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FSO Training > Facility Clearance (FCL) Orientation Handbook > Flashcards

Facility Clearance (FCL) Orientation Handbook Flashcards

1
Q

DCSA

A

Defense Counterintelligence and Security Agency

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2
Q

FCL

A

Facility Clearance

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3
Q

CSO

A

Cognizant Security Office

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4
Q

NISPOM

A

National Industrial Security Program Operating Manual

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5
Q

What document has the requirements, restrictions, and other safeguards you must put in place?

A

NISPOM

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6
Q

What is a Facility Clearance?

A

An administrative determination that from a national security standpoint a company is eligible for access to classified information at the same or lower classification level as the clearance being granted.

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7
Q

Who is the CSO for DoD?

A

DCSA

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8
Q

DCSA FCB

A

Defense Counterintelligence and Security Agency Facility Clearance Branch

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9
Q

GCA

A

Government Contracting Activity

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10
Q

NISP

A

National Industrial Security Program

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11
Q

Where are the eligibility requirements for a company to obtain a FCL?

A

NISPOM 2-102

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12
Q

KMP

A

Key Management Personnel

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13
Q

What are some of the requirements for eligibility of a FCL?

A
  • employees must need access to information that is classified at the Facility Clearance level requested.
  • meet personnel security clearance requirements for certain KMPs
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14
Q

NISS

A

National Industrial Security System

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15
Q

Requirements for interim security clearance

A
  • no FOCI foreign ownership, control, or influence
  • KMPs have personnel clearances at the interim level or higher
  • initial orientation meeting has been completed
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16
Q

DCSA ISR

A

DCSA Industrial Security Representative

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17
Q

When can a final FCL be issued?

A
  • all KMP are cleared at the final level of the requested FCL
  • there are no open changed conditions that would impact the FCL
    the initial orientation meeting has been completed
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18
Q

FOCI

A

Foreign Ownership, Control, or Influence

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19
Q

What are the 3 deadlines in the FCL process

A
  1. required legal documentation and DCSA forms must be submitted in NISS within 20 days of receiving the Welcome e-mail (Day 1)
  2. KMP e-QIPs must be submitted within 45 days of welcome e-mail (Day 1)
  3. KMP fingerprints should be submited at the same time as the e-QIP or within 14 days after submitting KMP e-QIPS
20
Q

Use the SF86 as an unofficial guide in gathering information for the e-QUIP

A

A paper SF86 cannot be submitted

21
Q

How are electronic fingerprints submitted?

A

They must be submitted to the Office of Personnel Managment (OPM) via the Secure Web Fingerprint Transmission (SWFT)
You can find a list of companies on the DMDC’s website

22
Q

First year Post FCL Responsibilities

A
  1. comply with NISPOM and implement a security program
  2. the ISR will reach out 120 days after the FCL is issued to conduct a brief assessment of your facility’s compliance with NISPOM requirements and implementation of its facility security program and an insider threat program
23
Q

FCL Orientation Video

A

a detailed narrated guide that will walk you through the FCL process
- contain specific deadlines that you have to meet

24
Q

FCL Initial Orientation Meeting

A
  • conducted by an ISR assigned from the local field office

Will discuss:
1. company’s NISPOM requirements
2. Facility’s Security Program
3. Facility’s Insider Threat Program
4. Provide KMP US citizenship verification (current or expired passport or birth certificate, and government issued photo ID).

