FOIPA adventures

[coderman]

On 10/5/15, coderman <coderman at 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

â–  No
_I Yes â–  No
Yes â–  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
â–  Declassification
11 Security education and training
16. Do your self-inspections include a review of relevant security
directives and instructions?
16. â–  Yes 7 No
17. Do your self-inspections include interviews with producers (where
applicable) and users of classified information?
17. H Yes â–  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 â–  No â–  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. â–  Yes
No â–  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

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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
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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.

â–  No â–  NA
❑ Yes ■ No ■ NA

25. D Yes
26.

27. El Yes

â–  No â–  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

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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•

â–  No â–  NA
—I Yes III No ■ NA
Yes III No â–  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

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36. Who receives the reports?

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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.

â–  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 â–  No â–  NA
59. Has the agency validated that this training has been received?
59. I Yes â–  No â–  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

â–  Estimated
No â–  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 â–  No â–  NA
64. What percentage of the derivative classifiers at your agency has
received this training?

64.

â–

100
Actual

Estimated

65. â–  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

â–  NA

â–  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 â–  No
❑

rl Yes â–  No

â–  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 â–  No â–  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

â–  Yes No
79.â–  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.

â–  Yes

No

â–

NA

Yes MI No I. NA

â–  Yes â–  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.

â–  Yes

86. III Yes
PART G: Findings of the Annual Review of Agency's Original and
Derivative Classification Actions

â–  No â–  NA
❑

❑

No â–  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

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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

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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

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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

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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

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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.
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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.

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(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.

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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.

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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)

â–
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)

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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
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National Reconnaissance Office
OP R

DATE

Security Manager

11 October
2012

ITEM

•
•
•

â–

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)
-

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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)

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x
X
x

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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.

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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,
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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
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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.

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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.
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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.
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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.
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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
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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

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