Handling Classified Information

Overview

All classified material in possession of the Company must be safeguarded at all times to prevent loss or compromise and unauthorized disclosure, dissemination, or duplication. This includes all classified material used or developed in connection with a classified contract; all aspects of pre-contract activity, including preparation of bids and proposals; and all aspects of post-contract activity.

Individual Responsibility

Security is a continuing individual responsibility. Each individual who has possession or knowledge of an item of classified material has the following responsibilities:

• The individual must determine whether a prospective recipient is an authorized person.
• He must advise the recipient of the classification of the information disclosed, whether or not the classification is obvious.

As an approved custodian or user of classified information, you are responsible for the protection and control of this information. Your security officer will brief you on the rules for handling classified information. Here are some of the standard procedures. 

• Classified material must be identified as being classified (i.e., by use of classified material cover sheets, markings, etc.)
• Cover, turn face down, or place classified material in a Government approved storage container when unauthorized persons are present.
• During preparation, drawings containing classified information may be left on the drawing board during brief absences and during the lunch period provided they are covered and left under the personal control and constant surveillance on an authorized cleared person
• Regraded material, until the regrading markings actually are made by proper authority, shall be safeguarded in the prescribed manner for the level of classification appearing thereon.

If you find classified material left unattended (for example, left in a rest room, on a desk, or in an open repository), it is your responsibility to ensure that the material is properly protected. Stay with the classified material and notify the security office. If this is not possible, take the documents or other material to the security office, a supervisor, or another person authorized access to that information, or, if necessary, lock the material in your own safe overnight. Classified material shall not be taken home, and you must not work on classified material at home. Classified information shall not be disposed of in the waste basket. It must be placed in a designated container for an approved method of destruction such as shredding or burning.

Classified working papers such as notes and rough drafts should be dated when created, marked with the overall classification and with the annotation "Working Papers," and disposed of with other classified waste when no longer needed.

Classified information must not be discussed in public places, in the presence of unauthorized individuals, or at a location other than U.S. Government cleared facilities or facilities specifically approved for classified conferences, meetings, or seminars by the U.S. Government.

Top Secret information is subject to continuing accountability.  Top Secret control officials are designated to receive, transmit, and maintain access and accountability records for Top Secret information.  When information is transmitted from one Top Secret control official to another, the receipt is recorded and a receipt is returned to the sending official.  Each item of Top Secret material is numbered in series, and each copy is also numbered.

Classified Material Control

The Company maintains a DoD classified material control station.

Any incoming, outgoing, and Company-generated classified document or material falling under DSS cognizance is entered into the SIMS Classified Documents and Materials database. After entry, a hard copy of this record is printed and filed into the Classified Material Control Log. Each document or item entered in this log is assigned and marked with a sequential serial number such as the following: 99-S-001-1. Broken down, this control number indicates the year this material was received or generated (1999), the classification level (S - SECRET), the sequential number for that item during the year (001 - first for 1999), and the copy number (1). This material is controlled within the facility by a continuous receipt system.

Generation of Classified Material

Classified material generated at our company will be entered into accountability upon the initial write-up of working papers, notes, drafts, drawings, AIS media, or other material. However, this does not mean that a blank notebook or other medium will be brought into accountability prior to classified information being applied. This applies to text or data that actually exists whether on paper, in software, or other record.

At a minimum, the following types of classified material require the following:

• "Working Papers" or Drafts: Require date when created and must be marked with its overall classification, with any warning applicable, and with the annotation "WORKING PAPERS". The other markings required for finished documents are not required for Working Papers. However, use of portion markings is encouraged during preparation to aid in applying proper markings to the finished product.
• AIS Material: Each piece of storage media will be identified by the Project or contract number and a general description of the information contained. Separate projects will not be resident on the same floppy or other storage media.
• Other Material: Confidential, Secret, or Top Secret material, in other than documentary form, is entered into the accountability system when classified information is actually formulated. Identifying data, such as the Project or contract number, and a general description of the information, must be applied if possible.
• Incorporation of Classified Material: When a classified document or other material is disassembled, joined to, incorporated, or made a part of another classified item, or a new classified item is created, accountability is established, terminated, or adjusted, as appropriate. Incorporation will be performed only by the Security Administrator so that the accountability records can be properly posted.

