Wednesday, March 31, 2021

What Defense Contractors Should Consider Before Appointing FSOs

Becoming a cleared defense contractor (CDC) demands more than just a defense contractor getting a security clearance and performing on classified contracts. It's more to do with, what to do once the clearance is awarded; specifically, protecting classified information. This protection involves physical, classified processing, and information security. It's more than just buying safes, installing access controls and getting employees security clearances. Primarily, the CDC must appoint a Facility Security Officer (FSO) responsible for implementing a program to protect classified information.

To better answer frequently asked questions, I've written several times on the topic of selecting the right Facility Security Officer (FSO) qualifications. According to the National Industrial Security Program Operating Manual (NISPOM), the FSO must be a US Citizen and be cleared to the level of the facility (security) clearance (FCL); period. This provides a lot of room for a cleared facility to figure out how to get the job done. However, in the book, How to Get U.S. Government Contracts and Classified Work, the author identifies what additional qualifications cleared contractors should recognize prior to appointing or hiring the FSO.

Primarily, the FSO should understand how to protect classified information as it relates to the cleared contract, organizational growth, enterprise goals, and NISPOM guidance. The FSO should be able to conduct a risk analysis, express the cost, benefits and impact of supporting a classified contract under the NISPOM requirements and incorporate an environment of cooperation and compliance within the enterprise. Finally, they should be able to influence and compel the senior leaders to make good decisions, support compliance and integrate security into the corporate culture. After all, security violations not only cause damage to national security, but could also impact the organization with loss of contracts. The FSO is pivotal to the successful execution of classified contracts.

In larger cleared contractor organizations the FSO is a full time job held by a department manager or higher. This FSO is supported by a staff of security specialists who may manage classified contract administration, safeguarding classified documents, process classified information on information systems, security clearances and other disciplines. The FSO oversees the entire security program as executed by the competent staff. In a best case scenario, they will report to the senior officer of the organization.

In small business the FSO may be the owner, chief officer, vice president or other senior leader picking up an additional responsibility. This is more of a situation of selecting the most knowledgeable, capable or competent and is usually the best choice. However, these people are already very busy trying to meet cost, scheduling and performance objectives. They may be able to implement and direct a security program to protect classified information, but not the day to day job functions that can pull them away from critical tasks. Jobs such as document control, visit authorization requests, security clearance requests and etc can be delegated to other competent, organized and less busy employees.

When competing for classified contracts, the winning company must be eligible to receive a security clearance. Prior to performing on the contract, they should have a facility security clearance in place and appoint an FSO. The FSO is responsible for the security program, but not necessarily solely responsible for executing the day to day activities. Just as FSOs in large organizations have a staff of employees, the FSO of small organizations should delegate day to day activities to competent cleared employees.

If you need assistance with FSO or security training please contact me. Additionally, we have NISPOM fundamentals training perfect for studying and applying to your CDC facility.

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 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 "How to Get U.S. Government Contracts and Classified Work", "ISP(R) and ISOC Master Exam Prep", and NISPOM/FSO Training".

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