Sunday, July 19, 2015

Correcting How Hollywood Portrays Cleared Contractors

© Mhieronimus | Dreamstime.com - Hollywood Sign Photo


I recently had the fortune of being on a radio talk show for security professionals. This show has an audience of approximately 10,000 listeners with varied corporate and law enforcement security experience. However, very few of the audience members work in the defense contractor industry or under the National Industrial Security Program.  

I had wanted to be a guest on the show since I had heard about it earlier this year. I had found them in a google search and discovered that they had covered the National Industrial Security Program (NISP) with some college students. The conversation, though serious, proved light as the talk show hosts engaged the guests and audience in an entertaining manner. They actually made NISP seem very interesting.

I had to ask myself, "When was the last time a security briefing, training, or seminar was engaging, serious, and comical at the same time?"

That was the question on my mind as I listened to the interview. The students did a great job talking about the security clearance topics. The most entertaining part of the show was listening to assumptions the hosts had about security clearances and protecting classified information. I thought I could help with those concerns and volunteered to be on the show. Like most good security managers, the show vetted Red Bike Publishing, our books, and credentials and decided to invite me on the show.

I went in with the understanding that this was their show and I was a guest. I probably would not get much time to speak as they did have a show to do. I felt my job was to complement the show by engaging their comments, concerns, and issues the best I could from a NISP point of view. I also realized this was a good opportunity to educate a broader security audience.

The concerns they shared showed a fundamental misunderstanding of how government contracting, classified contracts, andsecurity clearances work. This fundamental misunderstanding is often shared by those not in the know and often manifests in the movies and TV shows we watch today. For example, on an episode of Hawaii Five-0, a husband had stolen classified information off his wife's laptop computer at home while she slept. What?

Without fully understanding the NISP, the general public could draw conclusions that cleared employees keep classified information on laptops and bring them home at night. The Hawaii Five-0 character stated words to the effect of, "he broke into her laptop and stole her security clearance". Wait, what?.

You may have noticed similar discrepancies, but that's ok. It's Hollywood where monsters, fairies, and magic exists. Additionally, the nightmarish mishandling of classified information in the hands of incompetent people burdened by an overbearing bureaucrat is also wrongly portrayed. Not to forget also, most Hollywood movies feature defense contractors as evil and villainous, but we know different.

In spite of the Hollywood nightmare, cleared employees are trained to understand how the NISP works and how classified information is really protected.

Similar misunderstandings revealed themselves during the radio show. Here are some question topics that arose and that many FSOs and security managers may face. How would you have responded?

1. Wouldn't it make more sense to clear everyone to the TOP SECRET level and protect everything at TOP SECRET? 

This is the assumption that all classified information CONFIDENTIAL through TOP SECRET should be treated as TOP SECRET.

2. When private companies are working on their classified products, who knows how it is protected and if there is enough protection? 

This is the assumption that classified information is generated by everyone and there is on oversight by anyone. This also discounts the government contracting process.

3. Bad guys are constantly attacking our computers and taking our classified information

This assumes that classified information is processed on open computers and networks and takes us back to the Hawaii Five-0 scenario.

4. People with security clearances are doing what they want with no oversight

This assumes that the security clearance investigation, whole person concept adjudication, and continuous evaluation process do not exist.

There were so many other issues, too many to cover for this article.

As I encountered each of the obstacles, I began to weave a story of how the NISP worked as the hero to ease their fight the monsters of bad security management and our "endangered" secrets. I began by explaining the following: government contracts, six step OCA process, security classification level assignment and notification, markings, DD Forms 254, required initial security briefings, SF312 training, annual security awareness training, NISPOM guidance, derivative classifier training, OPM security clearance investigation process, continuous evaluation, periodic re-investigations, and Defense Security Services education, partnerships, and reviews.  There was not enough time to go into everything, but I used the allotted time to educate and correct their misguided assumptions.

However, these mistaken beliefs are not only shared by Hollywood and the general American public; newly cleared employees may share similar beliefs.

So, how should a facility security officer and cleared employees respond? Would they lambaste the less knowledgeable person, take time to train them, or become frustrated and walk away. 

I've had the opportunity to see all three approaches. The correct and most effective approach is to take the time to train and correct the problem. Next time you engage employees, perform training, or advise a program, be ready for anything, treat the topic with respect and correct the situation.


