Monday, August 31, 2015

NISPOM Based Questions

Try these NISPOM based questions and see how you do. You may find some answers in the NISPOM, but some you might just have to think about. Whether  you are working on NISPOM training, FSO certification, or security awareness training, these questions can help.
1. You are an FSO of a growing defense contractor. One of the executives approaches you about the need for more space to conduct classified work. He is agreeable to implementing your recommendation to use a restricted area and would like you to prepare a security briefing for his team. Prior to your briefing, you conduct the necessary research. Describe the reason for a restricted area and when cleared employees would use a restricted area. Keep in mind access control and storage requirements.

2. You have just sat down to eat lunch and receive a phone call from a cleared employee. She tells you that the security container’s drawers are closed, but the dial on the combination lock has not been engaged. She explains further that according to the SF 702, the container had been locked and checked 20 minutes earlier. She is sure that was “about the time everyone left for lunch.” What would you direct her to do?

3. Your colleagues leave for the day. On their way out, they inform you that you are the last to leave. The facility is authorized to store classified materials. What will you check for prior to leaving?

4. As part of the building project, you are responsible for providing input into the projected classified contracts and the required work space and storage requirements. As you put together a presentation you research the requirements of a much  needed closed area. Describe how a closed area should be constructed.
Who approves the construction requirements?

So how did you do? These questions and more can be found in DoD Security Clearance and Contracts Guidebook, as well as in NISPOM Training. Both resources provide excellent study material that may help with passing the ISP and SPeD certification exams. 

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".

Friday, August 28, 2015

Storing SECRET Classified Information

This article continues the series on the self-inspection guidance found in the Defense Security Service’s Self-Inspection Handbook for NISP Contractors. This article addressed the storage of information classified as SECRET.

5-303, 307 Is all SECRET and Confidential material being stored in GSA- approved security containers, approved vaults, or closed areas?

RESOURCES: ISL 2012-04 GSA Storage Equipment and SECRET Storage under Industrial Security Letters at:

GSA Security Container

SECRET material should be stored in a GSA approved security container or as authorized by the Cognizant Security Agency, in open storage or bin storage in an approved closed area or vault. When SECRET information is approved for open bin storage stored in a closed area, supplemental controls or an approved guard force are required. However NISPOM does not require supplemental controls SECRET stored in a GSA approved container.

Open Shelf or Bin Storage.

NISPOM paragraph 5-306b states that “open shelf or bin storage (hereinafter referred to as “open storage”) of SECRET and CONFIDENTIAL documents in closed areas requires Cognizant Security Agency (CSA) approval”. For the Department of Defense, the CSA is the Defense Security Agency (DSS)

So what is the CSA or DSS considering as demonstrations of compliance?

  • DSS reviews the following prior to providing approval: 
  • Size of the material and storage are-The area is large enough and limited to the space required to store the material or operational requirements. Also, the material may be too large for a standard GSA approved storage container. 
  • Since open storage environments enable visual access to classified information, access to the storage area is limited to those with access and need to know to preclude unauthorized access 
  • As with approved GSA Security Containers, the entrance doors to the open storage area should be secured by built-in GSA-approved electromechanical combination locks that meet Federal Specification FF-L-2740. 
  • SECRET information should be protected by supplemental controls such as an approved intrusion detection system with a 30-minute response time, and any DSS determined security in depth requirements. 

The DSS determined security in depth is based on the following criteria:

  • Perimeter controls that limit access to open storage those with proper clearance and need to know 
  • Access technology that helps recognize access and need to know in cases where the organization is too large for individual or personal recognition 

Safeguarding the SECRET Information

The FSO should design a policy to maintain strict control over classified material. “The NISPOM requires accountability and control of classified information at the TOP SECRET level. However, all material entering the facility, produced, reproduced or entering the facility in any fashion should be brought into possession for control, audit and inventory purposes. Contractors should consider maintaining an information management system (IMS) to protect and control classified information. This provides visibility over the classified material and allows for preventative measures against unauthorized disclosure or identification of security violations”.-DoD Security Clearance and Contracts Guidebook

The FSO should employ a security training and discipline program to compel cleared employees to act as force multipliers increasing security effectiveness. In that role, cleared employees will know to deliver all newly introduced classified material to the FSO for accountability purposes and into the IMS. When security personnel practice good customer service and enforce procedures, good relationships develop making procedures easy to follow as well as rewarding for all employees.

