File Management Tips and Suggestions FISWG/NCMS Winter Training Event December 17 th, 2014 Dela Williams Facility Security Officer

FCL File Folder O 441 or o This is the Department of Defense Security Agreement. It is an agreement between your organization and the United States Government that details the security responsibilities of both the cleared organization and the United States Government.

FCL File Folder cont. O SF-328 o The Certificate Pertaining to Foreign Interest is used to report your organization's foreign involvement. o Submit one copy and retain one executed copy. o Fully explain all "yes" answers.

FCL File Folder cont. O Key Management Personnel O Reference Guide: structures-job-aid.pdfhttp:// structures-job-aid.pdf

Corporate Paperwork for e-FCL Submission O Electronic Facility Clearance System (e-FCL) o The web-based e-FCL application, designed around the SF 328, "Certificate Pertaining to Foreign Interests," requires companies to upload and submit their required information into the system. o This information includes: o SF 328 o list of key management personnel o list of stockholders o Articles o Bylaws o Other supporting documentation o In addition, companies currently operating under a FOCI mitigation agreement must use e-FCL for annual certification processing.

Corporate Paperwork for e-FCL Submission cont. O Obtain and have available the following documents/information for your first visit from your Industrial Security Representative from DSS: o Articles of Incorporation o Bylaws o Meeting Minutes stating Directors/Officers

PCL Checklist O Name O PCL Justification O Initial Contact Meeting o Citizenship o Social Security o Gov’t Issued ID o Employee’s Contact Info ( /phone no.) o Provide employee with e-QIP Instructions (handout or )

PCL Checklist cont. O Initiate Electronic Fingerprinting Process O Privacy Notification

Employee File Folder O Electronic File Folder (paperless) O Hard Copy O Color coded stickers or tabs (differentiate) o Employees (blue) o Consultants (yellow) o KMPs (green) O Or by Program o ABC o XYZ

Employee File Folder cont. O Files In-Process: PCL or PR Suggestions: o Keep files in separate area in front for usual indicator. Then once find destroy PCL documentation & place with the general population. o Suggestion: Orange sticker share in-process

Suggested CAVEAT Folder O NATO Briefings Annual o Conduct NATO same month each year so not staggered (Be consistent) O NATO Debriefing: Attach to Re-Briefing and retain 2 years

Annual Refresher Briefing O Individual Acknowledgment O How are you tracking this? o Computer based training or sign in-sheet? O Match it up!

Self Inspection Handbook for NISP Contractor O Contractor Self Review: O Do not forget to check- o Each file folder (hard copy or electronic) for required items & to entrust no improperly retained PCL documentation. O Run Ghost Report O Check PR Report

Terminated/Separated Employee File Folders O Debrief on SF 312 O In-Person or by Phone with (date?) O Debrief company statement of acknowledgment O JPAS: 3 Parts o Debrief o Out-Process o Separate (w/date) O Go to the Person Summary Screen in JPAS & check employee’s record for separation date O NATO/Crypto? Debriefing date. o Retain for 2 or 2-3 years depending on requirement.

e-QIP Review O Review & Send Back O Review & Release O Make copy of SF 86 & signed Signature Release Forms (file) O Monitor JPAS o Initial PCL eligibility date

Initial Briefing [NISPOM 3-106] O SF 312 (date)/(make copy, mark as copy) o Date sent to PSMO-I O JPAS o Update Access o Enter SF 312 date o Final Eligibility Granted o Update JPAS: Final Access o Destroy Retained SF 86 & Signed Signature Release Forms

Reference Guide O Center for Development of Security Excellence (CDSE) O O U.S. Office of Personnel Management (OPM) O O application/#url=Quick-Reference-Guide application/#url=Quick-Reference-Guide O NCMS, The Society of Industrial Security Professionals O O FISWG: Florida Industrial Security Working Group O

Questions? Dela Williams Facility Security Officer