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A Key Element To assist in gaining a perspective on the value of a continuing evaluation program, the following is quoted from the February 1989 Security Awareness Bulletin published by the Department of Defense Security Institute, Richmond, Virginia. Although some of the dialogue is out-of-date in that the article mentions “designated countries” (the designated countries list no longer exists) and the requirement to “report contacts with citizens of designated countries” (report suspicious contacts by anyone, anywhere) as well as citing paragraph designations from the former Industrial Security Manual (ISM), the information continues to be germane to our efforts of maintaining an effective security awareness program. “THE CASE FOR CONTINUING EVALUATION: A Positive Approach to Ensuring Suitability to Hold a Security Clearance. Past the point of no return The following account, based on official government files, portrays a situation (typical of many) in which an employee’s security clearance is suspended. The personal and organizational failings in this case also led to the suspension of a facility clearance and to the loss of classified information to persons unknown. Could this disaster have been prevented? Judge for yourself. The names and places have been changed to maintain confidentiality, but the essential facts are true: Sam Wild came on board Visiclear, Inc., a small optical firm in Oregon, in late 1982. As a Quality Control supervisor, Wild had a continuing requirement for a secret clearance; Visiclear had several small defense contracts to produce high quality lenses for sensing devices. Although initially briefed about his security responsibilities in 1982, little was said to Wild about security after that point. In fact, security awareness, largely due to company policy, was a dead issue – dead at least until October 1987, when due to glaring security deficiencies, Visiclear received an unsatisfactory rating following an inspection by representatives of the Defense Security Service (DSS). As stated in the report, all employees in the department “were under tremendous pressure to have the product tested and shipped, and…security was more or less an afterthought to production.” Among several deficiencies cited was the fact that Wild had routinely allowed at least eight uncleared employees access to classified test data. Two of these were foreign nationals and one a recent Soviet emigrant. In addition, in his supervisory capacity, he had allowed employees to discard classified printouts in the trash and had left, unprotected, computer systems diskettes which should have been retained in a classified storage container. Wild’s total disregard for security and general apathy was judged to be so flagrant that he was subject to a “post-adjudicative investigation,” i.e., a good hard look at all of the available facts about an individual (after the initial granting of a clearance) to determine whether his continued access to classified information was still in the national interest. One might ask why Wild was entrusted with any of our nation’s secrets in the first place? As a minor, he did have a history of trouble with the law, but most of this had been expunged from the record. Wild was 23 and fresh out of college when hired by Visiclear. And, at that time, the granting of a secret clearance was based on only a standard check of law enforcement and intelligence agency databases. As is often the case with security offenders, warning flags go up only after a period of initial employment. But did Wild give the kind of signals that should have alerted management to a potential problem? Yes he did – but apparently nobody was paying attention The post-adjudicative investigation revealed information that should have been known and acted on much earlier, not only to preclude the possibility that the firm might be in jeopardy of losing its facility clearance, but to provide the kind of counseling or rehabilitation program that might have saved this employee from personal calamity. Interviews with co-workers, associates, and rental agents brought out a personal history of chronic indebtedness, continuing use of marijuana and habitual gambling, all occurring since Wild’s initial clearance and leading up to the lamentable facility inspection of October 1987. On two separate occasions Wild had been hauled into court by creditors and once had been forcibly evicted from his apartment for non-payment of rent. Both drug involvement and court judgments resulting in garnishment of salary were known to coworkers and management, but consistent with the firm’s almost nonexistent security program, no reports of adverse information had been submitted. After the DSS inspection, Wild’s security clearance was suspended by the Director, DSS, pending further review. But before a final determination of his suitability to hold a clearance, Wild’s employment was terminated by the firm. What went wrong? Even with counseling and support Wild may not have turned out to be the sort of personnel we would want to have access to classified information, even in the remote future. But with timely and accurate reporting of facts pertinent to the issue of suitability, Visiclear might have avoided a compromising situation. If our information is correct, the contractor in this case tried to make security pay the bills for productivity. In the long run, this didn’t work. Active programs for security awareness training and continuing evaluation for all cleared employees would have met any criterion of cost-effectiveness for this firm. Continuing Evaluation: “The Heart of the Program” Let’s try to nail down the concept of continuing evaluation by saying that it’s an on-going process of assessing an employee’s reliability and suitability for continued access to classified information after gaining employment. This decision-making process begins with the granting of a security clearance and concludes when that clearance has been withdrawn. It is necessary because people and situations change over time and therefore, the determination about suitability to hold that clearance is never final. And in theory, any kind of information bearing on an individual’s loyalty, trustworthiness, or potential vulnerabilities to espionage involvement must be included in this on-going process. As will be described below, the input of relevant facts and information for evaluation assumes that responsibilities are carried out faithfully by multiple actors including the holder of the clearance. The bitter experience of recent espionage losses committed by cleared personnel has again proven, at great cost, that initial evaluation alone for suitability to hold a clearance falls short of being a reliable mechanism. The fact is that even after the expenditure of enormous amounts of time and money by government agencies, a full 99 percent of applicants are granted initial or final clearance status. A recent report on the state of personnel security research from the highly respected Rand Corporation suggests that even with regular periodic reinvestigations, we can’t enjoy much confidence that we are identifying high-risk individuals: “... pursuit of a strategy limited solely to pre-clearance investigations in the face of possible future disloyalty problems requires that the investigations have predictive capabilities, which is unrealistic. Expanding the strategy to include periodic reinvestigations is clearly an improvement, in that it provides an opportunity to detect any adverse overt change since the last investigation; however, depending on the interval between investigations, it may still permit many years of uninterrupted compromises. "The report goes on to endorse “monitoring” job performance and personal behavior (that is, continuing evaluation) as an essential element in our total personnel security strategy. But how monitoring can be conducted most effectively will require, according to Rand, a great deal of research. At least until the findings are in (and probably long after) our personnel security programs will continue to be based on this central, but often ignored, concept of continuing evaluation, an on-going decision-making process. |
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Last Updated: July 7, 2000.