Accounting for lost documents.

ACCOUNTING FOR LOST DOCUMENTS

IT MAY NOT HAVE REGISTERED ON the Richter scale, but the aftershocks are still being felt throughout the defense industry. A few years ago, the accountability systems for classified documents of several major defense contractors were subjected to congressional scrutiny.

The problem began when one major contractor attempted to camouflage lost documents by postdating destruction certificates. It didn't work, and before long that contractor's misdeeds came under congressional review. In turn, Congress's investigative arm, the General Accounting Office (GAO), was asked to examine other special access programs used to protect and account for classified documents in related programs.

After GAO submitted its report to Congress, local and national media reported each new disclosure of unaccounted-for documents down to the exact number. They quoted tantalizing excerpts from the report, leaving readers to draw their own conclusions on the possible damage the missing documents could cause to national security: "can't account for [x-number] of documents," "uncertain if national security has been compromised," "contractor asked to comment on sensitivity of missing documents," "contractor tightens security systems in aftermath of GAO review."

In light of the sensationalism that surrounded the GAO report, it's no wonder that people became disillusioned about the process of safeguarding the nation's secrets; that at least one congressional subcommittee was contemplating launching a broader investigation of the matter; and that other defense contractors were scurrying to get their houses in order to avoid being caught up in the maelstrom.

The probe may not go any further, but contractors cannot afford to be apathetic or adopt a wait-and-see attitude. It's safer to proceed on the assumption that no major defense contractor is immune from a microscopic review of its classified accountability systems and that the only uncertainty is when and by whom the reviews will be conducted.

WHAT'S ALL THIS COMMOTION about a few hundred missing documents? you might ask. Aren't losses bound to occur when inventories approach a quarter or half million documents? Isn't it understood that those who engage in espionage are not likely to remove an accountable document permanently from a facility, fearing that its absence could be traced back to them later? Why are the regulated always in the spotlight and subject to more stringent accountability requirements than the regulators?

These questions make document security a controversial topic; since the Defense Department established its Industrial Security Program, there has been no quicker way to spark a hot debate within security circles than to bring the topic up.

Two schools of thought exist. The purists contend that if a classified document is lost, the information contained in the document must be considered as compromised (disclosed to unauthorized persons), unless it can be proven otherwise. The pragmatists argue that a lost document doesn't mean a compromise has occurred, or even that it has fallen into the wrong hands. Little room for compromise exists.

However, most industrial security managers readily agree on the following points:

* Controlling large volumes of classified documents is the one position in which they are most vulnerable to criticism during inspections, especially if missing documents surface that had not been previously discovered by the contractor itself.

* Keeping track of the development and movement of documents during their life span -- as they are transferred, reproduced, and disassembled -- can tax the capabilities of the best automated accountability system and often proves to be an exercise in futility.

* Nonsecurity staff members often have the most responsibility for making the system work effectively day in and day out, and quite often doing so is a collateral, not to mention burdensome, task. Usually they receive no additional incentive or recognition for performing the job correctly but all the blame when something goes wrong.

* Employees are naturally reluctant to report missing documents to the cognizant security office or customers because they never know whether they will be pilloried or praised for their forthrightness.

THERE ARE 1,001 WAYS TO LOSE A horse race. There are about as many ways to lose a document, too. Documents don't simply disappear into thin air or self-destruct. Some of the more commonly accepted, and plausible, explanations for lost documents are as follows:

* The accountable documents were inadvertently disposed of as classified waste without any supporting documentation. While this explanation is often valid, it can be used as an excuse for avoiding a thorough investigation. Increased security education is the best way to curb this problem, not making security personnel sift through classified waste containers on the off chance they might come across an accountable document.

* The documents were disassembled, or "cannibalized," to incorporate the extracted pages or chapters in another document or documents. The Industry Security Manual gives explicit guidelines on how to accomplish this minor feat. But one has only to be present during the preparation stages of a classified proposal -- as documents are being dismantled, dissected, and merged at a frenzied pace -- to fully appreciate the frustrations involved. Requiring that all physical changes to a document be made by trained personnel only at the document control stations, and following this practice religiously, is the only way to avoid having "gobbled-up" documents turn up missing at inventory time.

* The documents were transferred without receipts or notification to their document control station. Sometimes people bypass the prescribed control procedures, especially if they are cumbersome and difficult to work with, and transfer documents informally. The document found missing from the document control station of record may eventually reappear as a surplus document at another station, but by then a needless and time-consuming investigation may have been conducted, and possibly even a report submitted to the cognizant security office.

No facility has enough security personnel to police the hundreds or thousands of document transfers occurring annually. But errors in the transfer process should be a major check item during internal reviews and, when discovered, should be highlighted as a deterrent to others.

* An employee deliberately avoided basic security rules when checking out a document. If an individual is in a rush or late for a meeting, he or she might make this mistake. Although it's not as common a problem as it used to be, people with this attitude are usually equally untroubled about leaving classified documents at a meeting they attended without obtaining a receipt or telling anyone back at their home facility about it. In such instances, you can only hope that some conscientious soul at the remote meeting site will tell the facility security officer where the document is before it shows up as missing.

THE UNDERLYING QUESTION HERE is whether the loss of classified documents, under whatever circumstances, is the best or most reliable way of gauging the effectiveness of a contractor's accountability system.

No pat answer can be given to this query. Many variables are involved, such as the ratio of losses to total holdings, the nature and sensitivity of the lost documents, the presence or absence of a pattern in the type and volume of losses, how isolated or widespread the problem is throughout the facility, and the cause of the losses (such as a poorly designed system, lack of definitive procedures, inadequate supervision, a weak training program, or just plain carelessness and sloppy handling). Perhaps the most important variable is the actions taken to reduce future losses, in terms of closing loopholes, improving systems, and enforcing a disciplinary schedule with teeth in it.

How should contractors react to the phenomenon of missing documents in the defense industry? Perhaps it can best be viewed as bad news and good news. The bad part is you never know when auditors or investigators are going to appear for an in-depth review of your document control system, with special emphasis given to lost documents. The good part is that security managers should have an easier time convincing their management of the need to upgrade or otherwise improve the document accountability systems. It should be possible to sell management on the idea, not only as a means of heading off the "storm troops," but also because it's simply good business to have a system that is as functional as it is efficient.

What does the future hold? It is fairly safe to assume that the executive branch, with a little prodding from Congress, will continue to focus more attention on the degree of protection given to classified material in the possession of defense contractors. Thinking otherwise is about as perilious as Little Red Riding Hood venturing alone into the forest, knowing the wolf lurks within. The repercussions can be deadly.

Contractors, in turn, must cling to the hope that calmer and more objective minds will prevail whenever and wherever a new revelation about missing documents is flashed across the front page of the newspaper. And maybe such revelations won't automatically be engulfed in sensationalism but treated matter-of-factly. The day may yet come when everyone in government and industry accepts what to many has always been a truism: "Let he who is without lost documents cast the first allegation."

David A. Grand spent nearly 30 years in the federal government, retiring as director of security for the US Department of Transportation (DOT). Prior to joining DOT, Grand had been an industrial security specialist with the United States Air Force and worked for Lockheed Missile & Space Company and Northrop Corporation. He was a member of the task force responsible for the consolidation of the DOD Industrial Security Program in the mid-'60s and was action officer on the extensive revision of the 1966 Industrial Security Manual. Grand is a member of ASIS.