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Maintaining a Personnel Security Clearance Posted by DigitalDominion (2010/7/19)

Maintaining the Personnel Security Clearance record in JPAS is the responsibility of the industrial contractor.

Classified Information Nondisclosure Agreement (SF-312)

Maintaining the PID (Personal Identification Data) information

* Changing PID information when industry employees have DoD Categories
* Social Security Number (SSN) Changes
* Alias – Add, Modify or Delete
* Marital Status Changes

Incident Reports – what, when and why
Investigation Status Checks
Mass Personnel Changes
Research, Recertify, and Upgrade (R/R/U) Actions
Separation from the company
SMO Relationships in JPAS when Sensitive Compartmented Information (SCI) access is involve
Classified Information Nondisclosure Agreement (SF-312)

An FSO must brief employees on non-disclosure requirements prior to granting access; NISPOM Paragraph 3-105 requires that an individual issued an initial personnel security clearance for the first time execute a Classified Information Nondisclosure Agreement (SF-312) prior to being granted access to classified information and that the completed form is forwarded to the cognizant security agency for retention. If JPAS reflects an SF-312 was previously executed, it is not necessary to complete another form.

The date entered in JPAS should be the date the employee signed the form and it should not be changed. Other dates may be present in JPAS for the SF-312 execution but these dates should not be changed as they are used by DISCO retrieve SF-312s from the archives.

After the FSO has their employee complete an SF-312, it should be mailed to DISCO for retention:

Defense Industrial Security Clearance Office
2780 Airport Drive, Suite 400
Columbus, Ohio 43219-2268

FSOs will be notified and a new SF-312 will be required for any SF-312 not meeting the following criteria:

* Employee Social Security Number is incomplete or omitted
* Signature of employee is typed or omitted
* Witness signature is typed or omitted
* Employee and witness signature dates must be the same

Maintaining the PID (Personal Identification Data) information

Changing PID information when industry employees have DoD Categories

* The military personnel system, DEERS, overrides JPAS with PID information and is the “owner” of an individual’s information as long as there is an active association with that organization.

* When a person has a DoD Category, industry is not able to update a name change or any other PID information. This includes separation dates for other than industrial categories. It is noted that at this time DoD organizations are not consistently placing separation dates and codes. If a PID change is required, a TPR should be submitted via JPAS. The TPR will be routed to the appropriate organization to initiate the change.

* If a record reflects that a person is deceased when they are not, the decease date must be removed from both the separation area and the PID area. If it is not removed from both places, then the action will not be saved.

SSN Changes

FSOs can make changes to personal identification data with the exception of the SSN. When an SSN change is required, the request must be submitted to DISCO using the Research R/R/U process. Do not build the new SSN into the JPAS prior to requesting the change. The SMO should pull the subject into their Personnel Security Management (PSM) Net and update the Person Category with the Industry Category, Classification and Cage Code.

Alias – Add, Modify or Delete

An authorized JPAS user can add, modify, and delete an alias for a person. The following guidance should be used when entering or modifying the alias for a person:

* Do not enter an alias if the subject’s last name and first name match and the alias name only reflects an initial for the middle name
* Do not enter an alias if it is a single name (e.g. Cher, short for Cheryl)
* Do not enter nick-names
* When changing the subject’s name, always enter the prior name used as an alias unless the name already exists in the record.

Marital Status

The FSO should notify DISCO when an employee changes marital status in the following situations. The FSO should submit a Research R/R/U to provide the notification and submit the date of the change and reason for the change, e.g., marriage. This will minimize any disruption to the investigative process.

* When the employee has a clearance or is in process for a clearance with an investigative basis of: Single Scope Background Investigation (SSBI); Single Scope Background Periodic Reinvestigation (SBPR); or Phased Periodic Reinvestigation (PPR).

* Notification is only required for employees with open investigation types of National Agency Check/Local Agency Check/Credit Check (NACLC) when the marital status changes and the investigation is scheduled or open. For those situations, FSOs need only report the change is the marriage or cohabitation is to a foreign national. No update is required if an employee marries a foreign national when there is no open NACLC investigation.

Incident Reports – what, when and why

The FSO should submit reports for personnel with a security clearance, in-process for a clearance, or a that have a clearance eligibility that could be reinstated, in accordance with the reporting requirements in paragraph 1-302 of the National Industrial Security Program Operating Manual (NISPOM). JPAS provides the incident report capability to facilitate this reporting. At this time, the FSO should mark report as “final” rather than “initial”.

It is strongly recommended incident reports be submitted via JPAS. The system was designed to accommodate incident reporting. Submitting incidents via JPAS provides immediate assurance of receipt and eliminates the manual handling by multiple individuals when hard copy requests are received and entered into JPAS by adjudication staff.

