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.
Saturday, December 21, 2019
Facility and Personnel Security Clearances
Facility Security Clearances
A defense contractor is a business entity that has registered to contract with the US Government and has registered with the Central Contractor Registration. A Cleared Defense Contractor (CDC) is the designation of a U.S. Government Contractor facility that has been granted a Facility Clearance, authorizing them to perform on classified contracts. An uncleared defense contractor may bid on a classified contract without possessing an FCL. However, they must be cleared before getting access to the classified contract.
Many defense contractors may find it difficult to find and compete for classified contracts. They may have a unique skill that is hard to identify contracts requiring those skills. But this should not be a showstopper as uncleared defense contractor may partner with or team with an existing CDC for sponsorship. For example, suppose a major defense contractor is performing on a classified contract for engineering support. Their core competencies provide much needed results, but they are in need of a cleared widget maker to make a peripheral piece of hardware. The prime defense contractor is familiar with the excellent work performed by a small uncleared defense contractor. The company does not have a clearance, but the cleared contractor can award a subcontract and sponsor the winning company for a security clearance.
Personnel Security Clearances
Over the years I've been asked the same question: "Can you help me get a security clearance? My answer is both yes and know. If the individual either owns a business and is competing for a classified contract or has a contractual need for a Facility Clearance, then they are eligible to pursue a security clearance. Likewise, if they work for a cleared defense contractor and require a security clearance to perform on classified work, then the answer is yes as well.
The security clearance process begins with awarding the security clearance first to the enterprise and then to the employee. All classified information is provided to newly established Cleared Defense Contractor (CDC) as a result of a classified contract. The cleared employees are granted access based on the contract, security clearance level, and need to know.
The contractor and government have joint responsibilities with the PCL process as they do with the FCL process. When the FCL investigation is initiated, the employees should complete a Questionnaire for National Security Positions, also known as Standard Form (SF 86). Part of the process includes ensuring that the applicants are US Citizens. They should submit the application to the FSO who then submits applications. An investigation is conducted and the central adjudication facility (CAF) makes a determination.
With the FCL established, you are ready to proceed with the process. The PCL process begins with the applicant completing the Questionnaire for National Security Positions or also known as the SF 86. The SF 86 is primarily the part of the process that the applicant can affect the speed of the approval. A properly filled out application form is the key. Incomplete or inaccurate information is the number one cause of clearance delays. Names, addresses, telephone numbers, and dates of birth for relatives should be gathered as background research. Fortunately, the SF 86 form is online and requires only filling out once and updating when reinvestigations are required. When a clearance is up for renewal, the applicant can log in their SF 86 and make updates.
Not everyone investigated is guaranteed a clearance. In some instances, a clearance can be denied, revoked or suspended. The employee's background is investigated thoroughly for the initial clearance and again every five to fifteen years while maintaining a clearance. In the event that a security clearance is denied, suspended or revoked, the CSO will also notify the FSO. The FSO will then deny access to classified material to that employee.
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".
Steps to Getting the Facility and Personnel Security Clearance are available in our upcoming book tentatively titled Insider's Guide to Security Clearances. You can pre-order now.
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The Security Clearance in 30 Seconds
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How are security clearances granted? Why does the Government grant them? How does the Government assign classification levels? Who is eligible? First of all, classified information must be protected. Part of the protection is to ensure only properly investigated and vetted cleared employees with need to know get access granted.
According to the latest Executive Order, employees should not be granted access to classified information unless they possess a security clearance, have a need to know to get it, received an initial security briefing and have signed a nondisclosure agreement. Some clarifications should be made concerning who actually gets them. Those granted include the businesses and their employees. Defense contractor are business entities and employees are the people who work there. When a defense contractor gets granted access to classified information, they are then called Cleared Defense Contractors (CDC). Once they have their clearance, then the employees will go through the process to become cleared employees.
The Personnel security Clearance (PCL) is related to a Facility security Clearance (FCL) held by the cleared contractor they work for. Respectively, the defense contractor businesses are required to have a FCL prior to performing on classified contracts. What does this mean? It means the cleared contractor and cleared employee has been thoroughly investigated and properly vetted before even being considered eligible to receive classified information. The need to know aspect further defines which classified information is provided based on criteria such as contract or work requirements. The point is not anyone with a clearance gets access to classified information. It’s based on clearance level and their need to know.
Additionally, not anyone can just apply; it’s based on a classified contract. The company must be sponsored for a clearance by a Prime Contractor or Government Contracting Activity (GCA). The FCLs are granted to defense contractor facilities and PCLs are awarded to their employees; both granted only after an investigation and adjudication. Therefore, think of the process as the administrative determination that an entity and person is eligible from a national security basis for access to classified information.
There are several steps involved and for this article, we've listed them below:
- Registering as a defense contractor
- Getting sponsorship of facility security clearance
- Requesting personnel security clearances
- Appointing required employee positions
- Following guidance in the NISPOM and how to protect classified information.
