Tuesday, May 26, 2015

DSS Self-Inspection for Cleared Contractors-Inspection of Personal Effects

We are continuing our analysis of the DSS’ The Self-Inspection Handbook for NISP Contractors to determine requirements and best practices for meeting them.

Since Section M has multiple inspection points, we have broken them up into individual articles.  This update addresses using warning signs and inspections to ensure authorized introduction and removal of classified information. 

Question 5-103: Are signs posted at all entries and exits warning that anyone entering or departing is subject to an inspection of their personal effects?

 NISPOM 5-103 states “…The fact that persons who enter or depart the facility are subject to an inspection of their personal effects shall be conspicuously posted at all pertinent entries and exits.”

Security through Denial, Deterrence, and Detection

This notification is designed to both serve as a warning or deterrent to unauthorized introduction or removal of classified information. The actual inspection of personal effects serve denial and detection purposes.

These inspections and postings of signs should occur in strategic locations. The FSO should consider using them where they make the most sense, where they support classified contracts, and where they enhance job performance and not become a burden to the enterprise or national industrial security program. For example, the inspections should occur where access to classified material is more likely and not where access to classified material is not likely or remote at the very least. The inspections should occur in such a manner as to not impede traffic flow or classified performance.

Additionally, these inspections should be random and limited to business items and not personal items such as purses, wallets or undergarments. In all cases, coordinate with human resources and seek legal advice before implementing the program.

The Danger

The uncontrolled introduction of classified information can cause security violations and compromise of classified material.

The FSO should create company policy demonstrating how classified material is introduced and removed properly from the company and train cleared employees on the procedures. The intent is to establish an environment where all employees have a clear understanding of policy.

For example, the FSO can ensure that classified deliveries are to be made through the cleared contractor’s security department and not directly to the cleared employees. One trigger point to plan the reception of classified information is upon notification of a classified visit request.

Best Practices

At a minimum, ensure inspection signs are posted at all employee and visitor entries and exits. This broad scope captures the entire building access and egress possibilities where classified information can be introduced or removed.

Next, filter the flow of visitors. A follow on method of controlling the introduction of classified information is to restrict or direct the flow of visitor traffic into and out of the cleared facility. Cleared facilities may have multiple entry points and visitors should have access to only designated entry points. To help with maintaining control of the classified environment, FSO’s can employ information technology or human controls to direct pedestrian traffic into their facility. Access controls with biometric, pin card or data card access provide an excellent opportunity to flow all traffic through an authorized area.

When budget does not permit the purchase or subscription to expensive information technology, high security hardware such as door locks and crash bars are adequate to prevent entry into unauthorized doors.

When controls are in place, pedestrian traffic should file through a reception area where visitors are received warmly and reminded to check in with the security or reception desk for all classified deliveries.

Document Compliance and Best Practices

The VALIDATION should include, but are not limited to corporate policy letters, inventory of where inspection signs are posted, transcripts or slides from security awareness training, attendance rosters from training.

Authorized classified material should flow unimpeded to and from where classified work is performed. Security efforts should facilitate the authorized introduction of classified information, while denying, deterring, and detecting unauthorized attempts at introduction or removal. FSOs should ensure a strong security posture and train the force to work within the required environment.

For more information, see DoD Security Clearance and Contracts Guidebook.

Sunday, May 17, 2015

Self Inspection Handbook and The FSO-Classified Storage

This section continues our discussion of the DSS’ The Self-Inspection Handbook for NISP Contractors. We are still addressing Section M, classified storage. This update addresses perimeter controls that deter and detect unauthorized removal and introduction of classified information.

5-103 Is a system of perimeter controls maintained to deter or detect unauthorized introduction or removal of classified information from the facility? If so, when, where, and how are these being implemented?

According to NISPOM 5-103. Perimeter Controls. Contractors authorized to store classified material shall establish and maintain a system to deter and detect unauthorized introduction or removal of classified material from their facility.