An adjudicator will review the submitted report and determine if the item may be closed and a new eligibility adjudication entered, or if a partial investigation is required to provide the adjudicator sufficient information to make an adjudication. After the incident report is reviewed by the adjudicator, the FSO may receive a request for the subject to submit a new SF 86, Questionnaire for National Security Positions; this does not happen in all cases. If such a request is made, the FSO should initiate the request to the employee using JPAS. If the request is not received by DISCO within 30 days from the date of request, DISCO will administratively withdraw the eligibility determination by changing the eligibility to Loss of Jurisdiction. At that time, all access must stop.

Sources from which an incident report may be received:

* Facility Security Officers (FSO)
* Other Government Agencies
* Investigative process
* Another CAF’s decision to Deny, Revoke or Suspend a (Federal) security clearance
* Any person who knows the subject

If there is a question on the ability for the subject to have continued access when an incident report is reflected, contact the DoD Security Services Center for assistance.

Investigation Status Checks

JPAS should be used to check on the status of a pending investigation. If the FSO does not yet have access to JPAS, the status of an employee's investigation may be checked by calling the DoD Security Services Center. Do not call OPM for status checks. Do not submit R/R/Us for status checks.

Mass Personnel Changes

This feature enables authorized users in one action to take mass actions. The types of mass actions include:

1) separate (terminate) the association;
2) separate and transfer personnel associations among multiple facility organizations (MFO);
3) separate and transfer non-MFOs; or
4) transfer to non-MFOs. Items 2 and 3 overlay the category and will create a history item for the action; item 4 adds an additional person category to the subject’s record, i.e. adds a new affiliation to the person.

After performing a mass change, a check should be completed to ensure that all actions were accomplished. If an open incident report exists or the access is suspended, the subject’s record will not be modified. There are additional restrictions for Key Management Personnel (KMP) since the FCL may be affected. Verify from the Ineligible Personnel list the actions that the system did not complete.

Other helpful processing hints include:

* When using the mass action capability, access downgrades are based on the organization’s eligibility and not the person’s eligibility. This also applies when moving access to another organization.

* Only United States (US) and North Atlantic Treaty Organization (NATO) accesses can be downgraded. For example, SCI access can not be downgraded in a mass action.

* DISCO receives notification when a mass personnel change is affected on an individual with an open investigation. Individuals will appear on the Ineligible Personnel List within the Mass Personnel Changes screen. Manual processing of these actions is required. No further notification to DISCO is required for individuals with an open investigation.

* Notify DISCO when an action is pending on a subject, e.g. pending incident report, pending adjudication and pending investigation request (not an open investigation). An R/R/U request should be submitted on subjects with pending actions and indicate the type of action that is required.

* The Separation type “Facility Termination” should only be used when the organization’s eligibility has been terminated.

* When subjects appear on the Ineligible Personnel List and are identified as KMPs, you must complete the action by using the Add/Modify Non-DoD Person screen. As a reminder, changes in the status of KMPs are still reportable to your Industrial Security Representative in accordance with the National Industrial Security Program Operating Manual (NISPOM), 1-302h item 3.

* A history action is created for an organizational change.

Research, Recertify, and Upgrade (R/R/U) Actions

For FSOs that were around before JPAS, R/R/U actions include actions previously reported via the DISCO Form 562. Within JPAS, it is now known as an R/R/U action. Many of the actions previously reported on the Form 562, are now the responsibility of the FSO to maintain in JPAS. Several examples are in the Maintaining PID section but this is not all inclusive. If you have a question about how to proceed, contact the DoD Security Services Center for guidance.

Do not submit R/R/Us for status inquiries as this only delays the processing of other R/R/Us. If you have a status-type question that you are unable to resolve by viewing JPAS, contact the DoD Security Services Center.

Any JCAVS User within the same submitting SMO can cancel a previously submitted R/R/U. The R/R/U cannot be cancelled once it has been assigned to a JAMS user. Once cancelled, a JCAVS user can resubmit another R/R/U. JPAS will not permit generating an R/R/U if there is a pending R/R/U on a subject.

Separation from the company

Upon separation from the organization, the FSO enters a separated date for the employee in the system. If an investigation is open for the employee, a notification will be forwarded to the appropriate CAF to determine whether the investigation needs to be cancelled. Notify DISCO via R/R/U when a separation occurs and either of the following two items exist. Notification will permit DISCO to take appropriate actions on the record.

* An action is pending on a subject, e.g. pending incident report, pending adjudication and pending investigation request.

* There is not an open investigation and an interim eligibility exists

SMO Relationships in JPAS when Sensitive Compartmented Information (SCI) access is involved

* Procedures have not yet been standardized across DoD on how to handle JPAS owning and servicing relationships when SCI access is involved.

