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| NISPOM With Change 1 Available at www.RedBikePublishing.com |
Well,
it’s here, just this side of six years after the release; Change 1 to the
National Industrial Security Program Operating Manual. Over the recent three
years there have been draft versions of NISPOM submitted, reviewed and resubmitted, but
for the most part the NISPOM has remained unchanged. A testimony to an
efficient product or policy? Could be. Too many higher level executive order
and policy changes? Maybe.
Though
there has not been a major re-write or even revision, Change 1 does incorporate
some important considerations, to include both domestic and international
concerns. As programs and research efforts expand globally, Facility security
officers (FSO) should know how to protect it in house and train cleared employees
to do the same; this includes new markings and storage requirements.
The
major revision is in NISPOM
Chapter 4, Classification Markings, Paragraph 1, Derivative Classification. Primarily,
changes clarify the definition of derivative classification, the process of
derivative classification and the training required.
The
definition of derivative information is now more concise:
Contractor personnel make derivative
classification decisions when they incorporate, paraphrase, restate, or
generate in new form, information that is already classified; then mark the
newly developed material consistently with the classification markings that
apply to the source information.
And later clarified
in Paragraph 4-102b:
Derivative classification includes the
classification of information based on guidance, which may be either a source
document or classification guide. The duplication or reproduction of existing classified
information is not derivative classification.
But
to better understand derivative classification, let’s compare it with original
classification; at least for a baseline definition. Original classification
occurs when information meets classification criteria as described in Executive
Order 13526, “Classified National Security Information”. Classification is
usually considered as events, programs or missions develop. The product of
original classification is a security classification guide, classification
markings and the DD
Form 254.
Derivative
classified information occurs when information is used that has already been
determined classified and is provided in a new product such as report, item, or
event. Information is already known to be classified. In this case a security
classification guide or previously classified information is used to identify
the existing classification level. The product of derivative classification are
properly marked classified products.
A
very simplistic way for contractors to apply this is to remember that
contractors carry over classification markings on existing classified
information. It’s the federal government’s responsibility to assign original
classification. That means appointing an original classification authority to
determine classification levels where none have previously existed.
Another
timely clarification is that duplicating classified information by any means is
not derivative classification. It’s just copying and creating another of the
same. A new product or application using existing classification fits the
description.
- Writing a document using classified information from other classified sources; derivative.
- Using classified specs identified in an SCG to create a product; derivative
- A person in a designated government position determining classification levels based on criteria in EO 13526; original
- Making copies of a classified document; copying
This
clarification in NISPOM is necessary and just what FSOs need to complete their
education and perform better under the NISP. Understanding roles and
limitations leads to more informed cleared employees and a security program to
provide excellent protection to classified information.
The
new NISPOM with Change 1, March 28, 2013 is available at Red Bike Publishing.
See it here. For
more information on training cleared employees and working classified contracts
see DoD
Security Clearance and Contracts Guidebook.
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,and The NISPOM
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