Traceability is an important part of protecting classified information. There is plenty of allusion in industry best practices, NISPOM, and training that only TOP SECRET information is to be accountable. There is tremendous direction for application of accountability for TOP SECRET information, including the designation of a TOP SECRET Control Officer or TSCO. This position also has detailed responsibilities of how to receive, account for, trace, destroy, and remove the information that could cause extremely grave damage to national security if disclosed to uncleared and persons without need to know.

But what about SECRET and CONFIDENTIAL? Shouldn’t those also be accounted for? 

Technically no.

 Though many FSOs are actively protecting classified information in this manner, practitioners must be specific while communicating the requirements. I learned this lesson early when writing DoD Security Clearance and Contracts Guidebook. I had sent it out for review, editing, and comments from leaders in the industry. In the earlier version I wrote that “all classified information must be accounted for”. After all, I felt it was a safe assumption to write for a book about how to protect classified information. Language in the NISPOM suggests that classified information must be produced in a reasonable amount of time. Also, classified information should be reported if disclosed in an authorized manner, compromised, stolen or lost.

So how could you prove it was lost, stolen or otherwise safe unless you know what you have and how much of it is there? That sounds like accountability to me.

Though the reviewer and expert in the field expressed, rather emphatically, that I could not write such language but that the contractor could use an information management system to keep up with classified information. For the final version of the book, we agreed on using information management instead of accountability, but I still feel that some TS protection measures, accountability and traceability, should be practiced to protect all classified information.

How can TSCO requirements be applied to all classified information?

Without creating a great resource burden to the enterprise, the FSO can manage classified information responsibly and protect classified information by tracking and documenting what is stored on site, in what format, and how many copies there are. Additionally, contractors should discourage the introduction or removal of classified material without proper authority. A best practice includes centrally storing all classified information, receipting classified information, documenting the information in an information management system (IMS) such as SIMSSOFTWARE, and controlling the use of the classified information.

Commercially available IMS uses information technology to create a detailed database that helps FSOs track classified material through many dispositions from receipt, inventory requirements and final disposition. Some produce receipts, tie to a barcode scanner, report statistical data that can help determine use and much more. For example, if an inventory reveals missing classified information, the database can provide valuable information to help reconstruct the classified information’s history.

However, this doesn’t always have to be an expensive software or network endeavor. Some inexpensive and free solutions are available. I once produced my classified document library system on a printed Microsoft Excel spreadsheet to DSS' satisfaction.

Technology also exists to create a classified library or database and associating it with scanner software. Barcodes can be printed and applied to classified items for scanning. If an item is destroyed, shipped, filed, loaned or returned, it can be scanned and the status updated. These databases provide reports identifying when and where the barcode on the classified document was scanned and the last disposition. 

The FSO can use the technology to research dates, methods of receipt, contract number, assigned document number, assigned barcode, title, classification, copy number, location, and name of the receiver. For more information, see our blog post Information Management Systems.  http://dodsecurity.blogspot.com/2011/04/information-management-systems.html#.VVY_k-lFB9A

FSOs should establish perimeter controls to deter or detect unauthorized introduction or removal of classified information from the facility. The NISPOM encourages the use of technology to assist, however, this does not need to be an expensive endeavor. Technology could be as simple as a spreadsheet or an old school library checkout system.

FSOs should document whichever processes used and provide for self-inspections and DSS reviews. Security awareness training, posters, flyers, standard operating procedures, policy, practices and technology should be available for validation.

For more information, see our NISPOM training subjects or DoD Security Clearance and Contract Guidebook.

Jeff is an accomplished writer of non-fiction books, novels and periodicals. He also owns Red bike Publishing. Published books include: "Get Rich in a Niche-Insider's Guide to Self Publishing in a Specialized Industry" and "Commitment-A Novel". 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". See Red Bike Publishing for print copies of: Army Leadership The Ranger Handbook The Army Physical Readiness Manual Drill and Ceremonies The ITAR The NISPOM