Sunday, June 3, 2018

Classified Destruction

Cleared Defense Contractors (CDC) should operate security programs designed to protect classified information from receipt to disposition. This article addresses the safe and secure destruction of classified information. The article is based on the Self Inspection Handbook for NISP Contractors, and uses the format to walk through the self-inspection criteria. We begin the topic question, the NISPOM reference, an explanation of requirements, and finally how to inspect compliance.

Topic Question(s):
Is retention authority requested as required? 5-701, 5-702
Is classified material destroyed as soon as possible after it has served its purpose? 5-704
Is an effective method of destruction employed that meets NISPOM standards? 5-705
Is classified material destroyed by appropriately cleared authorized personnel who fully understand their responsibilities? (may include appropriately cleared subcontractor personnel) 5-706
Is classified waste properly safeguarded until its timely destruction? 5-708

NISPOM Reference(s):

NISPOM 5-701. Retention of Classified Material

5-704. Destruction

5-705. Methods of Destruction

5-706. Witness to Destruction

5-707. Destruction Records

5-708. Classified Waste


Classified Retention NISPOM 5-701
Per NISPOM guidance, contractors may maintain classified information beyond two years provided they have authorization. Though the classified contract may have terminated, there may be relevant work that the contractor must perform and with adequate justification to warrant approval. This approval is not something the contractor can assume, but authority must be pursued by the contractor. This approval is sought through an extension request to the GCA or through the prime contractor. Upon approval, the issuing authority should submit a final DD Form 254 to reflect the change.
Classified Destruction NISPOM 5-704
Where retention is not necessary or not permitted by the GCA, classified information must be destroyed or returned as soon as it has served its purpose. This destruction should be made a priority and executed as soon as possible. The Facility Security Officer is key in developing a system to evaluate the classified information to determine disposition. Where destruction is required, it should only be conducted using approved methods.
Methods of Destruction 5-705
There are many approved methods for destroying classified material based on its composition. For example, paper products can be shredded, burned, pulped or pulverized. Once a method is employed the destroyed material should be evaluated to ensure that nothing legible (visual or otherwise) exists. This means that if classified paper documents are burned in a pit or barrel for example, the ashes should be stirred regularly to ensure all the paper has been burned. One might be surprised how resilient paper can be when grouped in booklet form. Additionally, the shredding of classified information should only be accomplished using NSA equipment approved for the destruction of information by classification level.
Commercial enterprises and vendors also provide destruction services. Burn facilities operate at temperatures hot enough to burn paper in bulk, computers and hard drives and other medial. Shredding services exist that have mobile NSA approved shredders. However, DSS approval should be acquired prior to using such services.
Witness to Destruction 5-706
Two people are required to destroy and document the destruction of TOP SECRET information. Both parties should sign all receipts and personally observe the method of destruction. The destruction of SECRET and CONFIDENTIAL on the other hand only require one person.
Classified Destruction Documentation 5-707
The destruction records for TOP SECRET information should be maintained for two years. Just as TOP SECRET information is introduced in inventory, it should exit the same way. Though not required for SECRET and below, it is a good practice to maintain destruction records for SECRET and CONFIDENTIAL as well. This documentation helps determine the disposition of classified information during inspections and inventories. A good Information Management System such as Sims Software can perform these tracing and accountability tasks.
Classified Waste 5-708
Classified information should be destroyed the same day as it is removed from the cleared facility. When awaiting destruction, it should be treated at the level of classification. Collection boxes, bags and etc. should have classification markings, storage areas should be guarded, and the classified waste should be prepared for transmission by the same methods as all other classified information as described in NISPOM. Wrappings, receipt, escort, and etc. should be employed at all stages of transport from origin to destruction. Everything that cleared employees have learned about safeguarding classified information and other NISPOM training topics should be applied here. For example, where classified information is scheduled for destruction off the cleared contractor facility property, it should be removed from classified holdings, double wrapped and marked properly, escorted while in transport, and the entire journey to the destruction site. The destruction should be observed and destruction receipts / certificates annotated
Steps for destroying classified information:
1. Evaluate the contracts, work products, and DD Form 254s for any disposition instructions.
2. Determine which classified information should be destroyed.
3. Determine destruction method based on format of the classified information.
4. Remove classified information from inventory and prepare for destruction
a. annotate removal in information management systems
b. gather information and wrap and mark packages for removal (double wrap, bag, classified markings, etc.)
5. Develop transportation plan, identify escorts and or destruction personnel
6. Rehearse transportation plan and notify DSS if removing from facility. Ensure DSS approval if destroying classified information at commercial facilities.
7. Provide NISPOM Training such as Derivative Classifier Training, Insider Threat Training, and Security Awareness Training to ensure destruction process is accomplished per NISPOM standards.
6. Complete destruction receipts / certificates as required

1. Provide classified holdings review schedule (information management system or other listing)
2. Provide list of classified contract subject matter experts and those who have validated classified disposition decisions (trained by FSO or representative)
3.  Provide DSS approvals for destruction methodologies, transportation plans, and commercial destruction facilities
4.  Provide destruction plan for disposition of classified information by format.

5.  Produce destruction certificates / receipts

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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