Tuesday, July 14, 2015

NISPOM Based Questions

Looking for study information for your next SPeD or ISP Certification studies?


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.

Problems
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. 


Saturday, June 27, 2015

FSOs and Emergency Procedures

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 classified information and emergence procedures. 


5-104 Are procedures developed for the safeguarding of classified material during an emergency?

According to NISPOM Paragraph 5-104. Emergency Procedures, 
“Contractors shall develop procedures for safeguarding classified material in emergency situations. The procedures shall be as simple and practical as possible and should be adaptable to any type of emergency that may reasonably arise. Contractors shall promptly report to the CSA any emergency situation that renders the facility incapable of safeguarding classified material.”

An essential element to creating a security program to protect classified information involves not only thwarting spies, thieves, and insiders, but also inadvertent disclosure. This accidental disclosure can cause just as much damage as malicious intent. This, FSOs and cleared defense contractors should be prepared to protect classified information by format and location in the event of an emergency. Emergencies should also be considered by probability and on risk based decision processes.

The facility security officer should conduct an assessment of classified holdings to determine vulnerabilities, threats, and risk to classified information above and beyond what has been determined by the original classification authority and as applies to the National Industrial Security Program Operating Manual (NISPOM).

Since the NISPOM, SCG, Statement of Work, DDForm254 and other guidance dictates how to protect classified information, the FSO should consider forming a team to help determine emergency scenarios that could increase risk to classified information at the enterprise location(s).

It’s important that threats include natural disasters. Next, the threats should be mitigated to ensure that classified information is protected and not compromised, regardless of the emergency event. But remember, human lives come first. So the earlier and better the FSO prepares, the more successful they will be.

Here is an example of how an FSO might conduct a risk assessment. For this example, the following information only applies to emergency situations for information purposes. A genuine risk assessment should consider all scenarios. More scenarios can be found in DoD Security Clearance and Contracts Guidebook.

The 6 step risk assessment process should be used to determine and address risks to classified information. The following is an example of a risk assessment with emergency situations as the focus:

1. Determine assets to be protected.

In this case it’s classified information and controlled unclassified information stored on site. However, for the analysis, consider the classified information by format (hardcopy, softcopy, end item, information in a person’s head, ect.) and location (high bay, closed area, security contain, open storage, SCIF, and etc.)

2. Determine threats to the classified information.

For this situation, FSOs should determine disasters and emergencies that could cause unauthorized disclosure of classified information. Threats should be considered specific to the facility to the assets by format and location. Somethings to consider are workplace injuries, heart attacks, strokes, fire, severe weather, earthquakes, flood, explosions, and anything else that could lead to exposed or lost assets.

3. Assess Vulnerabilities or what can be exploited to get to the classified information specific to your facility.

Vulnerabilities could building set up in low areas, poor construction, location of classified material to emergency services traffic, or things that contribute to emergency situations.

4. Assess Risk to determine threat to vulnerability and determine whether or not baseline countermeasures are effective.

For example, an area approved for open storage has the required alarms and facility construction. However, how effective are these security measures in the event of an emergency. For example, when an employee experiences a heart attack how will that employee be rescued? What happens to classified information that is properly stored on shelves or are on desks, computer screens, or lab tables?

5. Assign countermeasures.

If the security program designed to protect classified information does not protect classified information appropriately, assign additional countermeasures. In the above example, the open storage approved area container is adequate for protecting classified information from intruders, but not authorized entry by uncleared personnel. Additional countermeasures could include assigning escorts for emergency situations, selecting ingress and exit routes, providing emergency situation throw blanket to hide classified information.

6. Determine Residual Risk.

Inspect the countermeasures to see if they truly mitigate the risk. One might have time to cover classified information during a medical emergency, but those countermeasures may not be effective when there is no reaction time. Always consider assigning the countermeasures by situation and asset format and location.

One universal tool that FSOs might find useful is providing an emergency kit back at each location. These kit bags can be assigned to responsible and adequately cleared employees to deploy in emergency situations. However, not at all costs. Human lives should always come first.

Emergency Kit Bags

· Marking supplies (Pen, stamp, preprinted labels, etc)

· Opaque bag or wrapping paper

· Opaque security tape

· Cleared personnel roster

· Classification level coversheets

· Light source

*Suggested contents of emergency kit bags. These bags should be kept up to date and readily available during emergency evacuations.


