DIS highlights security procedures.
The responsibility for obtaining the required government security clearance for commercial programs rests with the Defense Investigative Service (DIS). Without appropriate planning, this responsibility can be time-consuming and costly both to DIS and commercial contractors.
DIS is faced with fewer resources to plan and execute security arrangements, leaving much of the burden to the contractors. The procedures necessary to gain approval for a transfer of classified material may be accomplished concurrent with or prior to the submission of applications for licenses or agreements to the Department of State.
The procedures for international transfers of classified information, which include data related to hardware as well as technical data, are approved and controlled through government-to-government transfer.
Specifically, a DIS industrial security representative (IS rep) or DIS-appointed designated government representative (DGR) must verify the dispatch and receipt of the consignment and approve the transfer channels and procedures. To initiate a government-to-government transfer, security clearance verifications on all entities involved in the transfer must be obtained and the procedures used to transfer the classified information must be approved by the governments. After the initiation of an international program involving classified information, contractors should provide their local DIS field office with a description of the classification level of information to be exported.
The name, address, and telephone number of the agency that originated the classified information should also be provided. This information is necessary to enable DIS to make arrangements and provide guidance on the method of transfer. If special security arrangements are required the company should forward the proposed procedure to DIS for approval. The agency will secure the approval of the appropriate foreign government.
If the consignee is a foreign company, the U.S. company should ask DIS to obtain the necessary facility security clearance and storage capability verifications from the recipient government. Clearances for freight forwarders and carriers also must be verified.
If contractors from multiple countries are involved in the commercial effort, the prime contractor should prepare a program security instruction (PSI) to document how the security procedures from each participating country will be reconciled in the program. The contractor may obtain a copy of the format for a PSI from DIS.
The contractor's Facility Security Officer (FSO) should work with his or her counterpart in each participating foreign company to put together the basic information needed in developing the program security instruction.
The contractor should also provide an estimated schedule for shipments at the earliest stages of the planning procedure. The schedule allows DIS headquarters to coordinate with its foreign counterparts. Once the DIS IS rep or DGR has been notified of the impending transfer and has received the appropriate documentation, the transfer will be confirmed. Receipts will be properly prepared and the contents of each shipment visually verified before being sealed and addressed.
If classified information will be transferred under an exemption, the company should identify and provide copies of any prior export approvals for the same information. The actual documentation will be needed to verify the export approval before transfers can be authorized. The contractor should provide the name and telephone number of company officials responsible for certifying that classified shipments are within the limitations of the authorized export.
If foreign nationals will be assigned to, employed by, or visiting a cleared U.S. facility on a visit request, the company should forward a completed technology transfer control plan (TTCP) for DIS approval. A sample format for a TTCP for contractor personnel to review is available from the international branch of DIS.
It is important to address the security actions with the local IS rep at the earliest phases of international contracts. Companies should promote optimum coordination between the FSO and export control officers, marketing managers, transportation officers, and any other employees that will be involved in planning or facilitating the release of classified information to a foreign government.
Some additional procedures, developed by the Multinational Industrial Security Working Group, include a transportation plan for the shipment of classified material as freight, specific security clauses for international contracts, a clearance verifications request for foreign companies, and a request format for a visit to a foreign government organization or company. DIS has automated the visit request procedure.
To obtain information regarding the electronic transfer of visit information, contact the Defense Industrial Security Clearance Office.
John F. Donnelly is director of the Defense Investigative Service.
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|Title Annotation:||Pentagon Corner; Defense Investigative Service|
|Author:||Donnely, John F.|
|Date:||Jan 1, 1994|
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