25
FCL Package Submission
the required documents will be uploaded is the NISS - you will need a NISS account and one of the following roles 1. FSO Role 2. Alternate FSO Role 3. Other Security Staff Role - ensure package status is updated to "Submitted"
26
FCL Package Submission Checklist
- found in Appendix E - help to avoid common mistakes
27
LLC Required Business Records
1. Business License 2. Fictitious Name Certification 3. Certificate of Formation or Articles of Organization 4. Legal Organization Chart 5. Operating Agreement 6. LLC Meeting Minutes 7. Recent changes to company structure 8. FSO/ITPSO Appointment Letter 9. KMP Citizenship verification 10. Signed undated DD Form 441 11. Signed SF 328
28
LLC PCLs (personal clearances) for KMP
1. SMO 2. FSO 3. ITPSO 4. LLD Members are cleared if their duties require access to classified information. 5. Managers
29
Meeting Minutes
include the most recent Meeting Mintues and any Meeting Minutes to reflect changes to a company's address, name, KMPs, etc which may be different than the operating agreement/by-laws etc.
30
Legal Organizational Chart
- must be submitted in the FCL Package - shall reflect all US and foreign parent companies and subsidiaries including their affiliates
31
Excluded KMPs
DCSA will determine which Officers and Directors of the company not accessing classified information are considered excluded and do not need a PCL. Exclusions must be submitted for these officers
32
Required Forms
1. SF 328: Certificate Pertaining to Foreign Interests 2. Key Management Personnel (KMP) Form - NISS 3. Proof of Citizenship 4. DD Form 441 5. DD Form 441 -1 (if applicable)
33
SF 328 Certificate Pertaining to Foreign Interests
- certificate pertaining to a company's foreign interests - execute 2 original SF 328 forms for DCSA and container retention - must be signed by an employee/rep of the company who has actual authority to execute agreements (SMO) - One witness signature is required - upload signed SF 328 into NISS - provide all supplemental responses to affirmative SF 328 questions
34
KMP Form - NISS
- spell out entire KMP names - social security numbers not required for excluded KMPs - KMP must match the Articles or Organization, by-laws or amendments
35
Proof of Citizenship
- citizenship verification in the form of a US Passport, Birth Certificate
36
DD Form 441
- agreement between your organization and the US Government that details the security responsibilities of both the cleared organization and the US Government - Execute 2 original DD 441 forms for DCSA and contractor retention - DD 441 must be signed by an employee or rep of company - one witness signature required - upload signed DD 441 into NISS - date on page 1 and the government representative section on p2 should be left blank
37
dd form 441-1
- attachment to the DD form 441 - lists cleared divisions or branch offices that are included in and covered by the provisions of the organization's Security Agreement and Certificate Pertaining to Foreign Interest
38
Address General Notes
- organization must register their business with a physical address - the physical address is the actual address where the organization is located does not hae to be in the state of incorporation - the address the DCSA uses for the Facility Clearance and is considered the home office - the CAGE code registration must match this address - organization may also have a registered agent address which typically must be in the state of incorporation
39
Required documents
- some states do not require certain types of organizations to have all docs referenced - the company has to show that they meet NISPOM requirements
40
Business structure guidance, LLC - required documents
1. Certificate or Articles of Organization - filed with the Secretary of State's office where the company is organized 2. Operating Agreement - describes the governance of the LLC's business and financial and managerial rights & duties, initial and most recent meeting minutes as well as those approving any significant changes 3. Legal Org Chart - shows company's ownership - connection to other business entities - internal management structure of the company
41
Business structure guidance LLC - KMP list
- the KMP list must include all members and must match the Operating Agreement - the FSO and ITPSO must be listed in the KMP list and must be cleared or processed for a personnel security clearance at the level of the facility clearance requested
42
LLC Membership
- LLC membership may be individuals or other organizations - members are not generally required to be cleared simply because of their ownership interest, this can vary depending on their specific authority to control or influence the business as described in the operating agreement
43
member-managed
management of the company is either automatically vested in the members by virtue of their being members
44
manager-managed
membership is vested in a separately designated manager, mangers, or board of managers
45
Member Clearance
- managers of an LLC are generally required to be cleared as it is extremely rare that they have a level of authority that would allow them to be effectively excluded - for the purpose of the KMP list for DCSA companies should enter any and all titles that are outlined in business documents and refrain from including titles that are only used in practice
46
ITPSO Insider Threat Program Training
- considered a KMP - can be the same person as the FSO - must take take training within 30 days of being formally appointed

FSO Training (2 decks)

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