An FSO should form a team to conduct the risk assessment process. The team should include emergency scenarios among the possibilities of unauthorized disclosure of classified information. The more subject matter expertise, the better. The FSO might enlist the help of cleared employees working in each unique environment, the safety officer, facilities manager, and others to more provide a more complete picture of the environment.

VALIDATION:

Document all actions and make available during annual security review. Actions might include:

· risk assessment process describing each of the six steps

· locations of emergency kit bags

· security training provided to cleared employees

· training provided to designated emergency escorts

· list of approved emergency escorts

· plan to protect classified information during an emergency event

An essential element to creating a security program to protect classified information involves not only thwarting spies, thieves, and insiders, but also inadvertent disclosure. This accidental disclosure can cause just as much damage as malicious intent. This, FSOs and cleared defense contractors should be prepared to protect classified information by format and location in the event of an emergency. Emergencies should also be considered by probability and on risk based decision processes.

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".

The Six Step Risk Assessment Process for Cleared Defense Contractors and FSOs

The facility security officer should conduct an assessment of classified holdings to determine vulnerabilities, threats, and risk to classified information. This risk assessment is above and beyond what has been determined by the original classification authority (OCA) and as applies to the National Industrial Security Program Operating Manual (NISPOM). Where the OCA has determined classification level, the NISPOM provides guidance on how to protect the classified information. 


The mission piece is the defense contractor and how they protect the classified information by format and location. It's not always good enough to rely on NISPOM requirements as the environment may dictate additional countermeasures. For example, SECRET and CONFIDENTIAL information can be approved for storage in a GSA approved container. However, if the defense contractor is in a high crime area, additional physical security measures may be necessary. 

That's where the 6 step risk management process comes in handy. The NISPOM, SCG, Statement of Work, DDForm254 and other guidance recommends minimum protection measures, the FSO should consider forming a team to help determine risk to classified information at the enterprise location(s). The process can be laid out in six steps:

  1. Determine Assets to be Protected-In this case it’s classified information. The FSO might consider expanding the scope to include controlled unclassified information stored on site. However, for the analysis, consider the classified information by format (hardcopy, softcopy, end item, information in a person’s head, ect.) and location (high bay, closed area, security contain, open storage, SCIF, and etc.)
  2. Determine Threats-Threats can include: emergency situations, spies, break ins, insiders, and other environment issues specific to the contractor location.
  3. Assess Vulnerabilities-Understand what can be exploited to get to the classified information specific to your facility. Vulnerabilities could include traffic patterns, limited security staff, lack of seasoned cleared employees, or other weaknesses in the infrastructure or environment.
  4. Assess Risk-Match the threats to the vulnerabilities and determine whether or not baseline security measures are enough. For example, even though classified information is stored in an approved GSA security container, new employees forget to lock the container before leaving the area. In the example, the NISPOM requirements are met to store classified information, but the environment requires more protection.
  5. Assign Countermeasures-If the security program designed to protect classified information does not protect classified information appropriately, assign additional countermeasures. In the above example, the GSA approved container is adequate for protecting classified information, but employees have been forgetting to lock the container while taking short breaks. Additional countermeasures could include; multiple checks from supervisors, conducting additional security awareness training, discipline, and other actions to ensure the risk to classified information is mitigated.
  6. Determine Residual Risk-Inspect the countermeasures to see if they truly mitigate the risk. If the supervisor checks can’t be sustained, then additional countermeasures will have to be implemented. Keep checking until behavior is corrected and risk is mitigated.

The OCA provides the classification level and the contractor is required to protect the classified information assigned. The NISPOM provides the guidance, but that may not be enough. The FSO might consider enterprise specific issues that could require additional countermeasures, conduct risk assessments, and document the effort.


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".

Monday, June 1, 2015

Try these 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. 

1. After receiving classified material, the receiver inventories the contents and inspects the package. Name three items for possible inspection?

2. You have just received a classified package. Upon comparing the contents of the package with the receipt, you notice a misspelled title. What should you do?

3. Who should the FSO or senior security specialist notify in the event of a potential or suspected compromise of classified material?

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. 

Contact Jeff at Editor@redbikepublishing.com to book him at your next event.


Jeff 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".

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.
 


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".

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