Reproduction

Classified information is reproduced only when authorized and only through the Security Administrator. The following rules apply:

• All reproductions will be monitored or performed by Security personnel.
• Reproductions will be accomplished only on equipment designated by Security for such purpose. Rules governing the use of such equipment are posted near the equipment. Warnings prohibiting reproduction of classified material are also posted on or near equipment used only for unclassified material.
• During the layout, composition, and bindery stages of the reproduction, controls are established to deny unauthorized personnel access to the immediate area in which such work is being performed. Such controls will consist of sign postings and visual preclusions.
• Reproductions will be limited to the minimum number of copies needed to meet operational requirements.
• Reproductions will be safeguarded as required for the level of information involved.
• Classified waste, spoilage or overruns will be returned to Security for property control and disposal.
• Reproductions will be destroyed by approved methods of destruction after they have served their purpose .

Disposition and Retention

• All classified material (including copies and reproductions, and classified information stored on AIS media) received or generated in the performance of a classified contract will be returned to the User Agency on completion of the contract unless the material has been declassified, destroyed or retention of the material is authorized.
• Classified holdings will be reviewed upon completion of an inventory to reduce the amount of material held to the minimum necessary for efficient operations. Multiple copies, obsolete information, and classified waste will be destroyed as soon as practical after it has served its purpose.

Disposition

Classified material is returned or destroyed in accordance with the following schedule unless retention of the material is authorized as prescribed:

• If a bid, proposal, or quote is not submitted or withdrawn, return or destroy within 120 days after the opening date of bids, proposals or quotes.
• If a bid, proposal, or quote is not accepted, return or destroy  within 120 days after notification of such.
• If a bid is successful, return or destroy within 120 days after final delivery of goods and services, or after completion or termination of the classified contract, whichever comes first.
• If the classified material was not received under a specific contract, such as material obtained at classified meetings or reference material, return or destroy within 120 days after receipt.

Retention

When the Company desires to retain any classified material beyond the 120 days, the Project Manager in coordination with Security, generates a letter to the User Agency or customer identifying the specific documents to be retained and the appropriate justification for the retention. In such cases, the Company may retain the classified material for a period of 2 years unless notified to the contrary by the User Agency. The 2 year period will be computed from the date of the Company's correspondence. If retention is required beyond the 2 year period, the Company must request retention authority from the User Agency. Ideally, if the User Agency determines the Company has a continuing need for the material, the User Agency will issue a final DD Form 254 which will show the authorized retention period.

The letter requesting retention of classified material identifies the Top Secret, Secret, and Confidential material in a list of specific documents. A statement of justification for retention will be based on any of the following:

• The material is necessary for the maintenance of the Company's essential records.
• The material is patentable or proprietary data to which the Company has title.
• The material will assist the Company in independent research and development efforts.
• The material will benefit the U.S. Government in the performance of other prospective or existing User Agency contracts.
• The material is being retained in accordance with the "records retention clause" of the contract.
• The material has been authorized for retention for a specific period under the terms of the contract.
• The material will benefit the U.S. Government in the performance of another active contract and is being transferred to the active contract (specify contract). A copy of the correspondence will be provided to both User Agencies.

Destruction

Retention of classified material which is no longer needed increases the risk of security compromise and creates unnecessary overhead control costs. Each manager involved in classified work is responsible for conducting periodic review and purging of unnecessary classified material to minimize control costs and to decrease the likelihood of security compromise. The Security Department is responsible for the destruction of all classified material.

In all instances where specific instructions have been issued by a User Agency for the disposition or destruction of its classified material, such instructions are honored by the Company.

• Security shall destroy classified material as soon as possible after it has served the purpose for which it was released by the Government, developed or prepared by the Company, or retained after completion or termination of the contract.
• Classified material at our company is destroyed by shredding, except microform material, which will be burned.
• For accountable material, destruction shall be accomplished and witnessed on a Destruction Certificate by an individual cleared to the level of material to be destroyed. Classified waste, carbon ribbons, stencils, etc., that are not in the accountability system do not require a record of destruction.
• Destruction Records and Certificates indicating the date and the material destroyed will be executed by the individual designated to destroy it. These Certificates of Destruction are generated through the SIMS, and the software automatically updates the Document Control Log to reflect an accurate accountability. This record is retained for a period of not less than 3 years for Top Secret and not less than 2 years for Secret.