* The owning activity is responsible for maintaining the individual’s clearance record.

* If your organization provides the SCI indoctrination, then your organization should take the JPAS user level 2 or 3 owning relationship with the individual and the Government Activity may take a servicing relationship. This will permit both organizations to receive eligibility change notifications. If your organization does not provide the SCI indoctrination, then your organization should take a level 2 or 3 servicing relationship and the Government Activity will take the owning relationship. It is recommended that you discuss with your Government Activity the procedures they prefer.

* When completing requests to initiate investigations, annotate the investigation request in one of the following areas to indicate the need for SCI (or SAP) adjudication. identify the unclassified SCI/SAP name in the contract number section, or have the subject identify the information in the remarks section of the Personnel Security Questionnaire.

* For AF SCI eligibility determinations, an SCI SMO must be recorded on individual’s clearance record that requires the SCI determination. Failure to reflect the SCI SMO will mean that the AF CAF will not process the request.

[2011/5/23] Overseas Deployment Issues
(05/18/11)
release from DISCO

The Defense Industrial Security Clearance Office (DISCO) is currently making arrangements with the Office of Personnel Management (OPM) to have subject interviews completed in designated overseas locations for individuals whose investigations have not been completed due to the overseas deployment. DISCO will contact companies to identify individuals employed by their company who are overseas and still require a completed investigation, and to determine when the individuals will be made available for the interview in the designated locations.
[2011/5/23] Transition to Secure Web Fingerprint Transmission (SWFT) - Q8
Q: How does the electronic capture of fingerprints speed the investigative process?

A: From November 2010 to February 2011, OPM rejected approximately 3,160 investigative cases submitted by DISCO. Of those, 67 percent (2,115) were due to problems related to the fingerprint files. This equates to rejection of approximately 530 cases a month or roughly 6,340 cases a year due to fingerprint issues. OPM rejects cases when the fingerprints are unusable, such as a smudged or smeared print, too much or too little ink on the ink pad, etc.
[2011/5/23] Transition to Secure Web Fingerprint Transmission (SWFT) - Q7
Q: Other than SWFT, what other options do cleared contractors have?

A: At the moment, the only option available to cleared industry is SWFT. However, DSS is studying a number of other alternatives to assist the cleared contractor community.
[2011/5/23] Transition to Secure Web Fingerprint Transmission (SWFT) - Q6
Q: Can cleared facilities transition immediately to SWFT?

A: Yes, any cleared facility can begin the transition to SWFT immediately. SWFT is a fully operational system which is funded, managed and operated by Defense Manpower Data Center (DMDC). However, cleared facilities must purchase the equipment needed to capture the fingerprints. The equipment cost ranges from $2,000 to $20,000 per machine. For more information about the SWFT program, to include access and registration procedures, please visit https://www.dmdc.osd.mil/psawebdocs.
[2011/5/23] Transition to Secure Web Fingerprint Transmission (SWFT) - Q5
Q: How many companies are using this method[Secure Web Fingerprint Transmission (SWFT)]?

A: Roughly eleven percent of companies cleared under the National Industrial Security Program are using this method.
[2011/5/23] Transition to Secure Web Fingerprint Transmission (SWFT) - Q4
Q: What is SWFT?

A: SWFT is a web-based program that provides industry users the ability to securely transmit records directly from their records management systems to SWFT via secure web services. The process allows fingerprint images to be captured electronically, uploaded to the server where they are stored temporarily, and then released from the SWFT system to the Office of Personnel Management (OPM).
[2011/5/23] Transition to Secure Web Fingerprint Transmission (SWFT) - Q3
Q: What is required for a contractor to make the transition?

A: The only option available at the current time is for a cleared facility to purchase equipment and use the existing Secure Web Fingerprint Transmission (SWFT) program.
[2011/5/23] Transition to Secure Web Fingerprint Transmission (SWFT) - Q2
Q: How can a cleared company know what specific equipment to purchase?

A: The FBI maintains a list of products certified as tested and in compliance with the FBI's Next Generation Identification (NGI) initiatives and Integrated Automated Fingerprint Identification System (IAFIS) Image Quality Specifications (IQS). These products are certified by the FBI Criminal Justice Information Services Division Biometric Services Section, as part of Biometric Center of Excellence. There are approximately 500 products on this list, which is available on the FBI website: ...

[2011/5/23] Transition to Secure Web Fingerprint Transmission (SWFT) - Q1
Q: Why is this change (electronic submission of fingerprints) being mandated?

A: Manually capturing and submitting fingerprints is time consuming and prone to errors. The intent is to utilize automated electronic fingerprint devices to speed capture, submission, and processing time. Additionally, this transition will support goals established by the Intelligence Reform and Terrorism Prevention Act of 2004 and the implementation of Homeland Security Presidential Directive-12.