PROPOSALS FOR A by cyRrinE

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									                     PROPOSALS FOR A
  MODERN PERSONNEL SECURITY INVESTIGATIONS PROGRAM IN
SUPPORT OF THE NATIONAL INDUSTRIAL SECURITY PROGRAM (NISP)


             Delays in the completion of personnel security investigations adversely
     affect the ability of cleared contractors to perform on classified contracts and
     prepare to compete on pending or future contracts. Further, the opportunity to
     attract and retain the most talented employees has been damaged by industry’s
     inability to quickly provide new employees with challenging work assignments.
     These circumstances can result in diminished force readiness fur the Department
     of Defense (DoD) when systems are not delivered on time, and inefficiencies for
     other NISP user agencies when contract completions are impeded.

            The administrative processes surrounding personnel security investigations
     in industry -- from beginning the personnel selection process, to pre-employment
     inquiries to submission of the personnel security questionnaire, to checking status
     of investigations, to receipt of investigative results — is remarkably time
     consuming and expensive for both industry and government

             In most cases involving applicants for clearance, the industrial requestor
     has screened the employee and determined that there is no reason to believe that a
     clearance will not be granted. It has been reported that at least 99% of cases result
     in a favorable determination and the granting of a clearance. These facts raise
     serious questions as to whether the current industrial personnel security
     investigations program is viable.

              It is apparent that industry must rely heavily on the initial investigation to
     fulfill requirements of obtaining and performing on classified contracts. Industry
     recognizes the merits of the reinvestigation process as well, but contends that a
     balance must be struck between the government’s current emphasis on
     reinvestigations and industry’s needs for initial investigations.

            The Assistant Secretary of Defense (Command, Control, Communications
     and Intelligence) (ASD C3I) Strategic Planning Guidelines include the observation
     that, “Basic values such as identity, loyalty, security, and interpersonal
     relationships change and need to be reinterpreted.” The NTSP Goals include,
     “Emphasize personnel reliability...” In the context of such guidance, it would seem
     that investigative emphasis should change from loyalty and suitability to loyalty
     and reliability. Reliability can be determined by monitoring, evaluating, and
     analyzing an individual’s performance to include how well someone performs in
     protecting classified information. (See Chart at Attachment (1) which contrasts
     history with reality.)

            With the intention of offering a practical, modern implementation of the
     NISP. it is recommended that the DoD as Executive Agent, take actions to
     improve the industrial personnel security investigations program. The following
     specific proposals are offered.

            • Each candidate for clearance should be required to enter into a contract
     that includes an agreement to properly protect sensitive or classified information.
     This “Partnership for Assurance” would support the individual’s inclination

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           toward trustworthiness. Such a commitment serves to make the individual a part of
           the security process, and establishes another basis on which to hold the individual
           accountable. The process of entering into an agreement with the individual
           provides the employer an opportunity to demonstrate the significance of protection
           management to each employee’s mission and functions. This agreement is not
           intended to take the place of the nondisclosure agreement, hot can be reaffirmed
           annually during the employee’s annual performance review, and become part of
           the security education and awareness program as well.

                  • Security performance should be made part of each supervisor’s annual
            review of a cleared employee’s general performance.

                   • The annual security performance review should be part of a required,
            aggressive program of continuing evaluation of cleared personnel’s security
            stewardship. Continuing evaluations for security purposes may well coincide with
            the periodic screening of an individual for a position of greater responsibility.
            Continuing evaluation may include physical and mental fitness evaluations;
            security education and training that supports career enhancing assignments;
            persona! interviews to identify problems stemming from such situations as
            financial irresponsibility, interpersonal conflicts, stress, or anything else that
            might affect performance. The employer can use psychological testing or other
            techniques that might produce evidence of stability, reliability, dependability,
            adaptability, and general suitability for enduring the responsibilities of difficult
            assignments and access to increasingly higher levels of classified information~

                   • An Industrial Personnel Reliability Program (IPRP) should be established.
            It would emphasize continual vetting, use many more automated data matching
            techniques, save investigation manpower for problem cases, and improve the
            chances that we would have a cleared workforce.

                   • The investigative scope for initial investigation should be modified. The
            investigative organization should require and accept the individual’s submission
            of proof of citizenship; education; employment; and residence. Documentation of
            all such elements is available through public records that the applicant should be
            required to produce. National and local agency checks should be conducted along
            with credit checks. Following receipt of the required documentation and results of
            the automated checks, the individual may be granted access and put to work if no
            unfavorable information is uncovered. Should discrepancies need resolution, or
            some other circumstance require it, a personal interview of the applicant will be
            conducted or additional investigation undertaken, as necessary.

          • Random, aperiodic reinvestigation should be conducted when employees have
            access to Top Secret or compartmented information. Random, aperiodic
            investigations have a greater chance of identifying an individual’s vulnerabilities
            and would most likely save as a greater deterrent to improper actions than the
            anticipation of a routine, standard, five or seven year update investigation.

       None of these proposals for an improved, more efficient, and timely investigation
diminish the value of any investigative element that may be useful or necessary in resolving
an issue or completing an investigation. The greater emphasis on an individual’s
accountability, performance, reliability, and responsibility in the recommendations should
improve both timeliness and quality of the investigative process applicable to the industry.




                                                                                                  2
Personnel
Security                  1953 (current) Program                  2000/2001 Reality
Factor

Program Goal Ensure the loyalty (later security)       Find and keep reliable people in
             of the federal workforce.                 the federal contractor workforce


External        CPUSA is “5th column” within           Very different threat, no major
Threat          US, appeals to candidates along        enemy, some foreign national
                                                       affinity (Chinese-American)
Requiring       ideological line. Federal
program         loyalty/security program is born



Vetting         Asking friends, colleagues, checking   Americans far from homogeneous,
System          for defects. Assumes wide              have many foreign nationals now
Effectiveness   agreement on subjective standards      citizens, alliances, friendships
                of loyalty, mental health, etc.        formed, and broken quickly, work
                                                       ethic vastly different

Basic           Past behavior is best guide to         Past behavior, even if discernable,
Assumptions     future behavior                        often is not a good predictor of
                                                       how individuals will act

Compliance      Periodic Reviews will turn up
                problems                               Periodic reviews said to be after-the-
with
Program                                                fact pointers to problems that may
                                                       have existed all along


Bottom Line     System is front-end-loaded, may        Need to revamp system to allow for
                have some deterrent effect,            risk-management, reality of today’s
                manpower-intensive. Program            cleared base of individual and threat
                depends on almost non-existent         faced by US. Initial reviews can be
                willingness of others to report        accomplished with minimal manual
                behaviors                              effort, data base matching seems
                                                       more effective, automated reviews
                                                       of personnel need to be stepped up



                  Author:

                  Maynard Anderson
                  Arcadia Group Worldwide, Inc.
                  P. O. Box 222245
                  Chantilly, VA 20151

                  August 2001



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