MINUTES
SECURITY POLICY ADVISORY BOARD MEETING
LOCKHEED MARTIN, SUNNYVALE CA.
26 MARCH 1998
1. On 25 MARCH 1998, a public meeting of the Security Policy Advisory Board
was held at Building 107. Board Chairman General Larry Welch, USAF (Ret) presided
with board members Ms. Nina Stewart and Rear Admiral Thomas Brooks, USN (Ret)
present. Mr. Dan Jacobson, Director, Security Policy Board Staff and Mr. Terry
Thompson, Responsible Federal Officer were also present. Numerous members of the
public were also in attendance and participated.
AGENDA ITEMS:
2. The meeting was opened by Mr. Thompson who welcomed all in attendance and
introduced the Board. General Welch then added his welcome and noted that one of the
primary functions of the Security Policy Advisory Board is effective communication with
the private sector.
AGENDA ITEMS:
3. Ms. Cindy Cordon, ranking MOU representative, was then introduced and
began a discussion of issues important in the industrial arena. She indicated that the policy making process, in particular as it pertains to the NISP, lacks a device for closure. For
example, Chapter 8 has been discussed for over three years and remains unresolved. She
took cognizance of the difficulty attending computer security but nevertheless stated there
needs to be one authority who can move the process forward. When queried by the Board
as to what is the existing dispute resolution process Mr. Jacobson indicated there is an
ISOO oversight committee with that responsibility. Chairman Welch requested a copy of
the structure of the existing dispute resolution mechanism be forwarded to him. The Board
then asked whether this impasse was limited to Chapter 8 and Ms. Conlon replied a similar situation exists with Chapter 10. The Board stated that it would appear unlikely that one
individual could be designated as a resolution officer but perhaps a few members of senior
management could be so designated.
4. Ms. Conlon then indicated she read the recent article by Richard Lardner in THE
GOVERNMENT EXECUTIVE and takes issue with some conclusions of the author. She recalled a time before the advent of the Security Policy Board and its structure when
different government security officials didn't know one another and the security
environment was considerably less coordinated than it is today. She has observed
enormous progress to date---with much more progress needed. The board agreed with her
assessment noting that forward movement is slow but real. To that end, the Joint Security
Commission will reconvene shortly to evaluate the status of the implementation of its
original recommendations.
Upon receipt of a description of the dispute resolution mechanism for the IS00
Oversight Committee, the Board will explore the available options to finalize chapters
Eight and Ten.
STATUS OF THE IMPLEMENTATION OF RECIPROCITY
5. Ms. Charlene Wright, C3I, then addressed the Board on the issue of reciprocity
outlining five elements. She began by stating the SF 86 was implemented in DOD 1
January 1996 and DOD is currently working in close conjunction with OPM in developing
and implementing the EPSQ. In implementing the EPSQ, the twin issues of an electronic
signature and a fingerprint card are somewhat problematic and must be resolved. The
Board asked what the options were for an individual who did not have access to the
Internet? For such filers hard copy will remain a viable alternative. The Board inquired
whether a new SF 86 needs to be completed each time a cleared individual accepts a new
tasking from another agency? An additional SF 86 is currently required to bring an
individual's background up to date, despite the fact that no background investigation may
occur. A form is under consideration which facilitates the transfer of background data
without resort to completion of an additional SF 86.
6. Ms. Wright then addressed the area of investigations and noted that the SSBI
was adopted in October 1991 and that a common scope was finalized in March1997 with
the President's signature on the Investigative Standards. She also indicated Annex B of
DCID 1/14 outlines quality standards which are to be followed by the community. In
accordance with DOD 5200.2-R, DOD has long accepted investigations by other agencies.
7. Turning to adjudicative and training matters, Ms. Wright indicated that revisions
in adjudicative guidelines were begun in 1990 and coordinated for several years prior to the birth of the SPB. The effort culminated in March 1997 when the current adjudicative
guidelines were approved by the President. She further opined that there is a joint
adjudication training course under development by the Adjudicators Training Working
Group. The objective is to have in final product one adjudicator's course by December
1998.
8. Ms. Wright then indicated the DCII is now on line and available at ninety DOD
locations and twelve non-DOD locations. The DCII-SII connection is currently partially
operational with the DSS to OPM link functional but the OPM to DSS link is in the de-bug
stage. DCII contains data on five million clearances while SII will contain about two
hundred and fifty thousand -- when all clearances are entered. There is also a SAP database
under development which will be classified. The Board asked for a clarification re: the
policy for access to the newly combined database. Ms Wright stated that read only access
requires a SECRET while an SSBI is required for read and write access. Some agencies
are reluctant to provide their clearance data for the DCII/SII merger as certain
compartmentation requirements are thought to be necessary. Ms. Wright summarized by
stating much progress has been made on the implementation of reciprocity but much work
lies ahead.
9. Ms. Kathy Nolan of Science Applications stated that DSS researches clearance
matters beforehand and freely accepts clearances as appropriate. She encouraged other
agencies to do likewise.
