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

Monday, March 30, 2015

NISPOM Based Certification Questions.

Try these NISPOM based questions. They could complement your ISP Certification or SPeD certification study. See how you do.

1. Disclosure of U.S. Information to Foreign Governments is
guided by the:
a. CSA
b. GCA 
c. COR
d. ITAR
e. Exports Agreements

2. What is the required FCL a contractor facility must have if in possession of only NATO RESTRICTED information?
a. TOP SECRET
b. SECRET
c. CONFIDENTIAL
d. RESTRICTED
e. None of the Above

3. Which of the following are eligibility requirements a company must meet before it can be processed for an FCL?
a. The company must be an organization of at least 25
people
b. The company must have a desire for classified access
c. The company must have a reputation for integrity
d. The company must make its bottom line for three
consecutive quarters
e. The company is the only entity that can perform the work

4. When can a contractor disclose classified information to
another contractor?
a. Furtherance of contract 
b. Furtherance of business development
c. When directed by FSO
d. When directed by CSA
e. Just as long as other contractor is cleared




Scroll down for answers:






1. Disclosure of U.S. Information to Foreign Governments is
guided by the:
a. CSA
b. GCA (NISPOM 10-200)
c. COR
d. ITAR
e. Exports Agreements

2. What is the required FCL a contractor facility must have if in possession of only NATO RESTRICTED information?
a. TOP SECRET
b. SECRET
c. CONFIDENTIAL
d. RESTRICTED
e. None of the Above (NISPOM 10-702)

3. Which of the following are eligibility requirements a company must meet before it can be processed for an FCL?
a. The company must be an organization of at least 25
people
b. The company must have a desire for classified access
c. The company must have a reputation for integrity
(NISPOM 2-102c)
d. The company must make its bottom line for three
consecutive quarters
e. The company is the only entity that can perform the work

4. When can a contractor disclose classified information to
another contractor?
a. Furtherance of contract (NISPOM 5-509)
b. Furtherance of business development
c. When directed by FSO
d. When directed by CSA
e. Just as long as other contractor is cleared



FSOs and End of Day Security Checks



This section continues our discussion of the DSS’ The Self-Inspection Handbook for NISP Contractors. Now we are in Section M Classified Storage. So, here is the question:

5-102a Is there a system of security checks at the close of each working day to ensure that classified material is secured? 

Security checks help, period. However, they are only as good as the purpose they serve. Many times these checks are just a list of mundane actions forced on an employee to complete before they go home. Many times the checks are performed by employees on a duty roster pulling the job for a week at a time leaving at various times of the day. 

The real intent is to ensure classified information is locked up and inaccessible by uncleared personnel and those without need to know. Desktops, trash bins, printers, copiers are checked to ensure classified information has not been left unsecured.

GSA approved security containers are checked and initialed to ensure they are closed and locked properly. Closed area locks are checked as well as security alarms. The list goes on to ensure all situations where classified information has previously been available  has been secured and compromise has been mitigated. 

Now, security checks are important and so is the responsible party doing the checking. Often, any employee with a clearance is given the "duty". However, diligence should be made to ensure the checks are made at the right time. 

Here's a little hint at inherent, but rarely pondered danger. 

The end of day checks should be performed at the end of the duty day and not the end of the day for the employee on duty.

Did you get the play on words? 

The danger with a duty roster in many cases is that some employees performing the end of the day checks may not normally stay until the end of the duty day. Where the employee might leave at 3 pm, other employees might not leave until 5 pm. The two hour time difference is simply not providing the proper mitigation.

Within that two hours, an employee could reenter a closed area, open a security container, have a classified meeting, and etc. Life goes on after the designated end of day checker goes home.

Out side the box ideas: 

1. Have employees performing the duty alter their work schedule accordingly. Make sure that someone is covering down on the end of day checks at the end of the day.
Some even go so far as to put safety and housekeeping information as well.

2. Have a last call for classified information. If the normal duty day ends at 5 pm, ensure all classified information is secured by 4:45. Of course there are emergencies and case by case issues that can be dealt with upon request.

3. Assign end of day checks to only employees who leave at the end of the day. Build in additional "beginning of the day" performance measures for employees who arrive earlier in the day.

Another common problem is using the end of day check for safety and house cleaning. Re-think a separate check list for those issues. Employees should be focusing efforts on securing classified information, not ensuring the coffee pot is turned off.

Hang on to those end of day check lists. DSS will want to see them during the review. Be sure to check for them during your self-inspection.

We've covered this discussion in depth in 2012 and 2013 posts.  As a reminder here are the links for further discussion of this important issue:

http://dodsecurity.blogspot.com/2013/03/traditional-security-tools-in-unique.html

http://dodsecurity.blogspot.com/2010/11/storing-classified-information-keeps.html#links

Though not required by NISPOM, government forms are available on line for use or just to serve as model in the strengthening of security programs. Companies are free to use these forms or create their own. The government forms are available online. One such form is the Activity Security Check List, Standard Form 701. Again, unless the contract or Government agency requires the use of a specific format, the company is free to adapt their own version.

Consider visiting Red Bike Publishing for training that you can download and present to cleared employees as well as present to DSS during the annual review.


GSA Security Container Magnets
http://www.redbikepublishing.com/book/magnet/

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".