Certain
topics should be provided during TOP SECRET (TS) Personnel
Security Clearance (PCL)
initial security briefings and annual follow up training to complete the
holder’s education. After all, the higher certification lends to tougher
standards and more accountability. Full and complete training will enhance
national security by empowering the holder to protect information
appropriately.
Clearance
A
Single Scope Background Investigation (SSBI) is necessary to ensure an employee
is trustworthy and can be awarded a TOP SECRET Clearance. The SSBI investigates
a subject’s periods of employment, residences and education institutions
attended. Other areas subject to investigation include searching criminal and
financial records. The investigators may contact those with social and
professional knowledge of the applicant, and divorced spouses.
Access
Though the SSBI for the final TOP SECRET
clearance will take up to a year or longer, employees with a clean record can
still have access to TOP SECRET information. This is made possible through a
temporary or interim clearance as long as there is no immediate evidence of
adverse information. The interim TOP SECRET clearance is the approval allowing
the employee to have access to TOP SECRET information, Restricted Data, NATO
Information, and Communication Security information at the SECRET and CONFIDENTIAL
level. Access to compartmentalized and program information is an altogether
different process based on the SSBI, but final access determination is made by
the granting authority.
Markings
A
designated original classification authority makes classification
determinations based on demonstration of the level of damage to national
security per guidelines found in Executive Order 13526- Classified National Security Information. The OCA classifies
information meeting requirements as CONFIDENTIAL, SECRET or TOP SECRET,
depending on whether potential impact of compromise is rated as: damage, severe
damage or extremely grave damage in that order.
Classified
information should be conspicuously marked on the top and bottom of object
surface areas. For documents, they should be applied to the top and bottom of
each page, on portions, graphs, illustrations and photographs. Markings include
not only the classification level, but also the CLASSIFIED BY: information
lines. Coversheets should be applied when removed from storage. Hardware labels
should be color coded to indicate classification level; orange for TOP SECRET,
red for SECRET, blue for CONFIDENTIAL, and green for UNCLASSIFIED.
Countermeasures
Since the unauthorized disclosure of TOP
SECRET information could cause extremely grave damage to national security, the
National Industrial
Security Program Operating Manual (NISPOM), DoD Manual 5200.01 and other
applicable agency regulations require users to implement more stringent countermeasures.
These include denying access through accountability, infrastructure and
information assurance. These countermeasures are applied as long as the
information remains at the TS level or until downgraded, declassified or
destroyed.
Accountability
Cleared contractors that are granted a TS
Facility Clearance (FCL) and are authorized to maintain a TS inventory are
required to appoint a TOP SECRET control official (TSCO). All transactions involving TS require access
and accountability records. This requirement is for the lifecycle of the TS
information and includes reception, transmission, destruction and storage. Additionally, the contractor is required to
perform an annual accountability inventory unless a waiver for the requirement
is on file.
For example, all TOP SECRET information
and material is documented by numbering them in a series. This allows the
contractor and owner of the classified information to know exactly how many
there are and what to look for during inventory. Any incoming material, copies
generated or faxes transmitted are documented with the number and accounted for
by the TOP SECRET control official using the numbering and a continuous receipt
system.
Receipt
All classified material should be delivered only to
the persons authorized for receipt. In the case of TOP SECRET material, that
person is the TSCO. Cleared contractors should implement practices that ensure
that classified
material, regardless of delivery method, is received directly by authorized
personnel. Once received, the receiver should examine the classified
information for evidence of tampering and compare the contents with the
receipt. Once received and inspection completed, the TSCO will sign and return
the receipts to the sender, closing out the sender’s requirements to account
for that TOP SECRET item.
Storage
After documenting the TOP SECRET material’s arrival,
the TSCO is responsible for safeguarding it in a GSA-approved security
container, an approved vault, or an approved closed area with supplemental
controls. These controls include:
a. Intrusion Detection Systems as
described in the NISPOM Chapter 5, Section 9 (rather lengthy, so study up).
Tamper alarms are necessary for TOP SECRET storage.
b. Cleared contractors with security
guards approved as supplemental protection prior to January 1, 1995, can
continue to use them. In that case, they are required to patrol every 2 hours
for TOP SECRET.
c. In
some cases the supplemental controls may not be required. For example, where
the CSA determines that the GSA approved security containers and approved vaults
are in facilities with security in depth and they are secured with a locking
mechanism meeting Federal Specification FF-L-2740.
TOP SECRET Transmission Outside a
Facility. The cleared
contractor is not authorized to transmit any TOP SECRET material outside of
the cleared facility. Only the government contracting activity that provided
authorization to work with the TOP SECRET material can authorize the
transmission with written permission. Employees should always go through the
Facility Security Officer and TSCO before attempting to transmit any TOP SECRET
material. For two reasons; to ensure written authorization is on hand, and to
account for the status of all existing or to be reproduced TOP SECRET material.
When written authorization is provided, TOP
SECRET material may be transmitted by the following methods within and directly
between the United States and its territorial areas.
a. The Defense Courier Service.
b. A designated courier or escort cleared
for access to TOP SECRET information.
c. By electrical means over government cognizant
security agency-approved secured communications security circuits, that meets
NISPOM standards, the telecommunications security provisions of the contract,
or as otherwise authorized by the government contracting activity.
Transmission of
TOP SECRET material outside the United States and its territorial areas can be
accomplished with the
Defense Courier Service, Department of State Courier System, or a courier
service authorized by the government contracting activity.
Reproduction
The TSCO
should be involved with any activity involving TOP SECRET material including reproduction.
Again, not only will they ensure that it is authorized and/or contract related,
but they will assign the control number for the new document and account and
receipt all activities including its creation, storage, transmission or
destruction. These records should be
maintained for at least two years.
Retention
According to the NISPOM, cleared contractors
can usually retain contract related classified material for a period of 2 years
after completion of the contract unless otherwise directed by the government
contracting activity. But what if the classified material is still needed
beyond that time? The contractor should ask for and receive written
authorization identifying the classified information they wish to retain. TOP
SECRET material is requested in a list of specific documents or if permitted by
the government contracting activity, by subject matter and approximate number
of documents.
Destruction
Records.
As with other lifecycle activities concerning TOP
SECRET material, destruction should be documented in a receipt and with a clear
indication of what material was destroyed, by whom, the date, and signed by the
individual and witness. These destruction receipts should be on hand for two
years. The TSCO and those authorized to destroy the material are required
to know, through their personal knowledge, that such material was destroyed.
There
are many responsibilities required of those in charge of classified
information. Make sure you know what those responsibilities are. Failure to
follow guidelines and national security policy could cause your company to lose
contracts. Excelling in security responsibilities leads to award winning
performance. For career and performance enhancement ideas, visit www.redbikepublishing.com
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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