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 Guidebook) Any 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.
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