Re: FOIPA adventures

On 10/5/15, coderman <coderman@gmail.com> wrote:

honestly didn't think i'd get a useful reply to this one: " [regarding SCIFs]

... https://muckrock.s3.amazonaws.com/foia_files/2015/09/29/F15-0117_Peck.PDF NATIONAL RECONNAISSANCE OFFICE 14675 Lee Road Chantilly, VA 20151-1715 28 September 2015 Mr. Martin Peck MuckRock DEPT MR 21368 PO Box 55819 Boston, MA 02205-5819 Re: NRO Case #F15-0117 Dear Mr. Peck: This is in response to your request dated 19 September 2015, received in the National Reconnaissance Office (NRO) on 21 September 2015. Pursuant to the Freedom of Information Act, you are requesting "Records associated with self inspection of classified materials handling pursuant to Executive Order (E.O.) 13526 and E.O. 13587 for the last ten (10) years." We have accepted your request, and it is being processed in accordance with the FOIA, 5 U.S.C. § 552, as amended. As an interim release in response to your request, we are providing to you thirty-nine pages of responsive information that has previously been released in part to another requester. These pages are being released in part to you, as well. Information that is denied is withheld pursuant to FOIA exemption (b)(3), which is the basis for withholding information exempt from disclosure by statute. The relevant withholding statute is 10 U.S.C. § 424, which provides (except as required by the President or for information provided to Congress), that no provision of law shall be construed to require the disclosure of the organization or any function of the NRO; the number of persons employed by or assigned or detailed to the NRO; or the name or official title, occupational series, grade, or salary of any such person. Since it is unlikely we will be able to provide a complete response within the 20 working days stipulated by the Act, you have the right to consider this a denial and may appeal on this basis to the NRO Appeal Review Panel, 14675 Lee Road, Chantilly, VA 20151-1715 after the initial 20 working day period has elapsed. It would seem more reasonable, however, to allow us sufficient time to continue processing your request and respond as soon as we can. Unless we hear from you otherwise, we will assume that you agree and will continue processing your FOIA request on this basis. You will have the right to appeal any denial of records after you receive a final response to your request. The FOIA authorizes federal agencies to assess fees for record services. Based upon the information provided, you have been placed in the "other" category of requesters, which means you are responsible for the cost of search time exceeding two hours ($44.00/hour) and reproduction fees ($.15 per page) exceeding 100 pages. We will notify you if it appears that we will meet or exceed our $25.00 minimum billing threshold in processing your request. Additional information about fees can be found on our website at www.nro.gov . If you have any questions, please call the Requester Services Center at 703 - 227-9326, and reference the case number F15-0117. atricia B. Cameresi Chief, Information Review and Release Group Enclosure: Responsive information for 2012 & 2013 UNCLASSIFIED NRO APPROVED FOR RELEASE 28 August 2014 NATIONAL RECONNAISSANCE OFFICE 14675 Lee Road Chantilly, VA 20151-1715 MEMORANDUM FOR OFFICE OF THE UNDER SECRETARY OF DEFENSE FOR INTELLIGENCE SECURITY POLICY AND OVERSIGHT DIRECTORATE SUBJECT: Annual Self - Inspection Report REFERENCES: OUSD(I) Memorandum, Annual Senior Agency Official Self - Inspection Program Report for Classified National Security Information, 8 July 2013 The National Reconnaissance Office (NRO) is providing the attached Self - Inspection Report as requested in reference. oint of contact for questions concerning this submission is A. Jamieson Burnett Director, Office of Security and Counterintelligence Attachment: NRO Annual Self-Inspection Report for 2013 UNCLASSIFIED NRO APPROVED FOR RELEASE 28 August 2014 Enclosure 2 AGENCY ANNUAL SELF-INSPECTION PROGRAM DATA: FY 2013 (Submissions must be unclassified.) PART A: identifying Information 1. Enter the agency name. 1. National Reconnaissance Office (NRO) 2. Enter the date of this report. 3. Enter the name, title, address, phone, fax, and e-mail address of the Senior Agency Official (SAO) (as defined in E.O. 13526, section 5.4(d)) responsible for this report. 2 . 30 3. 4. Enter the name, title, phone, fax, and e-mail address of the individual or office responsible for conducting self-inspections and reporting findings. 4. 5. Enter the name, title, phone, fax, and e-mail address for the point-ofcontact responsible for answering questions regarding this report. 5 September 2013 Mr. Frank Calvelli Principal De suty Director, NRO Room (b)(3) 10 US( 14675 Lee Road, Chantilly, VA 20151 A. Jamieson Burnett Director, Office of Security and Counterintelli .ence, (b)(3) 10 USC 44 Finn= (b)(3) 10 USC 424 Chief Securit and Counterintelli ence Policy . Staff, (b)(3) 10 USC 424 Fax (b)(3) 10 USC 424 (b)(3) 10 USC 424 PART B: Classified National Security Information (CNSI) Program Profile Information 6. Has your agency been designated/delegated as an original classification authority (OCA)? 7. Does your agency perform original classification activity? 8. Does your agency perform derivative classification activity? 9. Does your agency have an approved declassification guide and declassify CNSI? 6. 7. 8. 9 ■No _I Yes ■No Yes ■No ❑ Yes ■No ❑ Yes ❑ PART C: Description of the Program A description of the agency's self-inspection program to include activities assessed, program areas covered, and methodology utilized. The description must demonstrate how the self-inspection program provides the SAO with information necessary to assess the effectiveness of the CNSI program within individual agency activities and the agency as a whole. Responsibility 10. How is the SAO involved in the self-inspection program? (Describe his or her involvement with the self-inspection program.) The Director of Security and Counterintelligence (D/OS&CI) advises the Senior Agency Official (SAO) when events warrant. The NRO Integrated Security Assessment Program (ISAP) results are also reported to the SAO thru the annual Management Control Plan Statement of Assurance (MCPSOA). 11. How is the self-inspection program structured to provide the SAO with information necessary to assess the agency's CNSI program in order to fulfill his or her responsibilities under section 5.4(d) of E.O. 13526? The DOS&CI receives periodic reports on the program and advises the SAO when the DOS&CI believes events warrant advising the SAO. The NRO ISAP results are also reported to the SAO thru the annual MCPSOA. 12. Whom has the SAO designated to assist in directing and administering the self-inspection program? Who conducts the self-inspections? (If the SAO conducts the self-inspections, which may be the case in smaller agencies, indicate this.) The DOS&CI is provided a Letter of Instruction by the Director, NRO which assigns his responsibilities. Approach (b)(3) 10 USC 424 13. What means and methods are employed in conducting self-inspections? (For example: interviews, surveys, data calls, checklists, analysis, etc.) NRO self-inspections are part of the NRO ISAP. Because contractors make upillif the total NRO workforce and have the overwhelming number of Sensitive Compartmented Information Facilities (SCIFs), ISAP is a collaborative between Government and industry to identify and address security vulnerabilities, provide , . , , process • ri • INFORMATION SECURITY OVERSIGHT OFFICE AUTHORIZED FOR LOCAL REPRODUCTION 32 CFR 2001 E.O. 13526 NRO APPROVED FOR RELEASE 28 August 2014 14. If your agency performs different types of inspections (e.g., component self-inspections, command inspections, compliance reviews, etc.), describe each of them and explain how they are used. If not, indicate NA. NA 15. Do your agency's self-inspections evaluate adherence to the principles and requirements of E.O. 13526 and its implementing directive and the effectiveness of agency programs covering the following areas? (Select all that apply.) Original classification Cl Security violations [ 1 Safeguarding __I Management and oversight Derivative classification ■Declassification 11 Security education and training 16. Do your self-inspections include a review of relevant security directives and instructions? 16. ■Yes 7 No 17. Do your self-inspections include interviews with producers (where applicable) and users of classified information? 17. H Yes ■No Approach: Representative Sample (If your agency does not classify information, indicate NA.) 18. Do your self-inspections include reviews of representative samples of original and derivative classification 18. Yes ■No ■NA actions to evaluate the appropriateness of classification and the proper application of document markings? 19. Do these reviews encompass all agency activities that generate classified information? 19. ■Yes No ■NA ❑ 20. Describe below how the agency identifies activities and offices whose documents are to be included in the sample of classification actions. (Indicate if NA.) Based on the 291 site self-assessments submitted, the ISAP Manager, Program Security Officers (PSOs) and stakeholders discuss findings and formulate recommendations for a formal assessment, if required. OS&CI talePhnlrle.re rPrirpcAnt the tr. inr (IC R,- rr clirp.rtnratF•c and nrnrrram ref-St-.F. cv rnrift, etafFc int...II -IA.11a but nett 21. Do the reviews include a sampling of various types of classified information in document and electronic 21. — Yes ■No ■NA formats? 22. How do you ensure that the materials reviewed provide a representative sample of the agency's classified information? (Indicate if NA.) Documents are selected for review in cooperation with site personnel who are familiar with the type of materials produced by the site. However, contractors are not required to count classified pages produced because of the additional costs that would be incurred by the NRO, so the documents reviewed may not be a representative 1 n-11 1 . 11 1 . A . .1 lrat-1,-IL 1 !11 1!1 I. •. nn 1 nn • 11 1 . .1 23. How do you determine that the sample is proportionally sufficient to enable a credible assessment of your agency's classified product? (Indicate if NA.) We do not attempt to do this as it would increase costs to the NRO (as explained in item 22 above). 24. Who conducts the review of the classified product? (Indicate if NA.) PSOs and Classification Management Officers (CMOs). 25. Are the personnel who conduct the reviews knowledgeable of the classification and marking requirements of E.O. 13526 and its implementing directive? 26. Do they have access to pertinent security classification guides? (Indicate if NA.) 27. Have appropriate personnel been designated to correct misclassification actions? (Indicate if NA.) If so, identify below. ■No ■NA ❑ Yes ■No ■NA 25. D Yes 26. 27. El Yes ■No ■NA Frequency 28. How frequently are self-inspections conducted? Annually. 29. Describe the factors that were considered in establishing this time period? The time period is defined in the NRO Security Manual (NSM). INFORMATION SECURITY OVERSIGHT OFFICE AUTHORIZED FOR LOCAL REPRODUCTION 32 CFR 2001 E.O. 13526 Enclosure 2 NRO APPROVED FOR RELEASE 28 August 2014 Coverage 30. How do you determine what offices, activities, divisions, etc., are covered by your self-inspection program? assessed? What agency activities are Self-assessments are to be completed on each contractor SCIF. All contractor activities are assessed. 31. How is the self-inspection program structured to assess individual agency activities and the agency as a whole? Contractor SCIF locations far outnumber government SCIF locations in the NRO. Government locations are relatively few in number and have professional government security officers assigned who can monitor safeguarding and classified information production and correct errors as they occur. We chose to concentrate on . 1 rni 1 .. • Special Access Programs (SAP) (If your agency does not have the authority to create SAPs, indicate NA.) 32. If your agency has any special access programs, are self-inspections of the SAP programs conducted annually? 33. Do the self-inspections confirm that the agency head or principal deputy has reviewed each special access program annually to determine if it continues to meet the requirements of E.O. 13526? 34. Do the self-inspections determine if officers and employees are aware of the prohibitions and sanctions for creating or continuing a special access program contrary to the requirements of E.O. 13526? 32. 33. 34• ■No ■NA —I Yes III No ■NA Yes III No ■NA ❑ Yes ❑ Reporting 35. What is the format for documenting self-inspections in your agency? Self-assessments are documented using the self-assessment review tool in the NSM, Appendix B. For formal assessments, an out-briefing is provided to site security staff and other site senior management identifying ori iritu nrnorrarn c 1 'nor:wet. nhcanratinna and am, 36. Who receives the reports? cAri 1 rift! "ha et nr nti ni.c " fl I c nrafArPrl di Irina the frorm it The OS&CI ISAP Manager. 37. Who compiles/analyzes the reports? The ISAP Manager and the responsible PSO analyze the report. 38. How are the findings analyzed to determine if there are problems of a systemic nature? The ISAP Manager provides to the sponsoring Government Program Security Officer (GPSO) for review and subsequent action. 39. How and when are the results of the self-inspections reported to the SAO? The DOS&CI determines when results warrant informing the SAO. 40. How is it determined if corrective actions are required? The Government PSO and security stakeholder(s) reviews determine if corrective actions are required. 