor organization's capability of getting and keeping classified contracts. As such, you should also be the senior executive's right hand and have successfully established the required relationship to provide sage security council.

Some topics relevant to your organization might be:
Where are we heading?
What type of classified storage might this require?
What will be the cost and impact to the company?
How is my security program poised to support current and new contracts?

If a new or existing contract requires dedicated space to perform on and store classified information, a "Closed Area" may be required. A closed area is used to safeguard classified material of unusual "size, nature, or operational necessity, and cannot be adequately protected by the normal safeguards or stored during nonworking hours in approved containers" and NISPOM 5-306 provides minimal guidance on cleared contractor responsibilities and 5-800 provides construction information.

1.  Ensure you have a classified contract that approves classified storage and performance at the prospective closed area location.
You can find this information on the top right corner of the DD Form 254. There are two blocks there that indicate Facility Clearance Required and Level of Safeguarding Required. Block 11 should be marked with the Cleared Contractor's requirements in performance of the classified contract (store, receive only, fabricate, etc). Further instructions may be found in Blocks 13 and 14. If you have any questions, you should clear it up with the customer. Your responsibility as FSO is to ensure your company is capable of understanding the security requirements and performing as instructed. It is vital that your executives and customers are in complete synchronicity

2. Work with your Defense Security Services to ensure they understand the requirements and there are no surprises. 
DSS has oversight and as such, they will verify that your classified contract, storage capability, and security program will protect classified information.  As such, the cleared defense contractor, your organization will also have to produce and demonstrate storage and performance procedures before approval.

3. Identify level of security.
For the storage of SECRET and above in a closed area, you will need to use supplemental protection during non-working hours and use approved locking devices for access control during working hours (see NISPOM 5-306). Access control can either be a cleared person making checks or an automated system. If you don't already have an area that meets approved construction requirements, you might have to make significant modifications to an existing room or completely build a new room. If so, consider taking pictures throughout the construction as you build so that you can demonstrate compliance. After construction is done, it will be hard to verify proper construction once construction is complete. At any rate, work closely with your DSS rep and Prime contractor or GCA.

That's it, these three steps should be addressed as a minimum before you invest critical resources to dedicate construct space for a "closed area". Closed areas help protect classified information that cannot be otherwise protected, but it costs money. Approval of closed areas may require further approval of open bin storage. 

For more information, check out our new book, DoD Security Clearances and Contracts Guidebook

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