An accountability record or IMS is an excellent tool for controlling classified information introduced into the defense contractor facility. With the accountability record, documents are managed with additional receipting action. Some accountability records track document status from introduction to dissemination on the same record.

Is a GSA Approved Container Really Enough?

Though the NISPOM only requires a GSA approved storage container for protecting information classified as SECRET, the environment may require additional security in depth based on a risk assessment. This risk management process could consider such factors as threat reports, increased threat activity, high crime area, natural disasters, or temporary events such as business closures, increased construction projects, or any other issues requiring increased levels of security. The point is, the NISPOM is a guide, DSS evaluates security plans, but the holder of the classified information is responsible for protecting classified information based on the operating environment.

However, security should be risk based and not dependent on best practices. For example, a defense contractor sufficiently stores SECRET information in a GSA approved container based on an average level of risk. A sister cleared contractor might implement additional controls and increased security in depth based on unique risks in the working environment. Providing an argument that both cleared contractors should protect the classified information with additional protection measures above what is required in NISPOM would ignore the risk management process. If an alarm or guard force is desired, it should be introduced as the result of a thorough risk assessment according to data provided from crime statistics, threat assessments, as identified in this section or as required by contract. Once the data is in, the FSO can address the issues.

In review, information classified as SECRET, should at a minimum be stored in a GSA approved security container. If approved for open storage, then supplemental protections apply. When a risk assessment calls for or the CSA directs security in-depth, document the actions and ensure self-inspections validate compliance and effectiveness.

VALIDATION: Demonstrate knowledge of where SECRET information is stored, GSA container approval documentation, and where GSA approved containers are located throughout the facility. Where security in-depth is applied, document the specific layered and complementary security controls sufficient to deter and detect unauthorized entry and movement within the facility, or specified portion of the facility in which open storage is approved. During self-inspections, document the effectiveness of these controls and report any changes affecting those controls to DSS.

Thursday, August 20, 2015

Storage of TOP SECRET Information

This article continues the topic of the Self-Inspection Handbook for Defense Contractors. The handbook is a tool provided by Defense Security Services for cleared defense contractors to improve security at cleared facilities throughout the National Industrial Security Program. Facility Security Officers at cleared facilities can use the tool to evaluate their own security programs, make improvements, and prepare for the annual security review.

These articles are written to provide security awareness training and help the FSO interpret and apply the NISPOM requirements and evaluate their programs while using the manual as a checklist.

This topic is Storage of TOP SECRET information. 

The question: 5-302 Is TOP SECRET classified information stored only in GSA- approved security containers, approved vaults, or approved Closed Areas with supplemental controls?

The NISPOM requires cleared contractors to maintain accountability and control of TOP SECRET information. Since the unauthorized disclosure or compromise of TOP SECRET information has the potential to cause exceptionally grave damage to national security, the cleared contractor must designate a Top Secret Control Official (TSCO) to ensure accountability and trace-ability of TOP SECRET information.

Though this article and handbook section is about the storage of TOP SECRET information, this article places emphasis on the trace-ability and accountability of TS. This requirement is for the life cycle of the information and includes reception, transmission, destruction and storage. "Each item of TOP SECRET material shall be numbered in series. The copy number shall be placed on TOP SECRET documents and on all associated transaction documents." (NISPOM 5-201c)

For example, the TSO brings TOP SECRET information into accountability and all transactions traced, receipted and recorded as TS items enter, within, and exiting the facility. This accountability and trace-ability can be accomplished with high tech security information management systems such as SIMS Software or with a pencil and paper depending on budget. Further accountability and trace-ability is required for TS information leaving the facility. 
 (DoD Security Clearance and Contracts GuidebookAny incoming material, copies generated, or faxes transmitted are with accounted for by the TSCO using the numbering and a continuous receipt system. The key is to capture security program practices for self-inspection purposes and DSS annual reviews.

TOP SECRET material is to be stored in a GSA approved security container, closed area, approved vault  and supplemental controls such as intrusion detection or an approved guard force. 

Keep informed by reading upcoming articles concerning construction of closed areas and vaults.

VALIDATION: This accountability and trace-ability is required so the validation simply reflects the requirement. Whatever system the TSCO employs to bring TS into accountability and trace the movement of TS should demonstrate compliance. Maintain this trace-ability and accountability documentation, administration information, and a list of security containers, SCIFs, Closed Areas, and etc., where TS is store in a secure area for inspection