41. Who takes the corrective actions? The assessed site. 42. How are the findings from your agency's self-inspection program distilled for the annual report to the Director of ISOO? The OS&CI Security Policy Staff (SPS) tasks the ISAP Manager to distill the findings and provide them to SPS for inclusion in the annual report. 43. Has the SAO formally endorsed this self-inspection report? IN FORMATION SECURITY OVERSIGHT OFFICE 43. ■Yes ❑ No AUTHORIZED FOR LOCAL REPRODUCTION 32 CFR 2001 E.O. 13526 NRO APPROVED FOR RELEASE 28 August 2014 PART D: A summary of the findings of your agency's self-inspection program The summary should present specific, concise findings from your self-inspection program for each of the required program areas below. It is not a description of the requirements of the agency's CNSI program. Rather, the summary outlines the essential self-inspection findings based on the compilation and/or distillation of the information contained in the agency's internal self-inspection reports, checklists, etc. In large agencies where findings are drawn from multiple agency offices and activities, the findings that are reported here may be the most significant or most frequently occurring. 44. Original Classification: OCAs are senior officers and mainly exercise their authority through the signing of classification guides for information unique to their activity. While OCA decisions get implemented through the classification guide, written documentation of individual OCA decisions is difficult or impossible to locate. OCA's were not using the appropriate OCA classification block but a derivative block. OS&CI Policy Branch will issue clear instructions for all classification guides to contain the appropriate OCA classification block. 45. Derivative Classification: NRO activities result in complicated Power Point slide briefings with complex tables, diagrams, and text boxes describing engineering and R&D activities. Under reduced manning from sequestration and budget cuts which have resulted in a loss of over 1,000 man-years of experience across the NRO, derivative classifiers struggle to get all derivative markings accurate after they have compiled difficult subject matter on compressed time lines under stressful conditions. It is admirable that individuals perform as well as they do. 46. Declassification: Not included in self-inspection. 47. Safeguarding: Regular conduct of exercises provides vital feedback to the physical security program. Exercises identify areas for corrective measures, enhancements, validates current tactics techniques and procedures (TTP) and the adoption/employment of new TTP to meet a dynamic threat environment. Regular inspections/audits are essential to ensuring status and validity of issued IC badges and conformity to physical security requirements. Risk assessments/physical security assessments provide a helpful "outside" perspective to site security offices. 48. Security Violations: The ISAP program is the formal mechanism by which we corroborate self-inspections. Included in these formal reviews is an assessment of the respective security violation program and trends. In addition, each component Security team evaluates Security incidents and violations by tracking them according to general broad categories. During this past FY, the majority (63%) of incidents/violations were related to categories within personnel electronic devices in SCIFs. Other categories that have multiple occurrences indicating potential trends are data 49. Security Education and Training: 100% of personnel assigned to the NRO are required to complete an SCI indoctrination briefing to include signing a Non-Disclosure Agreement. E.O. 13526 is called out specifically so that personnel fully understand their responsibilities and requirements to protect classified information. This message is repeated by the release of awareness videos and reminders throughout the year; to include presentations, written materials, and training. Specifically, OS&CI incorporates classification management questions within the Annual Security Refresher 50. Management and Oversight: Government oversight of NRO-sponsored SCIFs is achieved in a multi faceted manner. Program Security Officers, Physical/Technical, and Computer Security Officers review self-assessment results and participate in on-site reviews. Some program findings for FY 13 were identified in the following areas: • Standard Operating Procedures (SOPs) require more detail and more frequent revision to stay up-to-date with security requirements. INFORMATION SECURITY OVERSIGHT OFFICE AUTHORIZED FOR LOCAL REPRODUCTION 32 CFR 2001 E.O. 13526 NRO APPROVED FOR RELEASE 28 August 2014 PART E: An assessment of the findings of your agency's self-inspection program The assessment discerns what the findings mean. The assessment is an evaluation of the state of each element of your agency's CNSI program based on an analysis of the specific, concise findings of the self-inspection program. It reports what you have determined the findings indicate about the state of your agency's CNSI program. The assessment should inform the SAO and other decision makers of significant issues that impact the CNSI program. It should be used to determine how security programs can be improved, whether the agency regulation or other policies and procedures must be updated, and if necessary resources are committed to the effective implementation of the CNSI program. The assessment should report trends that were identified during the reporting period across the agency or in particular activities, as well as trends detected by making comparisons with earlier reporting periods. It can be used to support assertions about the successes and strengths of an agency's program. 51. Original Classification: While OCA's produce timely and sufficient Classification Guides, decisions are not normally documented outside the guide by a separate source document. OCAs are not using an OCA style classification block but this will be corrected soon when specific detailed policy is issued by Security Policy. 52. Derivative Classification: Derivative classifiers are still wrestling with proper portion marking and classification of complex power point slide presentations and other documents concerning difficult subject matter and formats. To try and stem this tide, we are adding more classification management questions to our ASR. Dwindling budgets, reduced manpower, and "greening" (reducing) of salaries has reduced longevity, increased turnover, and reduced portion marking proficiency. 53. Declassification: Not included in self-inspection. 54. Safeguarding: Awareness and education programs are vital to ensuring the workforce maintains awareness of security policy and procedures. Regular and aperiodic exercises, inspections, and audits provide crucial inputs that are indispensable to ensuring that the physical security program is current and effective. Key challenges are maintaining adequate funding to replace aging, malfunctioning, and obsolete security equipment and training and education for new personnel. The NRO has an organization-level process for the Assessment and Authorization 55. Security Violations: The NSM detail the NRO process for reporting and investigating security incidents, infractions and violations. Appropriate and prompt corrective actions were taken to mitigate the severity of the infraction/violation, and to sanction the offender via management, counterintelligence, and personnel security processes. Infractions and violations are centrally tracked in the Security Log (the NRO incident/violation database). This database is managed by the Program Security Officers in each directorate and office, and enables the PSO to automatically 56. Security Education and Training: OS&CI works closely with PSOs, Counterintelligence personnel, and the Integrated Self Assessment Program to determine any trends or specific areas that need an additional educational awareness campaign. Security communications are then targeted, utilizing large scale efforts, per a topic area and audience for best impact results. The NRO is adding additional classification management questions to the Annual Security Refresher to better satisfy the derivative classification training requirement. OCAs complete yearly training provided by 57. Management and Oversight: The NRO has a very mature Security management and oversight program. Over the past FY, much greater emphasis has been placed on ensuring all sites and facilities accomplished the self-assessments and submited the findings to the Government within the mandated time requirements. This improved management oversight has made an impact. Our self-inspection program coupled with security officer visits, and formal team assessments provide managers a report card on the health of our security programs. When negative trends are identified, INFORMATION SECURITY OVERSIGHT OFFICE AUTHORIZED FOR LOCAL REPRODUCTION 32 CFR 2001 E.O. 13526 NRO APPROVED FOR RELEASE 28 August 2014 PART F: Focus Questions Answer the questions below. If the response identifies a deficiency, it should be explained in Part D, Summary of Findings, under the relevant program area, and should be addressed in Part H, Corrective Actions. Training for Original Classification Authorities Original classification authorities are required to receive training in proper classification and declassification each calendar year. (Section 1.3(d) of E.O. 13526 and § 2001.70(c) of 32 C.F.R. Part 2001) (Indicate NA ifyour agency does not have original classification authority) 58. Does agency policy require training for original classifiers? 58. Yes ■No ■NA 59. Has the agency validated that this training has been received? 59. I Yes ■No ■NA ❑ 100 60. What percentage of the original classification authorities at your agency has received this training? 60. 61. Have any waivers to this requirement been granted? 61. III Yes Actual ■Estimated No ■NA Persons who Apply Derivative Classification Markings Persons who apply derivative classification markings are required to receive training in the proper application of the derivative classification principles of E.O. 13526, prior to derivatively classifying information and at least once every two years thereafter. (Section 2.1(d) of E.O. 13526 and § 2001.70(d) of 32 C.F.R. Part 2001) (Indicate NA if your agency does not have any personnel who derivatively classify information) 62. Does agency policy require training for derivative classifiers? 62. • Yes Ill No III NA 63. Has the agency validated that this training has been received? 63. Yes ■No ■NA 64. What percentage of the derivative classifiers at your agency has received this training? 64. ■100 Actual Estimated 65. ■Yes i No Initial Training All cleared agency personnel are required to receive initial training on basic security policies, principles, practices, and criminal, civil, and administrative penalties. (0 2001.70(6) of 32 C.F.R. Part 2001) 66. Does agency policy require initial training? 66. ❑ Yes ■No 65. Have any waivers to this requirement been granted? 67. Has the agency validated that this training has been received? 67. ❑ 68. What percentage of cleared personnel at your agency has received this training? 68. 100 70. Has the agency validated that this training has been received? 70. 71. What percentage of the cleared employees at your agency has received this training? 71. 100 Actual Yes ■NA ■No LI Actual • Estimated Annual Refresher Training Agencies are required to provide annual refresher training to all employees who create, process, or handle classified information. (§ 2001.70() of 32 C.F.R. Part 2001) 69. Does agency policy require annual refresher training? 69. Yes ■No ❑ rl Yes ■No ■Estimated Identification of Derivative Classifiers on Derivatively Classified Documents Derivative classifiers must be identified by name and position, or by personal identifier on each classified document. (Section 2.1(b)(1) of E.O. 13526 and § 2001.22(b) of 32 C.F.R. Part 2001) (Indicate NA ifyour agency does not derivatively classify information.) 72. Does your agency's review of classification actions evaluate if this requirement is being met`' 72. Yes ■No ■NA 73. What percentage of the documents sampled meet this requirement? 73 . 74. What was the number of documents reviewed for this requirement? 74. 87 166,130 pages List of Sources on Documents Derivatively Classified from Multiple Sources A list of sources must be included on or attached to each derivatively classified document that is classified based on more than one source document or classification guide. (§ 2001.22c(l)(ii) of 32 C.F.R. Part 2001) 75. Does your agency's review of classification actions evaluate if this requirement is being met? 75. • Yes ■No ■NA 76. What percentage of the documents sampled meet this requirement? 76. 88 77. What was the number of documents reviewed for this requirement? INFORMATION SECURITY OVERSIGHT OFFICE 7 7. 166,130 pages AUTHORIZED FOR LOCAL REPRODUCTION 32 CFR 2001 E.O. 13526 Enclosure 2 a ca alai The NRO APPROVED FOR RELEASE 28 August 2014 mauct nvatuations performance contract or other rating system of original classification authorities, security managers, and other personnel whose duties significantly involve the creation or handling of classified information must include a critical element to be evaluated relating to designation and management of classified information. (Section 5.4(d)(7) of E.O. 13526 ) 78. Does agency policy require this critical element in the performance evaluations of personnel in the categories required by E.O. 13526? 