Posts

Showing posts with the label government contracts

Security clearance eligibility and working for foreign companies

Image
I've recently received many emails from people who are curious about security clearances and working for foreign owned companies. Though the volume of those questions have increased, I guess the topic is no longer surprising in content as it could have been many years ago. Many years ago, we might automatically assume that working for a foreign owned company would be indicative of highly questionable practices, but maybe not any longer.  Things have changed. More foreign owned companies are opening doors in the U.S. Internet opportunities open doors to employment. Working for foreign companies provides new opportunities regardless of boarders such as: investment, teleworking, and creative content services that allow artists to bid on customer jobs have made this more of a possibility.  But the questions have been pretty vague and hard to answer.  Am I allowed to work for a foreign company if I have a security clearance? Will I be able to get...

Cleared Defense Contractor Performance and How to Protect Classified Information Fundamentals By: Jeffrey W. Bennett, SAPPC, SFPC, ISOC, ISP

Image
  Cleared Defense Contractors use classified information during performance of contracts. The Department of Defense makes the rules and governs how the classified contractors protect classified material. The Federal Government has published a policy appropriately titled: The National Industrial Security Program Operating Manual ( NISPOM ). This page turner is sponsored by the Presidential Executive Order (E0)12829 for the protection of information classified under E.O. 12958, As Amended. Having poured over both publications and the updates, I can confidently assure you that they take this business very seriously.     When specific work declares performance objectives on classified efforts, provisions of the applicable DD Form 254 and Security Classification Guide (SCG) shall govern. Both the DD 254 and SCG spell out what specific work a contractor can and cannot perform, what exactly is classified and how to protect it. Both of these document...

What Defense Contractors Should Consider Before Appointing FSOs

Image
Becoming a cleared defense contractor (CDC) demands more than just a defense contractor getting a security clearance and performing on  classified contracts . It's more to do with, what to do once the clearance is awarded; specifically, protecting classified information. This protection involves physical, classified processing, and information security. It's more than just buying safes, installing access controls and getting employees security clearances. Primarily, the CDC must appoint a Facility Security Officer (FSO) responsible for implementing a program to protect classified information. To better answer frequently asked questions, I've written several times on the topic of selecting the right Facility Security Officer (FSO) qualifications. According to the N ational Industrial Security Program Operating Manual (NISPOM) , the FSO must be a US Citizen and be cleared to the level of the facility (security) clearance (FCL); period. This provides a lot of room for a cleare...

Another explanation of CUI

Image
A buzz is sweeping the security community since the industry has been notified of the recent updates to DoD's CUI program based on the presidential memorandum with the subject,  Designation and sharing of Controlled Unclassified Information (CUI) . This memorandum implements a program designed to encourage the speedy sharing of information to those authorized and to better protect the information, privacy and legal rights of Americans. The CUI program is designed to promote proper safeguarding and dissemination of unclassified information.       Many readers may be familiar with the program CUI has replaced. Sensitive But Unclassified (SBU) information had enjoyed protection to a certain level but was not conducive to the necessary information sharing. Controlled Unclassified Information (CUI) directives provide procedures for a more appropriate Information Sharing Environment.     CUI is a designation of unclassified informati...

Training and Goals for Cleared Defense Contractor Employees

Image
Putting first things first. That has been a motto for many after reading books such as Franklin Covey’s 7 Habits of Highly Effective People or Reverend Rick Warren’s The Purpose Driven Life. Those and several similar motivational publications stress that everyone has the same amount of time in a day. What we do during that time helps us either make or goals or fail before we even get started.    As leaders, FSOs can help cleared defense contractor employees understand how to create incredible security programs. Focusing on training, interaction with other cleared employees, self-improvement and institutional education should be part of professional development. FSOs and managers who write evaluations for direct reports have an excellent opportunity to help them establish goals to become better at their jobs, more impactful in their careers and hopefully, groomed to become FSO’s themselves. Challenging employees and team members to achieve personal and professional goals b...

NISPOM Codifying, Guidance, Cleared Defense Contractors, and all those CFRs

Image
The latest industry buzz is the “release of the new National Industrial Security Program Operating Manual (NISPOM)”. I’m putting air quotes in there, because an actual NISPOM has not been rewritten or re-released. There is no re-release of NISPOM, only a reorganization of the CFRs that duplicate National Industrial Security Program requirements. If you are expecting the release of a “new NISPOM”, such as a Change 3 or a total re-write, that has not occurred. I encourage you to read further. The genesis of all this buzz of a “new NISPOM” is listed here:  https://www.govinfo.gov/content/pkg/FR-2020-12-21/pdf/2020-27698.pdf Straight to the point Conclusion:  No new NISPOM (just a few additions)  32 CFR part 117 and 32 CFR part 2004 are redundant requirements DoD will no longer publish the DoD Manual 5220.22, NISPOM as a DoD policy issuance in 32 CFR part 117.  32 CFR part 2004, “National Industrial Security Program” is now the standing CFR NISPOM Change 2 is still a req...

Protecting classified security container combinations

Image
 Here's an interesting scenario. Imagine you are walking the floor and talking to employees when you approach a security container and employees who controlled its access. As part of your inspection, you wanted to verify all documents were properly marked and stored appropriately. After asking for the custodian to open the container, he pulled out his cell phone and began scrolling. you asked what he had been looking for and he stated: "I can't remember the combination, but I'm sure that it's in here somewhere." Whoa! Hold the presses. You immediately changed the combination, filed the necessary report, and investigated whether or not classified information was compromised (not necessarily in that order). You also provided a clear policy and training agenda and that problem disappeared. The story may be true or a similar situation may be familiar.    But here's the question: Do your employees really understand how to protect classified information? Some no...

Frequently Asked Security Clearance Questions

Image
By: Jeffrey W. Bennett, SAPPC, SFPC, ISOC, ISP   In our various roles as industrial security managers, we often field tough security questions. Good questions provide the opportunity to address security clearance and awareness issues that may not arise during formal annual training sessions. These questions usually come up as I walk around the facilities or speak with folks informally. Here are just a few: 1. Is everyone who asks guaranteed a security clearance?    No, having a security clearance is not one of our inalienable rights. A security clearance is a determination of trustworthiness based upon an extensive background check conducted by some very professional and persistent investigators. The background checks help answer a person's ability to protect classified information based on the following criteria: • Allegiance to the United States • Foreign influence • Foreign preference • Sexual behavior   • Personal conduct • Financia...