Wednesday, October 2, 2013

How to get ready for the DSS Inspection

As mentioned in an earlier article, NISPOM Change 1 requires Derivative Classification Training and Record keeping Guidance. This guidance requires that the cleared contractor provide cleared personnel with initial Derivative Classification Training and follow up and at least once every 2 years. The training topics are vital to the cleared contractor performing on classified contracts.  Properly trained employees reduce the risk of unauthorized disclosure of classified information.

Currently this training can be put in place at the cleared contractor’s initiative. The sooner training is implemented the better. The Defense Security Services will be publishing an Industrial Security Letter (ISL) that provides instruction for conducting training including a “trained by” date to meet the requirements of the recent NISPOM changes. Why not begin the training now and be prepared for success before DSS gives the deadline for conducting training. Remember, if not trained, cleared employees cannot perform on classified work requiring derivative classification. That’s a lot of missed.

Remember that DSS is in the business of auditing. They are more than capable of both helping a company succeed with good training and working relationships, but they are also just as equipped to find security violations. Failure to protect classified information is a security violation. Failures are often caused by mismarked materials.

For example, after reviewing requirements of a DD Form 254 and statement of work, the industrial security representative discovers that derivative classification work has been occurring since the contract award a year prior. However, training records indicate that the derivative classification training had only been conducted in the last two weeks (while preparing for the inspection).  It wouldn’t be hard to deduce that there is a possible security violation and perhaps a review of classified inventory is in order.

So, how can you prepare to meet this challenge? 

Cleared contractors can refer to NISPOM paragraph 4-102 and develop training based on the directed subjects. Document that training and schedule follow-up training in two years. A good practice is to provide a copy of the training with training signatures or certificates. That way DSS can determine who was trained and whether or not the derivative classification training conformed to NISPOM Change 1.

No time to write training?

You can find training though professional organizations, at the DSS website or here

Jeffrey W. Bennett, ISP is the owner of Red Bike Publishing Red Bike Publishing . He regularly consults, presents security training, and recommends export compliance and intellectual property protection countermeasures. He is an accomplished writer of non-fiction books, novels and periodicals. Jeff is an expert in security and has written many security books including: "Insider's Guide to Security Clearances" and "DoD Security Clearances and Contracts Guidebook", "ISP Certification-The Industrial Security Professional Exam Manual", and NISPOM/FSO Training".

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