79. Has the agency validated that this critical element is included in the performance evaluations of personnel in the categories requited by E.O. 13526? 80. What percentage of such personnel at your agency has this element in their performance evaluations? OCA Delegations ■Yes No 79.■Yes 0 No 78. ❑ 80. 50% Actual • Estimated OCA delegations shall be reported or made available by name or position to the Director of the Information Security Oversight Office. (Section I .3(c)(5) of E.O. /3526). This can be accomplished by an initial submission followed by updates on a frequency determined by the £40, but at least annually. 02001.11 (c) and §2001.90(a) of 32 C.F.R. Part 2001) 81. Have there been any changes in the delegations, by name and position, of original classification authority in your agency since delegations were reported to ISOO in 2010. 82. Have all delegations been limited to the minimum required based on a demonstrable and continuing need to exercise this authority? 83. If changes have been made, have they been reported, by name or position, to ISOO? 81. 82. 83. ■Yes No ■NA Yes MI No I. NA ■Yes ■No NA Classification Challenges An agency head or SAO shall establish procedures under which authorized holders of information. including authorized holders outside the classifying agency, are encouraged and expected to challenge the classification of information that they believe is improperly classified or unclassified. (Section 1.8(b) of E.O. 13526) Classification challenges must be covered in the trainingfor original classification authorities and persons who apply derivative classification markings. 02001.7 1 and (§2001.71(d) of 32 C.F.R. Part 2001) 84. Has your agency established procedures under which the classification of information can be challenged in accordance with section 1.8(b) of E.O. 13526 and §2001.14 of 32 C.F.R. Part 2001? 85. Does your agency's training for OCAS and for personnel who apply derivative classification markings cover classification challenges? 86. Does your agency's training for all other cleared personnel cover classification challenges? 84• Yes 85. ■Yes 86. III Yes PART G: Findings of the Annual Review of Agency's Original and Derivative Classification Actions ■No ■NA ❑ ❑ No ■NA No In this section provide specific information with regard to the findings of the annual review of the agency's original and derivative classification actions to include the volume of classified materials reviewed and the number and type of discrepancies identified. 87. Indicate the volume of classified materials reviewed during the annual review of agency's original and derivative classification actions. (If your agency does not classify information, indicate NA.) 87. 166,130 pages 88. Indicate the number of discrepancies found during the annual review of classification actions for each category below. For additional information on marking, consult the ISOO marking guide. 88 (a) Over-classification: Information does not meet the standards for classification. 88 (a) 28,798 88 (b) Overgraded/Undergraded: Information classified at a higher/lower level than appropriate. 88 (b) 42,779 88 (c) Declassification: Improper or incomplete declassification instructions or no declassification instructions. 88 (c) 24,043 88 (d) Duration: a shorter duration of classification would be appropriate. 88 (d) 13,889 88(e) Unauthorized classifier: A classification action was taken by someone not authorized to do so. 88(e) 0 88 (f) "Classified By" line: A document does not identify the OCA or derivative classifier by name and position or by personal identifier. 88 (f) 22,368 88 (g) "Reason" line: an originally classified document does not cite a reason from section 1.4 of E.O. 13526. 88 (g) 0 88 (h) "Derived From" line: A document fails to cite, or cites improperly, the classification source. The line should include type of document, date of document, subject, and office/agency of origin. 88 017,096 88 (i) Multiple sources: A document cites "Multiple Sources" as the basis for classification, but a list of these sources is not included on or attached to the document. 88 (i) 19,190 88(j) Marking: A document lacks overall classification markings or has improper overall classification markings. 88 (j) 34,141 88 (k) Portion Marking: The document lacks some or all of the required portion markings. 88 (k) 59,937 88(1) Instructions from a classification guide are not properly applied. 88 (1) 17,070 88 (m) Other: . 88 (m) 0 INFORMATION SECURITY OVERSIGHT OFFICE AUTHORIZED FOR LOCAL REPRODUCTION 32 CFR 2001 E.O. 13526 Enclosure 2 NRO APPROVED FOR RELEASE 28 August 2014 • __ __..._ ..-..-... 89. Describe actions that have been taken or are planned to correct identified program deficiencies, marking discrepancies, or misclassification actions, and to deter their reoccurrence. OS&CI Policy Branch will issue written instructions that all Classification Guides and original classification decisions will use an OCA style classification block. We plan to issue NRO-wide, monthly, short written educational reminders of the most error-prone mistakes reported in item 88 which will also include the proper way to classify and mark materials. PART I: Best Practices Best practices are those actions or activities that make your self-inspection program and/or CNSI program more effective or efficient. They set your program apart through innovation or by exceeding the minimum program requirements. These are practices that may be utilized or emulated by other agencies. 90. Describe best practices that were identified during the self-inspection. One contractor site developed a database that allows self-assessments to be completed by each program area at that site. The database can apply filtering and reporting capabilities, thereby allowing managers to focus resources on a wide-range of security-related disciplines. This type of approach and comprehensive tool development had not been previously seen by the ISAP Program. PART J: Explanatory Comments Use this space to elaborate on any section of this form. If more space is needed, provide as an attachment to this fonn. Provide explanations for any significant changes in trends/numbers from the previous year's report. Item 16. All security directives and instructions are issued by the DOS&CI and are reviewed and updated annually but not as part of the self-inspection. All directives and instructions are maintained on-line and are accessible to all government employees and contractors. (b)(3) 10 USC 424 Item 27. All government and contractor PSOs and CMOs (about ' ' 'ndividuals) are authorized to correct incorrect classification, incorrect use of SCI control channels, an• incorrect dissemination restrictions. Item 68. CIA personnel (including CIA contractors with Agency Data Network or staff-like access) at the NRO are required to take the CIA "2013 Derivative Classifier Training" by their parent agency. All other government and contractors at the NRO take their training through the Annual Security Refresher briefing. Item 78. The NRO is comprised of government individuals from various agencies. Parent agencies set the rules for their performance contract or rating system which cannot be altered by the NRO. The percentage given represents the percentage of individuals from agencies that require a security performance evaluation statement. For !SOO Use Only ISOO Analyst: Date QC: Analyst Initials: AUTHORIZED FOR LOCAL REPRODUCTION 32 CFR 2001 E.O. 13526 UNCLASSIFIED NRO APPROVED FOR RELEASE 28 August 2014 NATIONAL RECONNAISSANCE OFFICE 14675 Lee Road Chantilly, VA 20151-1 71 5 12 October 2012 MEMORANDUM FOR OFFICE OF THE UNDER SECRETARY OF DEFENSE FOR INTELLIGENCE SECURITY DIRECTORATE SUBJECT: Annual Self-Inspection Report REFERENCES: (a) OUSD(I) Memorandum, Annual Senior Agency Official (SAO) Self-Inspection Program Report for Classified National Security Information, 2 October 2012 (b) Memorandum of Agreement between the Secretary of Defense and the Director of National Intelligence concerning the National Reconnaissance Office, 21 September 2010 (c) DoDI 5200.01, DoD Information Security Program and Protection of Sensitive Compartmented Information, 9 October 2008 The National Reconnaissance Office (NRO) is providing the attached Self-Inspection Report as requested in reference (a). In accordance with Director, National Reconnaissance Office authorities in reference (b) and (c) it should be noted that the NRO does not administer a standard DoD Information Security Program based on DoDM 5200.01-V1 thru V3 and, therefore, some of the items in the attached checklist are not applicable and have been noted as such. My point of contact for questions concerning this submission is (b)(3) 10 USG 44- . Jamieson Burnett irector, Office of Security and Counterintelligence Attachment: NRO Annual Self - Inspection Report for 2012 UNCLASSIFIED UNCLASSIFIED INFORMATION SECURITY PROGRAM SELF-INSPECTION CHECKLIST TITLE/SUBJECT/ACMATWFUNCRONAL AREA Information Security Program Self-Inspection Checklist NO. STEM NRO APPROVED FOR RELEASE 28 August 2014 National Reconnaissance Office 045 R DATE Security Manager 11 October 2012 EO 13526 CLASSIFIED NATIONAL SECURITY INFORMATION AND IMPLEMENTING DIRECTIVE REQUIREMENTS PART 1. DESCRIPTION OF SELF-INSPECTION PROGRAM: A description of the DoD Components self- inspection program should include activities assessed, program areas covered, and methodology utilized. The description must demonstrate how the self-inspection program provides the senior agency official with the information necessary to assess the effectiveness of the classified national security information program within the individual Component activities and the Component as a whole. It should include the following: 1. Responsibility for the program: (1) Whom does the senior agency official designate to assist in directing and administering the self-inspection program? Answer . The Director of Security and Counterintelligence (DOS&CI) is provided a Letter of Instruction by the Director, NRO which assigns his responsibilities. (2) How is the program structured to provide the senior agency official with the information necessary to assess the agency's classified national security information program? Answer: The DOS&CI advises the Senior Agency Official (SAO) when the DOS&CI believes events warrant advising the SAO. The NRO Integrated Security Assessment Program (ISAP) results are also reported to the SAO thru the annual Management Control Plan Statement of Assurance (MCPSOA). (b)(3) 10 USC 424 (3) Who conducts the self-inspections? Answer: NRO self-inspections are part of the NRO ISAP. Because contractors make upgAof the total NRO workforce and have the overwhelming number of Sensitive Compartmented Information Facilities (SCIFs), ISAP is a collaborative process between Government and industry to identifi , and address security vulnerabilities, provide datfornlysi,findings e tmcuriyseand.Th may lead to identification and definition of risk mitigation practices, and enable sharing of best security practices across government and industry. The primary purpose of the ISAP is to ensure the proper safeguarding of classified information through a single comprehensive review by various components of the Office of Security and Counterintelligence (OS&CI). ISAP integrates reviews utilizing program security, classification management, transportation and transmission of classified information, physical and technical accreditation, information systems security, personnel security, and Counterintelligence (CI) perspectives. The integrated assessment evaluates implementation of and ensures compliance with, established security policies, procedures, and plans at all NRO government and contractor location& Site personnel conduct/document security self-assessments per requirements stated in the NRO Security Manual (NSM). Security Officers will conduct self-assessments of their SCIFs at least annually. For the reporting period there were 343 site self-assessments. The ISAP Manager or designee reviews the site assessments and enters a copy into an NRO database listing each NRO sponsored facility. Based on the self-assessments, the ISAP Manager, Program Security Officers (PSOs) and stakeholders discuss findings and formulate recommendations for a formal assessment, if required OS&CI stakeholders represent the major OS&CI divisions and program office security staffs, including, but not limited to, PSOs, Physical/Technical Certification Officers, and Security Certification Officers. Stakeholders will develop and provide ISAP candidates to the ISAP Selection Board. Each ISAP recommendation shall contain detailed factors used to formulate the recommendation. Recommendation for site visits is then provided to the selection board Sites are selected based on ring proximity, resources, budgetary constraints, time since last assessment, and random sampling. A team composition is proposed for each site visit and a Lead PSO is selected The Assessment Team will, at a minimum, consist of a Government PSO and an OS&Cl/Facilities and Information Security Division (F&ISD) representative. Additional team members will be added as needed based on site size, mission, facility risk, and subject areas being assessed. An out-briefing is provided to site security site - and other site senior management identfying security program successes, observations, and any security "best practices" discovered during the formal assessment. The results are then loaded into the facility database that contains information from all previous visits with any problem areas or "best practices" noted. A final report requiring corrective actionsto be taken within 90 days of the date of UNCLASSIFIED 1 UNCLASSIFIED INFORMATION SECURITY PROGRAM SELF-INSPECTION CHECKLIST TITLESUBJECT/ACTIVITY/FUNCT1 ONAL AREA Information Security Program Self-Inspection Checklist NO. I NRO APPROVED FOR RELEASE 28 August 2014 National Reconnaissance Office OPR DATE Security Manager 11 October 2012 ITEM report is issued by the DOS&CI. The assessed site is required to provide follow-up reports of corrective action to the responsible PSO and the ISAP Manager every 90 days until all corrective actions are complete. The responsible PSO monitors all mitigation actions. Reports of corrective action are loaded into the NRO facilities database for historical purposes. For the reporting period, 16 formal team assessments were performed An additional 9 formal specific-issue reviews were conducted There were an additional 1,491 visits by OS&CI stakeholders to contractor SCIFs. (4) How is the senior agency official involved in the program? Answer: The DOS&CI keeps the SAO advised of trends and issues developed by the ISAP. The NRO ISAP results are also reported to the SAO thru the annual MCPSOA. 