Tuesday, March 8, 2011

Cleared Contractor Reporting Requirements

From "Insider's Guide to Security Clearances"
Reporting Security Violations


Providing required reports to the authorized persons or agency contributes to reducing the impact of the potential security violation, compromise or suspected compromise. Cleared employees should understand to whom and what to report. The sooner the report is issued and the more details given, the more can be done to prevent or mitigate damage to national security.

Cleared employees should be trained to report events affecting the facility security clearance or personnel security clearances. These events include threats to the security of classified information or the fact that classified information has been lost or compromised. All cleared employees should be trained how to submit reportable information internally to the FSO. Additionally, FSOs have reporting channels through DSS and the Federal Bureau of Investigation (FBI). The quicker information gets to the proper reporting authority, the sooner it can be address and damage can be prevented or mitigated.

Reports to the FBI

Contractors report to the FBI when they become aware of any of the following occasions:

Espionage – Persons attempting to obtain national defense, proprietary or other sensitive information without the proper permission or clearance and need to know.

Sabotage – Persons causing damage, diversion, destruction or other activity resulting in an opponent becoming less effective.

Terrorism – These are acts to create havoc and shock in order to advance goals of ideology, money, or furtherance of political agendas.

Subversion – Acts to overthrow forms of Government authority.

Reports to DSS

DSS is more able to address other issues impacting a contractor’s facility and personnel security clearances. FSOs should train cleared employee to submit information that adversely impacts the ability of a person or facility to protect classified information. More specifically, reports submitted to DSS include:

Adverse information – involves reports about a contractor or federal cleared employee that indicate that they may not be able to properly protect classified information. Adverse information topics include criteria found in the investigation/adjudication process:

• Allegiance to the United States

• Foreign preference

• Foreign influence

• Sexual behavior

• Personal conduct

• Financial considerations.

• Alcohol consumption

• Drug involvement

• Psychological conditions

• Criminal conduct

• Handling protected information

• Outside activities

• Use of Information Technology Systems

Any activity demonstrating a violation of any of the 13 investigation criteria could define reportable adverse information. When cleared employees display any characteristics that could imply inability to protect classified material or make them vulnerable to recruitment, they should report that information.

Suspicious contacts – Any attempt by any individual to obtain unauthorized access to classified information.

Change in Status – Agencies and contractors should report any changes in status of cleared employees. These reportable changes include: name, marital status, citizenship or termination of employment.

Citizenship by naturalization – When necessary, Non-U.S. employees can be granted Limited Access Authorization.

Refusal to sign the SF 312 - Refusing the sign the SF 312 communicates lack of agreement to protect classified material or lack of training

A change affecting the contractor facility clearance – The defense contractor is granted a clearance based in part on their ability to safeguard classified information.

Changes in storage capability – These changes include improvements or additions to the security program which raises the protection level or implement changes that deteriorate the protection level.

Inability to protect classified material – Anything preventing a cleared facility from being able to protect classified information should be reported.

Unauthorized receipt of classified material – Any classified information delivered from the cleared facility to an uncleared facility or person or classified information received without a contractual relationship should be reported.

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