Classified Storage Approval: Three Steps to Prepare Defense Contractors for Closed Areas

As a Facility Security Officer (FSO), you take the lead in creating a security program designed to protect classified information. He is at the forefront of his licensed contractor organization’s ability to obtain and maintain classified contracts. As such, she must also be the top executive’s right-hand woman and have successfully established the relationship required to provide wise security advice.

Some relevant topics for your organization may be:

Where are we headed?

What type of classified storage might this require?

What will be the cost and impact to the business?

How is my security program prepared to support current and new contracts?

If a new or existing contract requires a dedicated space to perform and store classified information, a “Locked Area” may be required. An enclosed area is used to safeguard classified material of “unusual size, nature, or operational necessity, and cannot be adequately protected by normal security measures or stored during non-business hours in approved containers” and NISPOM 5-306 provides minimal guidance. on the authorized responsibilities of the contractor. and 5-800 provides construction information.

1. Make sure you have a classified contract that approves classified storage and performance in the prospective location of the enclosed area. You can find this information in the upper right corner of the DD Form 254. There are two blocks there that say Installation Authorization Required and Protection Level Required. Block 11 must be marked with the requirements of the authorized contractor in the execution of the classified contract (store, receive only, manufacture, etc.). Further instructions can be found in Blocks 13 and 14. If you have any questions, you should clarify them with the client. Your responsibility as an FSO is to ensure that your company is able to understand the security requirements and act on instructions. It is vital that your executives and clients are completely in sync.

2. Work with your Defense Security Services (DSS) to make sure they understand the requirements and there are no surprises. DSS has oversight and as such will verify that your classified contract, storage capacity and security program protect classified information. As such, the licensed defense contractor, your organization will also need to produce and demonstrate storage and performance procedures prior to approval.

3. Identify the security level. For storage of SECRET and above in a locked area, you will need to use additional protection during non-business hours and use approved lockout devices for access control during business hours (see NISPOM 5-306). Access control can be an authorized person performing controls or an automated system. If you don’t already have an area that meets approved building requirements, you may need to make significant modifications to an existing room or build an entirely new room. If so, consider taking photos throughout construction as you build so you can demonstrate compliance. After the construction is finished, it will be difficult to verify proper construction after the construction is complete. In either case, work closely with your DSS representative and the prime contractor or government contracting activity.

That’s it, these three steps must be addressed at a minimum before investing critical resources to dedicate building space for a “closed area”. Locked areas help protect classified information that cannot be protected in any other way, but it costs money. Approval of closed areas may require additional approval of open container storage.

For more information, check out our new book, DoD Security Contracts and Clearance Guide

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