The 68 Page Checklist

Enter NISPOM Conforming Change 2 – aka: “The Insider Threat Program.” If you haven’t heard of this by now, you have not been reading these newsleters that we send out each month. (Audible gasp, shaking head in disbelief inserted here.)

The Insider Threat program requirement has come with several new elements for your security program. One of which – you guessed it – is the requirement for Annual Self-Inspection which – once completed – must be certifed in eFCL.

Why eFCL?

I am guessing so your DSS Rep will be alerted if you did NOT do it. Getting a “hey – you need to do this” reminder from your DSS Rep is no fun – so if this is your first time completing the self-inspection (I am not saying you are slack, you may be a newbie) DSS has provided a 68-page checklist with links to the guidance for each requirement.

I am guessing so your DSS Rep will be alerted if you did NOT do it. Getting a “hey – you need to do this” reminder from your DSS Rep is no fun – so if this is your first time completing the self-inspection (I am not saying you are slack, you may be a newbie) DSS has provided a 68-page checklist with links to the guidance for each requirement.

68 Pages?!?! Is there a comic-book version??

Now, before you curse the checklist – can you imagine having to review all of NISPOM, Industrial Security Letters, NISPOM changes, DMDC guidance, STEPP Courses, CDSE information, etc. JUST to make sure you did not miss anything?? God BLESS whoever put this checklist together! Let’s find those folks and get them some doughnuts! What’s more, unless you have classified storage, international contracts AND an authorized information system – you only have about 20-something pages to actually utilize.

Section A—Facility Clearance Requirements.

• • FORMS – Remember all those forms you submitted when your FCL was granted? You will want to ensure there have been no changes

• • Has the ownership changed? (Change KMP list)

• • Have you moved or changed company’s name? (Change DD441)

• • Did a KMP resign? (Change KMP List)

• • Did a KMP get added that doesn’t have the same clearance as the FCL? If so, they may need to be cleared or formally “excluded” from classifed.

• • Have you taken a look at all the marketing materials for the company? Is the facility’s clearance listed as a marketing tool anywhere? (If so – have it removed – ASAP!) While you are at it, have a look at WHO is checking out your website. Is it US companies or a lot of foreign views? It is always a good idea for the FSO to be aware of the website metrics.

• • Have you taken a look at all the marketing materials for the company? Is the facility’s clearance listed as a marketing tool anywhere? (If so – have it removed – ASAP!) While you are at it, have a look at WHO is checking out your website. Is it US companies or a lot of foreign views? It is always a good idea for the FSO to be aware of the website metrics.)

• • Review the SF328 – the new one is available here – are all the answers to the yes/no questions the same? If so, leave the one you have in place – no need to update the new one unless there has been a changed condition to the Foreign Ownership or Controlling Interests at your company.
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Steps For Making a change in eFCL:

1. 1. 1. 1. Login to eFCL. If you find yourself locked out of eFCL, you can request a new temporary password from fclserver@anl.gov or you can call (630) 252-6566.
         2. Select the “Changed Condition” icon. It looks like a tiny blue folder. 
         3. Fill out the “changed condition questionnaire”. There are places to select a KMP change, a new address, a name change. Explain the change, hit save and done.
         4. The system will prompt you for the updatable items.
         5. Submit (I always include a note to the DSS Rep to identify the change easily) for approval.
         6. You will receive an email once the change has been approved (or a modification is requested) so if several weeks go by without an approval – follow up with an email to your DSS Rep. They are busy with all the actual inspections and on the road A LOT. Bring it to their attention if the approval is pending. “But won’t that prompt them to do an in-person inspection?” Maybe, but it is better to keep your company’s information current.

Feeling more comfortable with eFCL now? Um, well – good, but it is going away later this year. eFCL will be replaced by the National Industrial Security System (NISS) this fall. Fear not though – FSO PRO and the FSO Success Newsletter will keep you in the loop as eFCL is replaced by NISS and all the new benefits to YOU!

Hot and Now! Free Doughnuts!

So, if you haven’t guessed by now – we at FSO PRO love us some doughnuts! Especially when they are hot & now!

If you go to our Facebook and like our page or follow our Instagram (both of which will be providing FSO information, tools, freebies and contests), you will automatcally go into a drawing for your own FREE Doughnuts!

We love them (and our clients!) so much that we send out doughnut gif cards around this tme every year.

As it turns out, we have several gift cards lef over. As tempting as it is to eat them ourselves (they melt in your mouth!), we would rather use this as a giveaway for you, gentle reader!