Prior to travel, a cleared employee should have a good understanding of their responsibilities to protect sensitive information. This can include classified or unclassified information and military or dual use information. For defense contractors, protection of classified information is addressed in the National Industrial Security Program Operating Manual (NISPOM), military technical data is covered by the International Traffic in Arms Regulation (ITAR) and dual use technical data is protected under the Export Administration Regulation (EAR).
Facility Security Officers (FSOs) and Exports Compliance Officers can train their travelling employees to protect technical and help them accept the responsibly to protect themselves, classified information, and technical information. Preparation for travel can be covered in 5 steps:
1. Ensure cleared employees notify their security office of all foreign business well in advance of a proposed travel date. This will prepare the employee and the supporting staff to adequately support the visit. If technical exchange is necessary, a year’s notice may be necessary to acquire the appropriate licenses and TAAs.
2. Travelers should understand how technical data can be transferred inadvertently or purposefully through a written note, viewing a computer screen, conducting seminars and etc. Make sure employees know they are only authorized to communicate technical data through a license and or TAA.
3. Employees should know the boundaries in advance before sharing any technical information with non US persons. Help them understand the provisos of licenses and TAAs and exactly what they are allowed to disclose.
4. Coordinate with the IT department (or someone offering these services) provides a computer only equipped with permitted information (according to licenses and TAAs). A sanitized computer reduces the threat of exports violations or theft of economic or corporate data. Keep all products and information that could lead to export violations or the release of proprietary data close at hand.
5. Teach employees to practice good physical safety and security. A good practice is for employees to conduct themselves as professionals at all times and know they represent the company. For safety, they might consider coordinating closely with their hosts to find the best places to eat and shop. The state department has a great website employees can visit to prepare for travel (www.state.gove). Anyone traveling abroad should familiarize themselves with the site and use it to become an informed international traveler.
Jeffrey W. Bennett, ISP is the owner of Red Bike Publishing Red Bike Publishing . 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", "ISP Certification-The Industrial Security Professional Exam Manual", and NISPOM/FSO Training" 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
Information for the CIO, CSO, FSO, ISSO and other security professionals. Understanding NISPOM and ITAR compliance is tough. With over 12,000 cleared defense contractors, a majority of those don't have a security staff. We'll hope to help fill the gap. From security clearances to performing on classified contracts, you can find help here.
Monday, October 10, 2011
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