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".
Saturday, December 14, 2019
Frequently Asked Security Clearance Questions
Opportunities abound in the defense industry where every job discipline requires a security clearance to perform on the contracts. Classified contracts require services that include staffing, janitorial, graphic design, accounting, finance and more. Technical experience is needed as well with mechanics, software designers, engineers, program managers and their support.
For the unfamiliar the security clearance process may seem daunting. The lack of information of how to get started, the required forms, interviews, waiting, and expectations can make the entire experience out of the individual's control. However, there is a well-established and efficient process that the government undertakes and you can be in as much control of the experience as possible.
A Little Background
Whether or not in college, gainfully employed outside of the defense industry, or starting a business, as the reader, you are interested in gaining a security clearance and starting a profession with the more than 13,000 Cleared Defense Contractors (CDC) making up the industrial base. Though you may be aware of the opporutnities, you may be wondering how to get started and I usually get asked the following question:
How do I get a clearance so I can get a classified job?
It's a great question, but it can't be answered easily as asked. The clearance comes after the job requirements. The question is often asked and in the form asked, skips right by the most fundamental question of whether or not an individual qualifies for a clearance and what is the process for getting a clearance. I will attempt to answer the first question by providing answers to the other two questions:
Can I get a security clearance?
Yes, the security clearance process is open to U.S. Citizens. If after a thorough investigation you are deemed trustworthy, you may be granted a question. However, not just anyone can apply; see the next question.
How do I get the clearance?
By applying for a job that requires a security clearance or starting your own company and winning classified contracts.
How long does it take to get a clearance?
This could take a few months to over a year depending on the investigation and adjudication of findings. The investigation is very in depth and depends a lot on information the applicant proides on the SF-86 application.
There is so much more, so keep following. We have an eBook available that can assist. Just register for our newsletter full of security clearance articles and advice and we'll send it. Here's the link: http://www.redbikepublishing.com/contact/
Jeffrey W. Bennett, ISP is the owner of Red Bike Publishing.
He 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"
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.
Monday, December 9, 2019
Getting Ready For NISPOM, FSO and ISP Certification
Study for certification with our latest study guide.
http://www.redbikepublishing.com/ispcertification/
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".
http://www.redbikepublishing.com/ispcertification/
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".
You Need A Security Clearance
Check out our new video and then pre-order your book on security clearances.
http://www.redbikepublishing.com/insidersguide/
Saturday, December 7, 2019
Planning for the Facility Security Clearance (FCL)
http://www.redbikepublishing.com/dodsecurityclearancesandcontracts/ |
Once a defense contractor is granted a facility clearance, they can begin to prepare to perform on the classified contract. This preparation could identify potential additional costs. The costs associated with performing on classified contracts will vary by contract and depends on whether or not the Cleared Defense Contractor (CDC) is a possessing or non-possessing facility. The possessing facility is one that performs classified work at the CDC location and may require the storage of classified documents or material on site.
Depending on the contract, this could involve purchasing multiple security containers or acquiring large storage areas for oversized material such as weapons systems or computers. For non-possessing facilities, this does not require the storage of classified information at the CDC. However, the organization will provide cleared employees to perform classified work at locations other than at the home facility.
The FSO can help reduce costs associated with protecting classified information by being involved and preparing as early in the acquisition process as possible. This is where an experience FSO can anticipate expenses, perform risk assessment while implementing National Industrial Security Program Operating Manual (NISPOM), and advise on ways to reduce costs while being compliant. The more money saved on overhead expenses, the greater the overall company profit. The earlier into the process the assessment is conducted the better the company performs.
Conducting a cost impact study or coordinating with the GCA and CSO later than necessary may place the contractor in the tough position of last minute work and higher associated expenses while building closed areas, ordering more GSA approved containers (safes), and meeting tough governmental compliance with short notice.
One good idea is for the FSO to form a working team to consider the costs. These could be program managers, engineers, security, contract and other managers responsible for developing business with the prime contractor or government agency. This team would consider the contract, security requirements, have decision authority and the ability to commit the company to the developing security plan. The FSO contributes by providing information and guidance on protecting classified information in the process and such planning could translate into significant cost reduction.
Understanding how to advise and assist in the development of the Contract Security Classification Specification (DD Form 254) and Security Classification Guides (SCG) brings the CDC into the planning process early and can benefit the government and the CDC by reducing time and resources. It provides the ground work for ensuring the customer security requirements are clear, applicable, and understood. Since the government provides the protection requirements, getting in on the ground level development can only benefit the contractor.
The FSO can use the DD Form 254 requirements as a baseline in assessing the current state of security to determine whether or not the company has enough classified storage space, the right type of storage space, whether or not alarms are needed and other physical security needs to support the contract, and the adequate security or support staff is on hand. Other performance requirements may indicate the need for classified computer processing, upgrading facility and personnel clearances, and increasing storage level and capability.
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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