2. Approach: (1) What means and methods are employed in conducting self-inspections? Answer: For formal assessments, the Assessment Team evaluates implementation, and ensures compliance with, established NRO security policies, procedures, and plans. (2) Are different types of self-inspections conducted? If so, describe each of them. Answer: Formal assessments will vary based on the experience of the lead PSO and the stakeholders with the facility and items noted in the self-evaluation report as well as the areas of responsibility of the attending subject matter experts. However, the objective for all is to identify and address security vulnerabilities, provide data for analysis, and identift system security issues and trends. (3) Do the self-inspections evaluate adherence to the principles and requirements of E.O. 13526 and its implementing directive and the effectiveness of agency programs covering: • Original classification? Answer: Since Original Classification items only apply to 13 government employees who are Original Classification Authorities (OCA) at NRO Headquarters, a formal tasking is sent to Program Security Officers supporting the OCA to determine the date the OCA received their annual briefing and the number of original classification decisions they made during the reporting period. Experience has shown that not all of the OCAs make individual OCA decisions every year but most require their authority to sign classification guides for their area of responsibility. For the reporting period there, nine OCA decisions were made. • Derivative classification? Answer: Included. In NRO Implementing Instructions released on 31 May 2011, derivative classifiers were instructed to include in the classification block a personal identification number rather than their name to protect their identity and association with the NRO. This "Classification ID (CLID)" number exists in the NRO Access Database so the specific individual with that number can always be identyled Employees of other agencies, who already have an ID number assigned by their parent agency, will use that number instead Headquarters NRO derivative classifiers have their PSO available for questions regarding classification and marking and to review their derivatively classified documents for format and accuracy of classffication and marking. Available on the OS&CI website are the Order, Information Security Oversight Office (IS00) Implementing Directive and Marking booklet, videos and documents that explain the correct way to classify and mark documents, the Controlled Access Program Coordination Office (CAPCO) register and manual, over 120 Frequently Asked Questions with answers that are posted about portion marking a Security Policy hotline that will answer their questions in real-time, and numerous other experts who are available to answer their questions. Once the document is distributed, they face additional scrutiny from any security or classification management officer who reads it or from subject matter experts who point out classification and marking errors to security officers. The ISAP team visiting a site will review a sample of derivatively classified documents to point out errors in classification and marking, omissions of required information, and to make suggestions for improvement. • Declassification? Answer: The NRO has a formal declassification program which restricts to one office the authority to officially declassify NRO information and release it to the public, and which is not included in the self-inspection program. The results of this program are reported in the SF 311 report provided to USD(I) in October 2012. The NRO Declassification Guide (known as the Review and Redaction Guide) is updated and approved by the UNCLASSIFIED 2 UNCLASSIFIED INFORMATION SECURITY PROGRAM SELF-INSPECTION CHECKLIST TITLE/SUEWECT/AC71VITY/FUNCT1ONAL AREA Information Security Program Self-Inspection Checklist NO. NRO APPROVED FOR RELEASE 28 August 2014 National Reconnaissance Office OPR DATE Security Manager 1 1 October 2012 ITEM DNRO each year. It is currently undergoing review by the Interagency and is expected to be approved by the end of 2012. • Security Classification Appeals Panel Safeguarding? Answer: Included • Security violations? Answer: Included • Security education and training? Answer: Included • Management and oversight? Answer: Included (4) Do the self-inspections include a review of relevant security directives and instructions, as well as interviews with producers and users of classified information? Answer: All directives and instructions are issued by the DOS&Cl and are reviewed and updated annually. All directives and instructions are maintained on-line and are accessible to all government employees and contractors. (5) Do the self-inspections include reviews of representative samples of your Component's original and derivative classification actions? • Do these reviews encompass all Component activities that generate classified information? Answer: There are hundreds of individual activities that can generate classified information. While the annual self-assessment questionnaire covers 343 of these activities, the ISAP formal assessment inspects only a small percentage of these activities yearly. However, the Program Security Officers, Contractor Program Security Officers, and Classification Specialists review hundreds of classified documents yearly and provide direction to originators to correct those that are improperly marked. o How do you identify the activities to which this applies? Answer: Site personnel conduct/document security self-assessments per requirements stated in the NSM • Do the reviews include a sampling of various types of classified information in document and electronic formats? o How do you ensure that the materials reviewed provide a representative sample of the Component's classified information? Answer: Documents are selected for review in cooperation with site personnel who are familiar with the type of materials produced by the site. However, contractors are not required to count classified pages produced because of the additional costs that would be incurred by the NRO, so the documents reviewed may not be a representative sample. o How do you determine that the sample is proportionally sufficient to enable a credible assessment of your Component's classified product? Answer: We do not attempt to do this as it would increase costs to the NRO (as explained above). • Who conducts the review of the classified products? o Are they knowledgeable of the classification and marking requirements of E.O. 13526 and its implementing directive? Answer: Yes o Do they have access to pertinent security classification guides? Answer: Yes • Have appropriate personnel been designated to correct misclassification actions? If so, identify. Answer: All Program Security Officers and Classification Managemeni Specialists are authorized to correct misclassification, incorrect use of SCI channels, and incorrect dissemination restrictions. 3. Frequency: (1) How frequently are self-inspections conducted? Answer: Annually. (2) What factors were considered in establishing this time period? Answer: Time period is defined in the NSM. UNCLASSIFIED 3 UNCLASSIFIED INFORMATION SECURITY PROGRAM SELF-INSPECTION CHECKLIST TITLE/SUBJECT/ACTIVITY/FUNCTIONAL AREA Information Security Program Self-Inspection Checklist NO. NRO APPROVED FOR RELEASE 28 August 2014 National Reconnaissance Office CPR DATE Security Manager 11 October 2012 ITEM 4. Coverage: (1) How do you determine what program elements and Component activities are covered by your self-inspection program? Answer: Self-assessments are to be completed on each contractor SCIF. (2) What Component activities are assessed? Answer: All contractor activities are assessed. (3) How is the program structured to assess individual Component activities and the Component as a whole? Answer: Contractor locations far outnumber government locations in the NRO. Government locations are relatively few in number and have professional government security officers assigned who can monitor safeguarding and classified information production and correct errors as they occur. We chose to concentrate on contractorfacilities which are visited relatively infrequently. The conditions at contractor locations are not directly applicable to government locations. (4) If your Component has any special access programs (SAP), are self-inspections of the SAP programs conducted annually? Answer: Most SAPs are reviewed as part of the ISAP program. The ISAP formal assessment team has PSOs assigned that are briefed for most SAPs. In addition. the NRO conducts special annual reviews (in some cases. semi-annual) of the entire Sensitive Activities portfolio. o o Do the self-inspections confirm that the Component head or principal deputy has reviewed each special access program annually to determine if it continues to meet the requirements of E.O. 13526? Answer: The NRO's entire Sensitive Activities portfolio is reviewed and briefed annually to the DNI's Senior Review Group (SRG) who then reports to Congress. Do the self-inspections determine if officers and employees are aware of the prohibitions and sanctions for creating or continuing a special access program contrary to the requirements of E.O. 13526? Answer: Yes. In keeping with E.O. 13526, all Sensitive Activities' compartments that are established terminated, or transitioned (to another program or lower classification) require NRO Special Activities Management Board review and approval, followed by notification to the DNI's Senior Review Group/Controlled Access Program Oversight Committee. 5. Reporting: (1) What format for documenting self-inspections in your Component? Answer: Self assessments are documented using the self-assessment review tool in the NSM, Appendix B. For formal assessments, an out-briefing is provided to site security staff and other site senior management identi&ing security program successes, observations, and any security "best practices" discovered during the formal assessment. The results are then loaded into the facility database that contains information from all previous visits with any problem areas or "best practices" noted A final report requiring corrective actions to be taken within 90 days of the date of report is issued by the DOS&CI. The assessed site is required to provide follow-up reports of corrective action to the responsible PSO and the ISAP Manager every 90 days until all corrective actions are complete. The responsible PSO monitors all mitigation actions. Reports of corrective action are loaded into the NRO facilities database for historical purposes. (2) Who receives the reports? Answer: The OS&CI ISAP Manager. (3) Who compiles/analyzes the reports? Answer: The ISAP Manager and the responsible PSO analyze the report. (4) How are the findings analyzed to determine if there are problems of a systemic nature? Answer: The ISAP Manager provides to the sponsoring Government Program Security Officer (GPSO) for review and subsequent action. (5) How and when are the results of the self-inspections reported to the senior agency official? Answer: The DOS&CI determines when results warrant informing the SAO. (6) How is it determined if corrective actions are required? Answer: The GPSO and security stalceholder(s) review. UNCLASSIFIED 4 UNCLASSIFIED INFORMATION SECURITY PROGRAM SELF-INSPECTION CHECKLIST TITLE/SUBJECTIACTIVITY/FUNCTIONAL AREA National Reconnaissance Office OPR Information Security Program Self Inspection Checklist NO. NRO APPROVED FOR RELEASE 28 August 2014 Security ITEM DATE Manager 11 October 2012 I I (7) Who takes the corrective actions? Answer: The assessed site. (8) How are the findings from your Component's self-inspection program distilled for the annual report to the Director o f ISOO? Answer: The OS&CI Security Policy Staff (SPS) tasks the ISAP Manager to distill the findings and provide them to SPS for inclusion in the annual report. Self-Inspection Program Description here: Description include in italics under questions above. PART 2. ASSESSMENT & SUMMARY: ASSESSMENT The assessment is an evaluation of the state of each element of your componenVs classified national security information