The Board fails to see the necessity of requiring the completion of an SF 86 prior to
the search of security databases. In many cases the existing clearance is located in the
course of the subsequent search and the completion of the SF 86 is therefore redundant
and/or superfluous. They strongly recommend that a practice be adopted whereby the
security /administrative officer is required to search databases and security records before
contacting the investigative subject. This practice should determine the current status of the subject's clearance and minimize duplicative efforts.
The Board welcomes the efforts of the entire community in implementing
reciprocity and encourages them to press onward.
10. Mr. Dan Jacobson, Director, Security Policy Board Staff, then addressed the
group on the key issues confronting the policy community today. One area that demands
attention is the compilation of threat data. The National Intelligence Council has indicated this is a priority matter. The Board noted that the Joint Security Commission recommended
threat data be collected in one central point for "one stop shopping." Mr. Jacobson replied
that, unfortunately, this did not occur and this issue must remain a priority. The issue of
Sensitive but Unclassified data dealing with the national infrastructure is also a priority for
today and tomorrow. At the core of this question rests the government's ability to protect
the information -- particularly in the face of the Freedom of Information Act. Mr. Jacobson
frankly posited that the government is not in an ideal position to protect this data and is
consequently handicapped in the matter. The President's Commission on Critical
infrastructure is the lead entity for this endeavor. He also noted that the Extranet for
Security initiative is moving forward but is in need of funding. This effort promises to
enhance the productivity of the average security officer by establishing a secure, electronic
channel of communication among security professionals. As previously indicated,
common training, particularly in the adjudicative arena, is a priority matter. A research and development proposal has been tendered with emphasis on the insider threat. This too
awaits funding but Mr. Jacobson noted that funding after the structure is completed is
always more expensive than implanting security after the fact.
11. Mr. Jacobson asserted that the SPB needs to be proactive and any participation
from the top down is welcome. He stated the National Security Telecommunications and
Information Security Committee (NSSTC) effort is a thorny one and needs much industry
support. The rapid pace of technological advance makes this task considerably complex
and may promise to be resource intensive.
12. As aforementioned, funding is being aggressively pursued. Several initiatives
are currently under fiscal review by community experts and it is fervently hoped that
resources can be located to implement endeavors such as Personnel Security Research and
the ESP -- to name a few.
PERSONNEL SECURITY RESEARCH:
13. Dr. Joseph Holthaus, SPBS, then addressed the group on the status of
Personnel Security research. Dr. Hoithaus indicated the Personnel Security Research Sub
Committee functions under the auspices of the Personnel Security Committee and is staffed
by professional researchers. The primary function of the sub committee is to review and
validate existing and proposed research projects. Within the past year, the sub committee
met to review the various studies regarding the neighborhood coverage of the background
investigation. The feedback of the sub committee was provided to the policy community
which then made a policy pronouncement. The sub committee has established a research
database which maintains unclassified abstracts of personnel security research material
completed by government sources. During the past year, the sub committee has met
periodically to construct a personnel security research plan which outlines research
priorities for the next five years. That document has been reviewed and approved by the
Personnel Security Committee and forwarded to elements of DOD and CMS for fiscal
analysis. Upon completion of that analysis, the plan will move forward to the Policy
Integration Committee, the Security Policy Forum and eventually the Security Policy
Board.
14. The Board queried Doctor Hothaus as to the results of the neighborhood study.
He indicated that in the final tally all agencies, save one, voted to retain neighborhood
coverage dating back three years. The Board also asked which source in the background
investigation produced the greatest amount of noteworthy information. According to
current data, subject interviews provide noteworthy information in 21% of cases.
15. Mr. Terry Thompson, SPBS, then began a discussion on the current status of
the financial disclosure issue. At this time two options are under consideration. The first is
the financial disclosure form consisting of seventy four data points and currently used by a
single agency. The second possibility, Option B, is a four question addendum to the SF 86
which queries the filer as to assets, liabilities and income. The form gathers more data and
the requested information is quite specific while Option B requests totals of assets,
liabilities and income but not a listing of specifics. The latter also includes expanded use of
financial databases, additional training for adjudicators and investigators and additional
questions to be asked of a source and/or a subject during the course of the investigation. It
is speculated that use of the form will probably provide more data and that information may have utility from an investigative standpoint. Conversely, the form is considered highly
invasive and the utility of the derived information is not necessarily held to be self evident.
The Board then queried whether the experimental use of the form has yet yielded any hard
data. No qualitative information is yet available but the design of the program is such that
significant yields may occur only over a period of years.
16. A participant indicated that industry sentiment favored providing whatever
fmancial data was eventually gathered directly to the governrnent rather than to a company security officer.
17. Another participant stated that industry is particularly sensitive about salary
information and treats it in a highly proprietary fashion.
18. Several participants expressed concern about the confidentiality of the data
collected.
The Board does not believe a case can be made for a separate financial disclosure
form. The form is highly invasive and the information gathered of questionable
investigative or screening utility. Certainly there has not yet been a convincing
demonstration of the usefulness of the data. The Board endorses Option B.
19. There was no further commentary and the meeting was closed by Mr.
Thompson at 1115 hours.