Release of Information

Classified or unclassified information pertaining to a classified contract or project may not be released for public dissemination without prior approval of the appropriate Government agency. A classified contract is defined as "any contract that requires or will require access to classified information by the contractor or his employees in the performance of the contract."

The following conditions constitute public release:

• Any information distributed in an uncontrolled manner, whereby the holder or recipient of the information cannot be determined.
• Any information distributed without instructions for handling, relative to public release.
• Any information distributed or made available to persons who have no official interest in the information.

Individual Responsibility

The prohibition against public release of information extends to informal conversations of personnel with friends, relatives, and fellow employees. The fact that the same or similar information appears in public news media must not be construed as license to confirm, deny, discuss, or further disseminate such information. Within the Company it is the responsibility of the holder of classified information to verify the requestor's level of clearance and "need to know" before releasing information.

Release To Visitors

Classified documents and equipment shall not be removed from the Company by any visitor, except in emergency situations or when time does not permit mailing. In those exceptional cases, the visitor must possess a courier authorization (filed with the Security Administrator) and all removals must be processed through the Security Department.

Release To Foreign Nationals

It is the general policy of the United States Government not to release any military, scientific or technical data to foreign nationals unless the United States Government is assured, on a Government- to-Government basis, that its information will be properly protected. The release of such information, requires approval of the cognizant Government department in accordance with established laws and Executive Orders. This applies whether the release is inside or outside the continental limits of the United States and whether the transmission is accomplished by oral, visual, or documentary means. All such proposed releases will be coordinated with the Security and Contracts Department.

Release To Public Media

Classified or unclassified information pertaining to classified contracts or projects, including public addresses, technical papers for presentation to professional societies, newspaper or magazine articles including in-house publications, college theses, radio or television scripts, etc., shall not be released for public dissemination until cleared by the User Agency.

Release At Conferences,
Seminars, Symposia, Etc.

Classified information is not to be disclosed in any manner at conferences, seminars, symposia, exhibits, conventions, or other gatherings, except under the conditions described below:

• At a meeting conducted pursuant to and as a necessary element of a specific contract and attended only by authorized persons who have a "need to know."
• At a meeting conducted by a Department of Defense activity at which only contractor and/or Department of Defense personnel are present. If the information to be disclosed is under the jurisdiction of another Government agency and the meeting is to be attended by representatives from other than the Department of Defense, the conducting activity must obtain written approval from the contracting officer.
• At a meeting conducted by the Company, or an association, society or other group sponsored by the Department of Defense, provided written approval of the contracting officer concerned is furnished to the sponsoring activity prior to disclosure, and the meeting is under strict security controls.

Brochures And Sales Literature

Government security regulations require the written authorization of the contracting officer to publish or distribute any classified brochure, promotional sales literature, or similar type material except as follows:

• That which is published or distributed for necessary use by the Company or a subcontractor in the performance of a User Agency contract.
• That which is prepared in reply to a request for a proposal or invitation to bid received from a User Agency, or from a prime or subcontractor of a User Agency.
• That which is in response to a request of a proper official of a User Agency.

PUBLICATION AND DISTRIBUTION AUTHORIZED BY ______________.

Questionnaires And Surveys

To preclude release of information which could be developed into vital intelligence of strategic significance to an enemy of the United States, discretion and sound judgment must be exercised in replying to requests (questionnaires, requests for reports, surveys, etc.) from professional or trade associations, research institutes, consultant agencies or similar organizations purporting to be such. All requests which pertain to a classified contract or proprietary project should be referred without delay, together with proposed reply, to the Company Security Department.  The Company Security Department will coordinate with Contracts for classification review and clearance or denial.

Requests for information involving financial matters or the Company patents should be referred to the Chief Financial Officer/Director of Finance and the Manager of Contracts.

Questionnaires submitted by or under the sponsorship of agencies of the Executive Branch of the Federal Government should be complied with when there is evidence that the requests have been approved by the Bureau of the Budget under the Federal Reports Act of 1942.
 

Related Topics:  Mailing and Carrying Classified Materials, Protecting Sensitive Unclassified Information, Foreign Government Classified Information.

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