program based on an analysis of the findings of the selfinspection program. It should consider if the program element is being effectively implemented in accordance with the Order and Directive and DoD 5200.01-M. It should consider whether the findings indicate that the regulation or other policies or procedures may need to be updated, and it should take into account other program information such as the Standard Form 311, "Agency Security Classification Management Program Data." If a particular element does not apply to a component (e.g., original classification authority) the report should explain this. • Original classification Rating: Satisfactory • Derivative classification Rating: Document creation: Satisfactory Training: Deficient due to cost • Declassification Rating: Satisfactory • Safeguarding Rating: Satisfactory • Security violations: Rating: Satisfactory • Security education and training Rating: Satisfactory except for Derivative Classifier training which is not required due to cost • Management and oversight Rating: Satisfactory SUMMARY: The summary should report the findings from the self-inspection program within each of the program areas. This information should support the assessment. • Original classification Rating: Satisfactory • Derivative classification Rating: Document creation: Satisfactory Training: Deficient due to cost • Declassification Rating: Satisfactory • Safeguarding Rating: Satisfactory • Security violations Rating: Satisfactory • Security education and training Rating: Satisfactory except for Derivative Classifier training which is not required due to cost • Management and oversight Rating: Satisfactory Assessment & Summary here: included in italics under headings above. UNCLASSIFIED 5 UNCLASSIFIED INFORMATION SECURITY PROGRAM SELF-INSPECTION CHECKLIST TITLE/SUBJECT/ACT1VITYIFU KnONAL AREA Information Security NO. Program Self-Inspection Checklist NRO APPROVED FOR RELEASE 28 August 2014 National Reconnaissance Office OPR DATE Security Manager 11 October 201 2 ITEM PART 3. FOCUS QUESTIONS: FOCUS QUESTIONS: Answer the following focus questions. (1) Training for original classification authorities. (This applies only to Components with original classification authority). (1) Original classification authorities are required to receive training in proper classification and declassification each calendar year (5200.01-V?). What percentage of the original classification authorities at your Component has received this training? (2) Have any waivers to this requirement been granted? Answer: 100% of NRO OCAs have received training. No waivers have been granted. FOCUS QUESTIONS: Answer the following focus questions. (2) Training for persons who apply derivative classification markings. (1) Persons who apply derivative classification markings are required to receive training in the proper application of the derivative classification principles of the E0 13526 prior to derivatively classifying information and at least once every two years thereafter. What percentage of the derivative classifiers at your Component has received this training? (2) Have waivers to this requirement been granted? Answer: Percentage unknown. The DSS and CAPCO Derivative Classifier training is available through the NRO computer network; however, NRO has not made this training mandatory because of the cost of two hours of direct labor charged by each contractor. No waivers have been granted. FOCUS QUESTIONS: Answer the following focus questions. (3) Initial training. (1) All cleared agency personnel are required to receive initial training on basic security policies, principles, practices, and criminal, civil, and administrative penalties. What percentage of these personnel at your Component has received this training? Answer: 100% of new employees have received initial training. FOCUS QUESTIONS: Answer the following focus questions. (4) Refresher training. (1) Components are required to provide annual refresher training to all employees who create, process, or handle classified information. What percentage of these employees at your Component has received this training? Answer: 100% of employees have received refresher training. FOCUS QUESTIONS: Answer the following focus questions. (5) Identity of persons who apply derivative classification markings. (1) Derivative classifiers must be identified by name and position, or by personal identifier on each classified document. What percentage of the documents sampled meet this requirement? (Also, indicate the number of documents reviewed for this requirement.) Answer: NRO personnel are directed to use a personal identifier. 100% of documents have met this requirement. The number of documents reviewed is unknown. FOCUS QUESTIONS: Answer the following focus questions. (6) List of multiple sources. (1) A list of sources must be included on or attached to each derivatively classified document that is classified based on more than one source document or classification guide. What percentage of the documents sampled meet this requirement? (Also, indicate the number of documents reviewed for this requirement.) Answer: 100% of documents have met this requirement. The number of documents reviewed is unknown. UNCLASSIFIED 6 UNCLASSIFIED INFORMATION SECURITY PROGRAM SELF-INSPECTION CHECKLIST T1 TLEPAIBJECT/ACT1VITY1FUNCTIONAL AREA Information Security Program Self-Inspection Checklist NO. NRO APPROVED FOR RELEASE 28 August 2014 National Reconnaissance Office OPR DATE Security Manager 11 October 2012 ITEM FOCUS QUESTIONS: Answer the following focus questions. (7) Performance evaluations. (1) The performance contract or other rating system of original classification authorities, security managers, and other personnel whose duties significantly involve the creation or handling of classified information must include a critical element to be evaluated relating to designation and management of classified information. What percentage of such personnel at your Component has this element in their performance contracts? Answer: The NRO is comprised of government individuals from various agencies. Parent agencies set the rules for their performance contract or rating system. Based on the rules for each parent agency, approximately 40% have this element in their performance contract PART 4. DISCREPANCIES: Specific information with regard to the findings of the annual review of the Component's original and derivative classification actions to include the volume of classified materials reviewed and the number and type of discrepancies identified. 1. "Discrepancies" are instances when the classification and/or marking requirements of the Order, Directive and Agency regulation are not met. Among these are: (1) Overclassification: information does not meet the standards for classification. (2) Overgraded/Undergraded: Information classified at a higher/lower level than appropriate. (3) Declassification: Improper or incomplete declassification instructions or no declassification instructions. (4) Duration: A shorter duration of classification would be appropriate. (5) Unauthorized classifier: A classification action taken by someone not authorized to do so. (6) "Classified By" line: A document does not identify the OCA or derivative classifier by name and position or by personal identifier. (7) "Reason" line: An originally classified document does not cite a reason from section 1.4 of the Order. (8) "Derived From" line: A document fails to cite, or cites improperly, the classification source. The line should include type of document, date of document, subject, and office/agency of origin. (9) Multiple sources: A document cites "Multiple Sources" as the basis for classification, but list of these sources is not included on or attached to the document. (l0)Marking: A document lacks overall classification markings or has improper overall classification markings. (I 1 ) Portion Marking: The document lacks required portion markings. (12) Instructions from a classification guide are not properly applied. For additional information on marking, consult the l)oDM 5200.01-V2. List identified program deficiencies here. Also list actions taken or are planned to correct identified program deficiencies, marking discrepancies, or misclassification actions, and to deter their reoccurrence: Answer: Improper application of portion marking. Individuals will receive additional training and review of their documents by security officers. PART 5. BEST PRACTICES: List best practices that were identified during self inspections here: - Comprehensive security database developed which reflects final adjudication and investigation of security incidents - SCIF decertification process assembled consisting of: -- SCIF decertification checklist -- Sanitization steps for offices -- SCIF decertification roles and responsibilities - The self-assessments, methodology, and supporting application is a model for other industry sites - Comprehensive Open/Close procedures - Plexiglas inspection window and inspection ports for checking penetration of perimeter by HVAC, wiring, etc. - DoD SELF INSPECTION PROGRAM REQUIREMENTS: This portion of the checklist meets specific - requirements for a standard DoD Information Security Program based on the DoDM 5200.01-V1 thru V3. Please answer the following questions below. NO.PROGRAM MANAGEMENT (EO 13526 REQUIREMENTS) I YES I NO I N/A UNCLASSIFIED 7 UNCLASSIFIED INFORMATION SECURITY PROGRAM SELF-INSPECTION CHECKLIST TITLE/SUBJECT/ACTIVITY/FUNCTIONAL AREA 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. IL National Reconnaissance Office OPR Information Security Program Self-Inspection Checklist NO. NRO APPROVED FOR RELEASE 28 August 2014 Security Manager ITEM Has the head of each activity in the Component appointed a security manager to manage and implement the activity's information security program which implements the provisions of DoDM 5200.01-M? (DoDM 5200.01-M, Vol 1, End 2, para 8.b & 9.a) Does the Component Head develop and implement, through the security manager, security instructions necessary for program implementation? (DoDM 5200.01-M, Vol 1, Encl 2, para 9.d) Are sufficient resources and personnel committed to implement the classified national security information security program? (DOOM 5200.01-M, Vol 1, Encl 2, para 6.d) Are OCAs delegated classification authorities in writing? (DoDM 5200.01-M, Vol 1, Encl 4, para 5.c) Has the security manager attended the required training? Note: Training and education shall be provided before, concurrent with, or not later than six months following appointment. (DoDM 5200.01-M, Vol 3, End 5, paras 4.a and 10) Does the security manager conduct security inspections (self-inspections)? (DoDM 5200.01-M, Vol 1, Encl 2, para 7.d) • Is the Component Head informed of the results of such inspection? Does the security manager establish, implement and maintain an effective security education program as required by DoDM 5200.01-M, Volume 3, Enclosure 5, to include initial orientation and continuing/refresher training for assigned members? (DoDM 5200.01-M, Vol 1, End 2, para 7.g & 9.f; Vol 1, Encl 3, Para 6.c; and Vol 3, Encl 5, para 7 & 8) • Do security managers document all security-related training? (DoDM 5200.01-M, Vol 3, End 5, para 11) Are procedures established to prevent unauthorized access to classified information? (DOOM 5200.01-M, Vol 1, End 2, para 7.e) • Note: Examples include implementing visitor controls, restricting combinations to cleared members, establishing end-of-day security checks, etc) Are emergency plans developed for the protection, removal, or destruction of classified material in case of fire, natural disaster, civil disturbance, or terrorist activities to minimize the risk of compromise? (DOOM 5200.01-M, Vol 1, Encl 2, para 9.d) Are procedures established for ensuring that all persons handling classified material are properly cleared and have a need-to-know? (DOOM 5200.01-M, Vol 1, End 3, para 11.a) Does the security manager maintain a continuity handbook? DATE 11 October 2012 x x x x x x x x x x x x x x ORIGINAL CLASSIFICATION (EO 13526 REQUIREMENTS) 12. Are Original Classification Authorities (OCAs) trained on the process and requirements for original classification (DOOM 5200.01-M, Vol 1, Encl 4, para 6), to include? x Applicable standards and categories for classification? (D0DM 5200.01-m, x UNCLASSIFIED 8 UNCLASSIFIED INFORMATION SECURITY PROGRAM SELF-INSPECTION CHECKLIST ITTLE/SUBJECT/ACTIVITYTUNCTIONAL AREA Information Security Program Self-Inspection Checklist NO. NRO APPROVED FOR RELEASE 28 August 2014 National Reconnaissance Office OPR DATE Security Manager 11 October 2012 ITEM 1, Encl 4, para 1) Levels of classification and damage criteria associated with each one? (DoDM 5200.01-M, Vol 1, Encl 4, para 3) • Avoidance of over - classification? (DoDM 5200.01-M, Vol 1, End 4, para 6.f) • Classification prohibitions and limitations? (DoDM 5200.01-M, Vol 1, Encl 4, para 2) • Required markings, including those for dissemination and handling? (DoDM 5200.01-M, Vol 1, Encl 4, para 6.h; Vol 2, Ends 3 & 4) • Determination of declassification instructions? (DoDM 5200.01-M, Vol 1, Encl 4, para 13.a) • Delegations of OCA responsibilities? (DoDM 5200.01-M, Vol 1, Encl 4, para 5 & 5.c) • Classification challenges? (DoDM 5200.01-M, Vol 1, Encl 4, para 22) 13. Have OCAs prepared, as appropriate, classification guides to facilitate the proper and uniform derivative classification of information? (DoDM 5200.01, Vol 1, Encl 4, para 6.h; Vo11, Encl 6, para 1) 14. Do the guides meet the requirements of section 2.2 of E.O. 13526 and section 2001.15 of title 32, Code of Federal Regulations (CFR)? Vol • X X X x x X x X DERIVATIVE CLASSIFICATION (EO 13526 REQUIREMENTS) 15. Are persons who apply derivative classification markings trained on the process and requirements for derivative classification (DoDM 5200.01-M, Vol 1, Encl 4, para 11 & 12), to include? • Identity of derivative classifier? (DoDM 5200.01-M, Vol 2, End 3, para 7 & 8.c. (1)(a)) • Use of source documents, including classification guides? (DoDM 5200.01M, Vol 2, Encl 3, para 8.c.