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Facility Clearance Processing. Chad E. Stoker Chief, Facility Clearance Division Defense Industrial Security Clearance Office (DISCO) (614) 827-1535. Overview . National Industrial Security Program (NISP) Authority & Responsibilities NISP Policy Rules and Regulations Industrial Security

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Presentation Transcript
slide1

Facility Clearance Processing

Chad E. Stoker

Chief, Facility Clearance Division

Defense Industrial Security Clearance Office (DISCO)

(614) 827-1535

slide2

Overview

  • National Industrial Security Program (NISP)
    • Authority & Responsibilities
    • NISP Policy Rules and Regulations
  • Industrial Security
  • DSS
    • Mission
    • What we do; how we do it; who we serve
  • The Facility Clearance
    • What it is
    • The Clearance Process
slide5

FCL Checklist

FCL, FOCI, & PCL FAQs

Sample Sponsorship Letter

Links

slide7

NISP Policy = NSC

CSA’s

DoD

NRC

DOE

CIA

CSO’s

NRC

DOE

CIA

DSS

GCA’s

five essential elements of fcl process
FIVE ESSENTIAL ELEMENTS OF FCL PROCESS
  • Sponsorship
  • Business Structure/Organization
  • Security Agreement
  • Foreign Ownership, Control, Interest (FOCI)
  • Key Management Personnel
sponsorship
SPONSORSHIP
  • From GCA or Cleared Contractor
  • To DISCO (Facility Clearance Branch)
  • Storage Required???

GCA

why do we clear a facility
Why do we clear a Facility?

Department of Defense Contract

Security Classification Specification

DD FORM 254

DD Form 254, Dec 90

mfos nonposessing divisions
MFOs & Nonposessing Divisions
  • ISL 03L-1 says:

“DISCO will no longer process new FCLs for division or branch offices that do not require possession of classified material for contract performance, unless there is a sufficient contractual or critical operational need.”

what about existing non possessing divisions branches
What About Existing Non-Possessing Divisions/Branches?
  • The ISL says DSS has been contacting currently cleared non-possessing division/branch offices …[and] has proposed administrative termination of those facility clearances.
  • Exceptions: >200 PCLs or a contractual requirement for a local FCLC.
services companies 1
Services Companies (1)
  • Example: Janitorial Service
  • Do not clear for convenience
    • Runs contrary to the Regulations
    • Poor Security Practice
services companies 2
Services Companies (2)
  • NISPOM:

NISPOM 2-102(a): “contractor must need access to the classified information in connection with a legitimate U.S. Government or foreign requirement”

NISPOM 7-102(d): “Requests to process a prospective subcontractor for an FCL must be based on a bona fide procurement need for the prospective subcontractor to have access to, or possession of, classified information.”

services companies 3
Services Companies (3)
  • Personnel Security Reg (For GCAs):

DoD 5200.2-R, Personnel Security Regulation, 3-601(a): “DoD Components shall not request, and shall not direct or permit their contractors to request, security clearances to permit access to areas when access to classified information is not required in the normal course of duties or which should be precluded by appropriate security measures.”

services companies 4
Services Companies (4)
  • Executive Order (For GCAs):

12968 2.1(b)(1): “Eligibility for access to classified information shall not be requested or granted solely to permit entry to, or ease of movement within, controlled areas when the employee has no need for access and access to classified information may reasonably be prevented . . .

services companies 5
Services Companies (5)

12968 2.1(b)(1): “ . . . Where circumstances indicate employees may be inadvertently exposed to classified information in the course of their duties, agencies are authorized to grant or deny, in their discretion, facility access approvals to such employees based on an appropriate level of investigation as determined by each agency.”

services companies 6
Services Companies (6)
  • Poor Security Practice:
    • Clearing the Services company facilitates the shirking of reasonable security responsibilities to protect for need-to-know.
    • Conceivably, the prospective cleared cleaning company’s personnel could have access to classified information across a broad scope of classified programs, without there being a genuine duty related need-to-know.
one person companies 1
One Person Companies (1)
  • Self-incorporated consultants
  • ISL 03L-1:
    • Cleared contractors may process self-incorporated consultants for a PCL
    • Consultant and members of his/her immediate family are the sole owners
    • In such cases a FCL is not required
slide21

Facility Structure

Corporation

Partnership

Sole

Proprietorship

security agreement

Witness That:

CONTRACT

Section II-Inspection

Section III Modification

Section IV Termination

Section V Prior Sec

Agreements

Section VI Sec.Costs

Section I-Security

Controls

Security Agreement

Department of Defense

Security Agreement

  • A six part document
  • U.S. Govt. & Company
  • Voluntary Participation

DD Form 254

facility security officer
Facility Security Officer
  • Daily operation of the security program.
key management personnel listed but excluded
Key Management PersonnelListed but Excluded*

Directors

Sr. VP

Secretary

Treasurer

clearance verification activity cva
Clearance Verification Activity (CVA)

CLEARANCEvsSTORAGE

phone = (888) 282-7682

fax = (614) 827-1544

or :

www.dss.mil

CONFIDENTIAL

SECRET

summary
Summary
  • National Industrial Security Program (NISP)
    • Authority & Responsibilities
    • NISP Policy Rules and Regulations
  • Industrial Security
  • DSS
    • Mission
    • What we do; how we do it; who we serve
  • The Facility Clearance
    • What it is
    • The Clearance Process