Top secret Clearnaces

Getting an FCL in the Classified World

Security Clearance for your BusinessMany small business owners and entrepreneurs are engineers and scientists who have stepped outside the larger companies to pursue their own business. Inside the larger companies they were individually supported for their security clearance. Now, as a business owner desiring to work in the classified world, they wonder how to start down the road to working in the classified world.

There is a method for entering into the DoD classified “world of work”. It really isn’t too “secret” (pardon the pun). The entrance costs your company nothing other than time to gather information and meet with the Defense Security Service (DSS) as described below. But what you need is to first get a “facility clearance”.

(Note: the term “facility clearance” in security does not mean a physical facility. A company can have a facility clearance without having an office or building, as long as the company does not store classified information.)

So, one enters into the DoD classified “world of work” by having a facility clearance. How does one get a facility clearance? Your company must have a contractual requirement to access DoD classified information or materials. That is all. Not too secret about that but it is absolutely necessary. To restate, your company must have a contract requiring access to classified information. Sometimes your company can win such a contract from another contractor or DoD agency without a facility clearance in place. But once won, your company must complete the contractual requirements.

Let’s say that your company (a.k.a. “ABC”) has won a contract from another company or government agency. Let’s call that entity “XYZ”. So what happens next? Well, it’s all in XYZs hands at this point.

Top secret ClearnacesXYZ has issued the contract to ABC with FAR clause 52.204-2 Security Requirements and attached a DD Form 254, DoD Contract Security Classification Specification to the contract. Contracting officers should know of this clause and form. With the DD Form 254 issued, XYZ is ready to take the second step.

The second step is that XYZ writes a “Sponsorship Letter” reflecting the request for the personnel of ABC to work with classified. The Sponsorship Letter is written to the DSS with an attached copy of the DDForm 254. Note that there are specific items that must be reflected in the Sponsorship Letter which guides the DSS.

With the receipt of the Sponsorship Letter, a DSS Industrial Security Representative (ISR) coordinates a visit to ABC’s facilities and sits down with the Facility Security Officer (FSO). The FSO can be the owner/operator of the business with two or more people or it can be an employee assigned as the FSO in a larger company.

At the end of that meeting between the FSO and the DSS/ISR, each will have the information necessary to proceed. The DSS/ISR will continue with the facility clearance process which includes clearing at least one employee of ABC- the owner /FSO if so desired.

Both the FSO and the DSS/ISR work concurrently on their responsibilities. DSS tries to work facility clearance requests as a top priority so at some point both the DSS/ISR and the FSO meet again to finish up the clearance process. If both sides have their jobs done, the DSS/ISR can issue an interim or final facility clearance at the level required by the DDForm 254. However, the next part of a Facility Clearance gets a little dicey, for as you know in all contracts, “the devil is in the details”.

Security Clearance OverWhelmSome of those devilish details as found in the contract and DDForm 254 are:

  • Will ABC store classified material (a possessing facility) or only access classified at other locations (a non-possessing facility)?
  • Who will administer the JPAS program? The FSO in a larger company or the CEO/Owner/FSO in a smaller company?
  • Who in the company will handle the annual training of cleared employees?
  • If your company become a possessing facility, then ABC will need:
    – A safe or “closed area” to store classified;
    – Possibly a COMSEC “SOCA” account so you can use a STE or STUIII phone to talk with the customer;
    – Maybe a computer to process classified information and a computer-smart cleared employee to handle DoD security on “AIS” systems and to write the System Security Plan.
    – A method to ship and receive classified information and materials;
    As you see, ABC Company has to make decisions based on the DDForm 254 and then the DSS/ISR provides the guidance to provide proper security.