(1)(b), 8.c.(2) & 8.c.(3)) • Declassification instructions? (DoDM 5200.01-M, Vol 2, Encl 3, para 8.c.(1)(d), 8.c.(4)-(9) & 9) • Proper application of markings? See Classification Markings/Document Review section below. (DoDM 5200.01-M, Vol 2, Encl 3 & 4) • Classification challenges (DoDM 5200.01-M, Vol 1, Encl 4, para 22) x x X X X CLASSIFICATION MARKINGS/DOCUMENT REVIEW (EO 13526 REQUIREMENTS) 16. Reviews of original and derivative classification actions shall be conducted in accordance with section 2001.60(c)(2) of title 32, CFR, and should evaluate the classification and marking of documents to include: (DOOM 5200.01-M, Vol 1, Encl 2, para 7.d) • Have the standards of classification been met? (DoDM 5200.01, Vol 1, Encl 4, para 1 & 2) • Could damage to the national security be reasonably expected in the event of unauthorized disclosure? (DoDM 5200.01, Vol 1, Encl 4, para 3) • Have the requirements for original classification of Part 1 of E.0.13526 or for derivative classification in Part 2 of E.O. 13526 been met? • Have the required markings been applied in accordance with E.O. 13526 and Subpart C of title 32, CFR? (DOOM 5200.01-M, Vol 2, para 3) UNCLASSIFIED 9 x X x x X 1 UNCLASSIFIED INFORMATION SECURITY PROGRAM SELF-INSPECTION CHECKLIST 11TLEISUBJECTIACTIVITY/FUNcnONAL AREA Information Security Program Self-Inspection Checklist NO. NRO APPROVED FOR RELEASE 28 August 2014 National Reconnaissance Office OPR DATE Security Manager 11 October 2012 ITEM • • • Overall classification level (DoDM 5200.01-M, Vol 2, Encl 3, para 5) "Reason for Classification" line (originally classified documents only) (DoDM 5200.01-M, Vol 2, Encl 3, para 3.b.(1)(b) & 3.b.(4)) The Agency, Office or Origin, and Date (DoDM 5200.01-M, Vol 2, Encl 3, para 7) • • 17. 18. 19. 20. 21. 22. 23. 24. A "Derived From" line (DOOM 5200.01-M, Vol 2, Encl 3, para 8.c.(1)(b)) A "Classified By" line (DoDM 5200.01-M, Vol 2, Encl 3, para 8.b.(1)(a) & 8.c.(1)(a)) • identification of the sources of classification (DoDM 5200.01-M, Vol 2, End 3, para 8.c.(1)(b), 8.c(2), & 8.c.(3)) • "Declassify On" line (DoDM 5200.01-M,Vol 2, Encl 3, para 8.c.(d)) • Downgrading instructions, if required (DoDM 5200.01-M, Vol 2, Encl 3, para 8.a.(4)) • Page and Portion Markings (DoDM 5200.01-M, Vol 2, Encl 3, para 5 & 6) • Have any unauthorized or invalid markings been applied to documents? Are Agency personnel who conduct reviews of the agency's original and derivative classification actions trained on the classification and marking requirements of E.O. 13526, part 2001 of title 32, CFR, and DoDM 5200.01; and do they have access to pertinent security classification guides? Are "subjects" or "titles" of classified documents marked with the appropriate symbol (TS), (S), (C), or (U) following and to the left of the title or subject? (DoDM 5200.01-M, Vol 2, Encl 3. Para 6.e.(2) & 14) Is each section, part, paragraph, or similar portion of a classified document marked to show the highest level of classification of information it contains, or that it is unclassified? Portion of text shall be marked with the appropriate abbreviations (TS, S, C, or U). (DOOM 5200.01-M, Vol 2, Encl 3, para 6) Are portions within documents containing Restricted Data and Formerly Restricted Data marked with the abbreviation "RD" or "FRO" (e.g. S//RD or TS//FRD)? (DoDM 5200.01-M, Vol 2, Encl 4, para 8.a & 8.b) Are portions within documents containing foreign government or North Atlantic Treaty Organization (NATO) information marked with the foreign classification or NATO and the appropriate classification level (e.g. //GBR S or //NATO C)? (DoDM 5200.01-M, Vol 2, Encl 4, para 4) Is the abbreviation "FOUO" used to designate unclassified portions that contain information that may be exempt from mandatory release to the public under the Freedom of Information Act (FOIA)? (DoDM 5200.01-M, Vol 2, Encl 4, para 10.b & Vol 4, End 3, para 2.c) Are charts, graphs, photographs, illustrations, figures, and similar items within classified documents marked to show their classification? (DoDM 5200.01-M, Vol 2, Encl 3, para 6.a & 18) Are the markings placed within the chart, graph, photograph, illustration, figure, etc. or next to the item? (DoDM 5200.01-M, Vol 2, End 3, para 6.e.(3) & 18) UNCLASSIFIED 10 .. x X X x x x x x x X x x x x x x x UNCLASSIFIED INFORMATION SECURITY PROGRAM SELF-INSPECTION CHECKLIST TITLE /SUBJECT/ACTIVITWFUNCTI ONAL AREA Information Security Program Self-Inspection Checklist NO. 25. 26. 27. 28. 29. NRO APPROVED FOR RELEASE 28 August 2014 National Reconnaissance Office OPR Security Manager ITEM Is the highest classification level placed on the top and bottom of each page containing classified information or marked "unclassified"? (This is called the "banner line") • Do the markings stand out from the balance of the information on the page (must be readily visible)? (DoDM 5200.01-M, Vol 2, Encl 3, para 5) Are TRANSMITTAL documents properly marked to include either its highest classification or a notation "Unclassified when separated from classified enclosures"? (DoDM 5200.01-M, Vol 2, Encl 3, para 15) For ELECTRONIC documents: • Are e-mails, blog entries, bulletin board postings, and other electronic documents marked as finished documents, not working papers? (DoDM 5200.01-M, Vol 2, Enc 3, para 17.a.(2)) • Do e-mails include the appropriate banner line, portion markings, and classification authority block? Is the subject line portion mark the classification of the subject, not the overall classification of the e-mail? (DoDM 5200.01-M, Vol 2, Encl 3, para 17.b) • Do classified URLs contain embedded portion marks? (DoDM 5200.01-M, Vol 2, Encl 3, para 17.d) • Are briefing slides, including any speaker notes and hidden slides, marked as required for text documents? (DoD 5200.01-M, Vol 2,Encl 3, para 16) • Are maps, charts, blueprints, photographs, and other special types of materials marked in the same fashion as for documents, to the extent feasible? (DoD 5200.01, Vol 2, Encl 3, para 18) Are Files, Folders, and Groups of documents clearly marked on the outside of the file or folder (attaching a classified document cover sheet to the front of the folder or holder will satisfy this requirement)? (DoDM 5200.01-M, Vol 2, Encl 2, para 4.a) Are removable storage media (e.g. magnetic tape reels, disk packs, diskettes, CD-ROMS, removable hard disks, disk cartridges, tape cassettes, etc.) marked with the appropriate Standard Form label (SF 706/707/708/710)? (DoDM 5200.01-M,Vol 2, Encl 2, para 4.b) DATE 11 October 2012 x X x x x x x x x x DECLASSIFICATION (EO 13526 REQUIREMENTS) 30. 31. Is there a records management system to facilitate public release of declassified documents? Are procedures established for automatic, systematic, discretionary, and mandatory declassification review? x x SAFEGUARDING AND STORAGE (EO 13526 REQUIREMENTS) 32. 33. 34. 35. Is the program designed and maintained to optimize safeguarding of classified information? Are there control measures to prevent unauthorized access to classified information? Are personnel aware of procedures for identifying, reporting, and processing unauthorized disclosures of classified information? Are there procedures to ensure that appropriate management action is UNCLASSIFIED 11 x x x x 1 UNCLASSIFIED INFORMATION SECURITY PROGRAM SELF-INSPECTION CHECKLIST TITLE/SUBJECT/ACTIVITY/FUNCTIONAL AREA Information Security Program Self-Inspection Checklist NO. NRO APPROVED FOR RELEASE 28 August 2014 National Reconnaissance Office OPR DATE Security Manager 11 October 2012 ITEM taken to correct identified problems? Are there methods for transmitting classified information, preparing it correctly for mailing, and for hand carrying or escorting classified material? 37. Is classified information removed from storage kept under constant surveillance of authorized persons? (DoDM 5200.01-M, Vol 3, Encl 2, para 8) 38. Are cover sheets placed on all documents removed from storage? (DoDM 5200.01-M, Vol 3, End 2, para 8) 39. Are end-of-day security checks established for areas that process or store classified information to ensure the area is secure at the close of each working day? (DOOM 5200.01-M, Vol 3, Encl 2, para 9) 40. Is the SF 701, Activity Security Checklist, used to record end-of-day checks? (DoDM 5200.01-M, Vol 3, Encl 2, para 9) 41. is the SF 702, Security Container Check Sheet, used to record the closing of each vault, secure room, or container used for storage of classified material? (DoDM 5200.01-M, Vol 3, Encl 2, para 9) 42. Is the SF 700, Security Container Information, properly completed and posted inside the LOCKING drawer of the security container, or inside the door of vault and similar facilities? (DoDM 5200.01-M, Vol 3, Encl 3, para 10) 43. Are storage containers (safes) that may have been used to store classified information inspected by properly cleared personnel before removal from protected areas or before unauthorized persons are allowed access to them? (DoDM 5200.01-M, Vol 3, Encl 3, para 13) 44• Are combinations to security containers changed at the required intervals? (DoDM 5200.01-M, Vol 3, Encl 3, para 11.b) 45. If written records of the combination are maintained, are they marked and protected at the highest classification of the material stored therein? (DOOM 5200.01-M, Vol 3, Encl 3, para 11.a) • Is the combination stored in a security container other than the one for which it is being used? 46. Are entrances to secure rooms or areas under visual control at all times during duty hours to prevent unauthorized access or equipped with electric, mechanical or electromechanical access control devices to limit access during duty hours? (DoDM 5200.01-M, Vol 3, Encl 3, para 12.a) 47. Does each vault or container bear an external marking for identification purpose? NOTE: The level of classification stored therein must NOT be marked on the outside of the container(s). (DoDM 5200.01-M, Vol 3, Encl 3, Para 9) 48. is Top Secret material stored only in a GSA approved security container (safe) having one of the following supplemental controls: (DOOM 5200.01-M, Vol 3, Encl 3, para 3.a) • Guard or duty personnel cleared to the Secret level inspect the security container once every two hours • An Intrusion Detection System (alarm system) meeting requirements of para 2 of the Appendix to Encl 3 of DoDM 5200.01-M, Vol 3. 36. UNCLASSIFIED 12 x x x x x x x x x x x x x x x UNCLASSIFIED INFORMATION SECURITY PROGRAM SELF-INSPECTION CHECKLIST TITLE/SUBJECT/ACTIVITY/FUNCTIONAL ARE A Information Security Program Self-Inspection Checklist NO. NRO APPROVED FOR RELEASE 28 August 2014 National Reconnaissance Office OPR DATE Security Manager 11 October 2012 ITEM • 49. so. 51. 52. 53. 3, 54. Combination lock meeting Federal Specification FF-L-2740 (X0-7) with security-in-depth Is Secret material stored in a GSA approved security container (safe) without supplemental controls or in the same manner as Top Secret? (NOTE: Approved containers will have a certification label on the container itself) (DOOM 5200.01-M, Vol 3, Encl 3, para 3.b) Is Confidential material stored in a GSA approved security container? (DoDM 5200.01-M,Vol 3, End 3, para 3.c) Are security container repairs (e.g. drilled because of a forgotten combination) done in accordance with FED-STD 809? (DoDM 5200.01-M, Vol 3, Encl 3, para 14) Is equipment (e.g. copiers, facsimile machines, AIS equipment and peripherals, electronic typewriters and word processing systems) used for processing classified information protected from unauthorized access? (DoDM 5200.01-M, Vol 3, Encl 2, para 14.a) Do appropriately cleared and technically knowledgeable personnel inspect the equipment and media used for processing classified information before the equipment is removed from the protected areas? (DoDM 5200.01-M, Vol Encl 2, para 14.d) Are GSA approved field safes and special purpose one and two drawer lightweight security containers securely fastened to the structure or under sufficient surveillance to prevent their theft? (DoDM 5200.01-M, Vol 3, End 3, para 6.a) x x x x X x x TELECOMMUNICATIONS, AUTOMATION INFORMATION SYSTEMS, AND NETWORK SECURITY MO 13526 REQUIREMENTS) 55. 56. Consistent with section 4.1(f) of E.O. 13526 and section 2001.50 of title 32, CFR, have uniform procedures been established to ensure that automated information systems that collect, create, communicate, compute, disseminate, process or store classified or controlled unclassified information are protected in accordance with applicable DoD policy issuances? Have procedures been established and implemented to: • Prevent access by unauthorized persons; • Ensure the integrity of the information; • TO the maximum extent practicable, use: 1) Common information technology standards, protocols, and interfaces that maximize the availability of, and access to, the information in a form and manner that facilitates its authorized use; and 2) Standardized electronic formats to maximize the accessibility of information to persons who meet the criteria set forth in section 4.1(a) of E.O. 13526. UNCLASSIFIED 13 x x x x UNCLASSIFIED INFORMATION SECURITY PROGRAM SELF-INSPECTION CHECKLIST TULE/SUBJECT/ACTIVITY/FUNCTIONAL AREA Information Security Program Self-Inspection Checklist NO. 57. 58. NRO APPROVED FOR RELEASE 28 August 2014 National Reconnaissance Office OPR DATE Security Manager 11 October 2012 ITEM Have procedures been established to ensure that unclassified copiers connected to the Internet are not used for classified reproduction? (DoDM 5200.01-M, Vol 3, Encl 7, para 10) • Are modems, telecommunications capabilities and network connections disabled on copiers approved for classified reproductions? (DoDM 5200.01-M, Vol 3, Encl 7, para 10) • Are classified hard drives removed from classified reproduction equipment prior to maintenance? (DOOM 5200.01-M, Vol 3, End 7, para 10) Are cameras and microphones disabled on all hardware used for classified processing, in classified spaces, or connected to networks in classified spaces? (DoDM 5200.01-M, Vol 3, Encl 7, para 10) x x x X REPRODUCTION OF CLASSIFIED MATERIAL (EO 13526 REQUIREMENTS) 59. Are procedures established to oversee and control the reproduction of classified material? (DoDM 5200.01-M, Vol 3, Encl 2, para 5.b ) 60. Are personnel, who reproduce classified, aware of the risks involved with the specific reproduction equipment and the appropriate countermeasures they are required to take? (DoDM 5200.01-M, Vol 3, Encl 2, para 5.b.(2)) 61. Are waste products generated during reproduction properly protected and disposed of? (DoDM 5200.01-M, Vol 3, Encl 2, para 5.b.(6)) 62. Is reproduction equipment specifically designated for the reproduction of classified material? (DoDM 5200.01-M, Vol 3, End 2, para 5.b.(7)) 63. [Optional] Are RULES POSTED on or near the designated equipment authorized for the reproduction of classified? (DoDM 5200.01-M, Vol 3, Encl 2, para 15) 64. [Optional) Are NOTICES prohibiting reproduction of classified POSTED on equipment used only for the reproduction of unclassified material? (DoDM 5200.01-M, vol 3, Encl 2, para 15) ■65. 66. x x x X x x DISPOSITION AND DESTRUCTION OF CLASSIFIED MATERIAL (EO 13526 REQUIREMENTS) Has each activity with classified holdings set aside at least one "Clean-Out" day each year when specific attention and effort is focused on disposition of unneeded classified material? (DoDM 5200.01-M, VoI3, Encl 3, para 17.b) Is classified materials properly destroyed by approved methods? (DOOM 5200.01-M, Vol 3, Encl 3, para 17 &18) x x TRANSMISSION AND TRANSPORTATION OF CLASSIFIED INFORMATION (EO 13526 REQUIREMENTS) 67. Whenever classified information is transmitted outside of the activity is it enclosed in two opaque sealed envelopes or similar wrappings or containers durable enough to properly protect the material from accidental exposure and facilitate detection of tampering? (DOOM 5200.01-M, Vol 3, Encl 4, para 9) • NOTE: When classified material is hand-carried outside an activity, a locked briefcase may serve as the outer wrapper. UNCLASSIFIED 14 x UNCLASSIFIED INFORMATION SECURITY PROGRAM SELF-INSPECTION CHECKLIST 11TLEISUBJECTIACTNITY/FUNCTIONAL AREA National Reconnaissance Office OPR Information Security Program Self-Inspection Checklist NO. NRO APPROVED FOR RELEASE 28 August 2014 Security Manager DATE 11 October 2012 ITEM 68. Is the outer wrapper addressed to an official government activity or to a DOD contractor with a facility clearance and appropriate storage capability with a complete return address of the sender? (DoDM 5200.01-M, Vol 3, Encl 4, para 9.a.(1)) 69. Is the inner wrapper or container marked with the following information: sender's and receiving activity's address and highest classification level of the contents (including where appropriate, any special markings)? (DoDM 5200.01-M, Vol 3, End 4, para 9.a.(2)) • NOTE: The inner envelope may have an "attention line" with a person's name. 70. Are procedures established to limit the hand carrying of classified information to only when other means of transmission or transportation cannot be used? (DoDM 5200.01-M, Vol 3, End 4, para 11.a) 71. Are hand-carrying officials briefed on and have they acknowledged their responsibilities for protecting classified information? (DoDM 5200.01-M, Vol 3, Encl 4, para 11.c) 72. Are courier officials provided a written statement authorizing such hand carrying transmission? (DOOM 5200.01-M, Vol 3, Encl 4, para 12) • [Optional] Does the activity list all classified carried or escorted by traveling personnel? (DoDM 5200.01-M, VoI3, Encl 4, para 11) • [Optional] Does the activity keep this list until all material reaches the recipient's activity? (DoDM 5200.01-M, Vol 3, End 4, para 11) 73. When "Confidential" classified information is sent U.S. Postal Service "First Class" mail between DOD Components within the United States, is the outer envelope or wrapper endorsed "POSTMASTER: RETURN SERVICE REQUESTED"? (DOOM 5200.01-M, Vol 3, Encl 4, para 5.d 1 74. Do recipients of First Class mail bearing the "Postmaster" notice protect it as Confidential material? x x x x x X x x x SECURITY EDUCATION (E0 13526 REQUIREMENTS) 75. 76. 77. 78. 79. 80. , Has the Component Senior Agency Official established a Security Education program? (DoDM 5200.01-M,Vol 1, Encl 2, para 7.g ) Has the activity security manager implemented the security education and training program within the activity? (DoDM 5200.01, Vol 1, Encl 2, para 9.f) Have all personnel been trained on policies for classification, safeguarding and declassification? Do all personnel who perform derivative classification receive training every 2 years? (DoDM 5200.01-M, Vol 3, Encl 5, para 7.c) All original classification authorities (OCA) must receive training in proper classification and declassification at least once a calendar year. (DoDM 5200.01-M Volt, Encl 4, para 5.d and Vol 3, Encl 5, para 5) Does this training program include an "Initial Orientation" for all assigned personnel who are cleared for access to classified information? (DoDM 5200.01-M, Vol 3, End 5, para 3) Does this orientation include the: (DOOM 5200.01-M, Vol 3, End 5, para 3) UNCLASSIFIED 15 x x x x x . UNCLASSIFIED INFORMATION SECURITY PROGRAM SELF-INSPECTION CHECKLIST TITLE/SUBJECT/ACTIVITYIRJ NicnomAL AREA Information Security Program Self-Inspection Checklist NO. NRO APPROVED FOR RELEASE 28 August 2014 National Reconnaissance Office OP R DATE Security Manager 11 October 2012 ITEM • • • ■x x x x • x x x x x x x x x x x SECURITY INCIDENTS AND VIOLATIONS TO INCLUDE COMPROMISES MO 13526 REQUIREMENTS) 88. Are assigned members trained on of their responsibilities to report security violations concerning classified information? (DOOM 5200.01-M, Vol 3, End 6, para 3.b) 89 Are there procedures to conduct an inquiry/investigation of a loss, possible compromise, or unauthorized disclosure of classified information? (DoDM 5200.01-M, Vol 3, Encl 6, para 6) - UNCLASSIFIED 16 x x 7 Roles and responsibilities of assigned members and key personnel? Elements of safeguarding classified information? Elements of classifying and declassifying information? 81 . Is additional training provided for members who: (DOOM 5200.01-M, Vol 3, End 5, para 4.b & c) • Are members of deployable organizations, to provide enhanced security training to meet the needs of the operational environment? • Will be traveling to foreign countries? • Will be escorting, hand carrying, or serving as a courier for classified material? • Will use automated information systems to store, process, or transmit classified? • Will have access to information requiring special control or safeguarding measures? • Will be using Foreign Government Information or work in coalition or bilateral environments? • Submit information to OCAs for original classification decisions? 82. Is Refresher training provided at least annually to assigned members? (DOOM 5200.01-M, Vol 3, Encl 5, para 7.a) 83. Is Refresher training tailored to the mission needs and address policies, principles and procedures covered in initial training? (DoDM 5200.01-M, Vol 3, End 5, para 7.a) 84. Does Refresher training address concerns identified during Component SelfInspections? (DOOM 5200.01-M, Vol 3, End 5, para 7.a) 85. Are procedures established to ensure cleared employees who leave the organization or whose clearance Is terminated receives a termination briefing? (DoDM 5200.01-M, Vol 3, End 5, para 9) 86. Are records maintained to show the names of members who participated in "Initial" and "Refresher" training? (DoDM 5200.01-M,Vol3, Encl 5, para 11 ) 87. Do training programs for "Uncleared" members include: (DoDM 5200.01-M, Vol 3, Encl 5, para 3) • The nature and importance of classified information? • Actions to take if they discover classified information unprotected? • The need to report suspected contact with a foreign intelligence collector? UNCLASSIFIED INFORMATION SECURITY PROGRAM SELF-INSPECTION CHECKLIST IITLE/SUBJECT/ACTIVITY/FUNCTIONAL AREA 90. 91. 92. National Reconnaissance Office OPR Information Security Program Self-Inspection Checklist NO. NRO APPROVED FOR RELEASE 28 August 2014 Security Manager DATE 11 October 2012 ITEM Are appropriate and prompt corrective actions taken when a violation or infraction occurs? (DoD 5200.01-M, Vol 3, Encl 6) Are inquiries and/or investigations promptly conducted to ascertain the facts surrounding reported incidents? (DoDM 5200.01-M, VoI3, Encl 6, para 6) Are individuals who commit violations or infractions subject to appropriate sanctions? (DOOM 5200.01-M, Vol1, Encl 3, para 17 and VoI3, Encl 6, para 8.b & 14) UNCLASSIFIED 17 x X x UNCLASSIFIED NRO APPROVED FOR RELEASE 28 August 2014 NRO Explanation of N/A Responses on 2012 Information Security Program Self-inspection Checklist Item 1. Comment The DNRO appoints the DOS&CI as responsible for NRO security. The DOS&CI appoints a Government Program Security Officer (GPSO) as the head of each Directorate or Office activity who implements the provisions of the NRO Security Program. For each contractor, an NRO Contractor Program Security Officer (NCPSO) is nominated by the contractor and approved by the DOS&CI. The NCPSO is a senior Contractor PSO responsible and accountable for the security oversight of all NRO program activities at their company or corporation. 2. All security instructions are signed by the DOS&CI 5. Equivalent training is provided 6. Security evaluations and self-inspections are centrally managed under the DOS&CI. The DOS&CI is informed of the results of such inspections. 7. Security-related training will be documented in the Personnel Security File or in a listing of all personnel who completed the training 9. Yes, in areas where political instability, terrorism, host country attitude, or criminal activity suggests the possibility that a SCIF may be overrun by hostile forces. 11. If the security manager has a COOP mission, essential materials are in place at the alternate location. 12. The NRO cannot approve OCAs so we cannot delegate OCA responsibilities. 16. The NRO does not use Downgrading markings. 21. NRO personnel do not have the authority to create NATO information. 28. Most SCIFs are open storage and do not require the use of cover sheets. 38. Most SCIFs are open storage and do not require the use of cover sheets. 40. SF 701 may be used or locally designed forms may be used 41. SF 702 may be used or locally designed forms may be used 45. Yes, at the SCI level, except for SAR where the holder does not have access to the SAR compartment nor the physical area housing the container. UNCLASSIFIED NRO APPROVED FOR RELEASE 28 August 2014 UNCLASSIFIED Please note: The best way to view the report "Agency Annual Self-Inspection Program Data: FY 2013" (attached to this explanation) is in softcopy because several of the expandable fields have text that is hidden when viewed in hardcopy. The full text of entries that exceed the viewable space of expandable fields is included below for ease of reading, however, only the softcopy form will be submitted to OUSD(I). 3. Enter the name, title, address, phone, fax, and e-mail address of the Senior Agency Official (SAO) (as defined in E.O. 13526, section 5.4(d)) responsible for this report. Mr. Frank Calvelli Principal Deputy Director, NRO Room 14675 Lee Road, Chantilly, VA 20151 (b)(3) 10 USC 424 FAX (b)(3) 10 USC 424 (b)(3) 10 USC 424 13. What means and methods are employed in conducting self inspections? (For example: interviews, surveys, data calls, checklists, analysis, etc.) - NRO self-inspections are part of the NRO ISAP. Because of the total NRO workforce and have the contractors make up overwhelming number of Sensitive Compartmented Information Facilities (SCIFs), ISAP is a collaborative process between Government and industry to identify and address security vulnerabilities, provide data for analysis, and identify system security issues and trends. Site personnel conduct/document security self-assessments, per requirements stated in the NRO Security Manual (NSM) at least annually. The ISAP Manager or designee reviews the site assessments and enters a copy into an NRO database listing each NRO sponsored facility. Based on the self-assessments, the ISAP Manager, Program Security Officers (PSOs) and stakeholders discuss findings and formulate recommendations for a formal assessment, if required. OS&CI stakeholders represent the major OS&CI directorates and program office security staffs, including, but not limited to, PSOs, 1 UNCLASSIFIED NRO APPROVED FOR RELEASE 28 August 2014 UNCLASSIFIED Physical/Technical Certification Officers and Security Certification Officers. Stakeholders develop and provide ISAP candidates to the ISAP Selection Board. Each ISAP recommendation shall contain detailed factors used to formulate the recommendation. Recommendation for site visits is then provided to the selection board. Sites are selected based on risk, proximity, resources, budgetary constraints, time since last assessment, and random sampling. A team composition is proposed for each site visit and a Lead PSO is selected. The Assessment Team will, at a minimum, consist of a Government PSO and an OS&Cl/Facilities and Information Security Division (F&ISD) representative. Additional team members will be added as needed based on site size, mission, facility risk, and subject areas being assessed. After the on-site assessment, an out-briefing is provided to site security staff and other site senior management identifying security program successes, observations, and any security "best practices" discovered during the formal assessment. The results are loaded into the facility database that contains information from all previous visits with any problem areas or "best practices" noted. A final report requiring corrective actions to be taken within 90 days of the date of the report is issued by the D/OS&CI. The assessed site is required to provide follow-up reports of corrective action to the responsible PSO and the ISAP Manager every 90 days until all corrective actions are complete. The responsible PSO monitors all mitigation actions. Reports of corrective action are loaded into the NRO facilities database for historical purposes. For the reporting period, 291 selfassessments were received and 10 formal team assessments were performed. No additional formal specific-issue reviews were conducted. There were an additional 742 visits by OS&CI stakeholders to contractor SCIFs. In addition, a data call was conducted with all PSOs and CMOs in NRO Headquarters to answer items 87 and 88. 20. Describe below how the agency identifies activities and offices whose documents are to be included in the sample of classification actions. (Indicate if NA.) Based on the 291 site self-assessments submitted, the ISAP Manager, Program Security Officers (PSOs) and stakeholders discuss findings and formulate recommendations for a formal 2 UNCLASSIFIED NRO APPROVED FOR RELEASE 28 August 2014 UNCLASSIFIED assessment, if required. OS&CI stakeholders represent the major OS&CI directorates and program office security staffs, including, but not limited to, PSOs, Physical/Technical Certification Officers and Security Certification Officers. Stakeholders develop and provide ISAP candidates to the ISAP Selection Board. Each ISAP recommendation shall contain detailed factors used to formulate the recommendation. Recommendation for site visits is then provided to the selection board. Sites are selected based on risk, proximity, resources, budgetary constraints, time since last assessment, and random sampling. A team composition is proposed for each site visit and a Lead PSO is selected. Additionally, several types of documents at NRO headquarters are reviewed annually by CMOs and PSOs for proper classification and marking. A data call was conducted with all PSOs and CMOs in NRO Headquarters to answer items 87 and 88. 22. How do you ensure that the materials reviewed provide a representative sample of the agency's classified information? (Indicate if NA.) Documents are selected for review in cooperation with site personnel who are familiar with the type of materials produced by the site. However, contractors are not required to count classified pages produced because of the additional costs that would be incurred by the NRO, so the documents reviewed may not be a representative sample. The data call conducted with NRO Headquarters PSOs and CMOs for item 87 and 88 represents all documents they reviewed during FY 2013. 31. How is the self-inspection program structured to assess individual agency activities and the agency as a whole? Contractor SCIF locations far outnumber government SCIF locations in the NRO. Government locations are relatively few in number and have professional government security officers assigned who can monitor safeguarding and classified information production and correct errors as they occur. We chose to concentrate on contractor facilities which are visited relatively infrequently. The conditions at contractor locations are not directly applicable to government locations. 3 UNCLASSIFIED NRO APPROVED FOR RELEASE 28 August 2014 UNCLASSIFIED 35. What is the format for documenting self-inspections in your agency? Self-assessments are documented using the self-assessment review tool in the NSM, Appendix B. For formal assessments, an outbriefing is provided to site security staff and other site senior management identifying security program successes, observations, and any security "best practices" discovered during the formal assessment. The results are then loaded into the facility database that contains information from all previous visits with any problem areas or "best practices" noted. A final report requiring corrective actions to be taken within 90 days of the date of report is issued by the D/OS&CI. The assessed site is required to provide follow-up reports of corrective action to the responsible PSO and the ISAP Manager every 90 days until all corrective actions are complete. The responsible PSO monitors all mitigation actions. Reports of corrective action are loaded into the NRO facilities database for historical purposes. 47. Safeguarding: Regular conduct of exercises provides vital feedback to the physical security program. Exercises identify areas for corrective measures, enhancements, validate current tactics, techniques and procedures (TTP) and the adoption/employment of new TTP to meet a dynamic threat environment. Regular inspections/audits are essential to ensuring status and validity of issued IC badges and conformity to physical security requirements. Risk assessments/physical security assessments provide a helpful "outside" perspective to site security offices. NRO government and contractor personnel work in SCIFs equipped with secure telephones, FAX, and teleconferencing equipment, badges and badge readers, guard forces in several locations, document shredders and other features to ensure compromises of classified information do not occur. While the insider threat is always a possibility, we take every precaution to prevent security incidents from occurring. The NRO applies uniform procedures established by the Intelligence Community Directive (ICD)-503 family of policy and guidance for Information Technology Systems Security Risk Management and Assessment and Authorization (A&A) activities. 4 UNCLASSIFIED NRO APPROVED FOR RELEASE 28 August 2014 UNCLASSIFIED 48. Security Violations: The ISAP program is the formal mechanism by which we corroborate self - inspections. Included in these formal reviews is an assessment of the respective security violation program and trends. In addition, each component Security team evaluates Security incidents and violations by tracking them according to general broad categories. During this past FY, the majority (63%) of incidents/violations were related to categories within personnel electronic devices in SCIFs. Other categories that have multiple occurrences indicating potential trends are data spills (9%) and inadvertent removal of classified information (12%). Personal cell phones and prohibited electronic devices are not allowed in SCIFs. While we have installed lockers outside SCIFs to secure cell phones, entry of prohibited electronic devices into SCIFs is still a problem. Visitor attendance to NRO conferences/facilities result in numerous cell phones being brought into the conference even by individuals with security duties who should know better. 49. Security Education and Training: 100% of personnel assigned to the NRO are required to complete an SCI indoctrination briefing to include signing a NonDisclosure Agreement. E.O. 13526 is called out specifically so that personnel fully understand their responsibilities and requirements to protect classified information. This message is repeated by the release of awareness videos and reminders throughout the year; to include presentations, written materials, and training. Specifically, OS&CI incorporates classification management questions within the Annual Security Refresher (ASR) web-based training (WBT). In 2014 ASR will include additional Derivative Classification questions. With as many contractors as the NRO employs, training can be a major expense. Every contractor and government employee with a secure computer account is required to take the Annual Security Refresher training otherwise they lose their computer connection. There are numerous additional courses and specialized security training available on-line even though sequestration has reduced training manpower overall to include elimination of the Information Management Branch which ran the OS&CI web site and security-specific applications. 5 UNCLASSIFIED NRO APPROVED FOR RELEASE 28 August 2014 UNCLASSIFIED 50. Management and Oversight: Government oversight of NRO-sponsored SCIFs is achieved in a multi-faceted manner. Program Security Officers, Physical/Technical, and Computer Security Officers review selfassessment results and participate in on-site reviews. Some program findings for FY 13 were identified in the following areas: • Standard Operating Procedures (SOPs) require more detail and more frequent revision to stay up-to-date with security requirements. • Foreign travel and contact reporting were not always accomplished using the mandated NRO Counterintelligence Network (CINet). • There are undocumented information systems within facilities. • Not all employees with AIS privileged user type access have been identified and tracked. • Facility alarm test records are not always maintained for the required time period. • Red/Black cabling is not labeled for identification. 54. Safeguarding: Awareness and education programs are vital to ensuring the workforce maintains awareness of security policy and procedures. Regular and aperiodic exercises, inspections, and audits provide crucial inputs that are indispensable to ensuring that the physical security program is current and effective. Key challenges are maintaining adequate funding to replace aging, malfunctioning, and obsolete security equipment and training and education for new personnel. The NRO has an organization-level process for the Assessment and Authorization (A&A) of Information Systems and a Directive 51-1, "Information Technology, Information Assurance, and Information Management Architecture and Strategy for Certification and Accreditation" to ensure automated information systems that collect, create, communicate, compute, disseminate, process or store classified information are protected in accordance with applicable national policy issuances. 6 UNCLASSIFIED NRO APPROVED FOR RELEASE 28 August 2014 UNCLASSIFIED 55. Security Violations: The NSM details the NRO process for reporting and investigating security incidents, infractions and violations. Appropriate and prompt corrective actions were taken to.mitigate the severity of the infraction/violation, and to sanction the offender via management, counterintelligence, and personnel security processes. Infractions and violations are centrally tracked in the Security Log (the NRO incident/violation database). This database is managed by the Program Security Officers in each directorate and office, and enables the PSO to automatically notify Counterintelligence Division and Personnel Security Division, via a system generated e-mail, of infractions/violations that require immediate CI and/or personnel security attention. The database also enables both OS&CI management as well as individual PSOs to track and analyze trends linked to the various categories of security infractions/violations. 56. Security Education and Training: OS&CI works closely with PSOs, Counterintelligence personnel, and the Integrated Self Assessment Program to determine any trends or specific areas that need an additional educational awareness campaign. Security communications are then targeted, utilizing large scale efforts, per a topic area and audience for best impact results. The NRO is adding additional classification management questions to the Annual Security Refresher to better satisfy the derivative classification training requirement. OCAs complete yearly training provided by NRO/OS&Cl/Policy Branch with direct knowledge of current CAPCO guidelines. 57. Management and Oversight: The NRO has a very mature Security management and oversight program. Over the past FY, much greater emphasis has been placed on ensuring all sites and facilities accomplished the self-assessments and submited the findings to the Government within the mandated time requirements. This improved management oversight has made an impact. Our self-inspection program coupled with security officer visits, and formal team 7 UNCLASSIFIED NRO APPROVED FOR RELEASE 28 August 2014 UNCLASSIFIED assessments provide managers a report card on the health of our security programs. When negative trends are identified, managers from across industry and the Government develop corrective action plans to reverse the trends and ensure security requirements are met. Impacts are being felt to overall security programs due to reductions in security resources. While security requirements are increasing, especially in the area of information systems management, resources are being reduced. Additionally, some sites assessed have made decisions not to fully comply with a security requirement because of resource constraints. 8 UNCLASSIFIED