nooks logo text

NOOKS TurboFCL

Insider Threat Program Senior Official

Roles & Responsibilities

The Insider Threat Program Senior Official (ITPSO) plays a critical role in the Facility Clearance (FCL) application process and in maintaining compliance with insider threat mitigation requirements after the clearance is granted. Their responsibilities can be divided into two phases: during the FCL application process and after the FCL is approved.

During the FCL Application Process

1. Appointment by Senior Management

  1. The ITPSO must be appointed by the company's senior management. This appointment demonstrates the organization's commitment to implementing an effective insider threat program.

2. Ensuring Compliance with NISPOM Requirements

  1. The ITPSO ensures that the company establishes an Insider Threat Program (ITP) in compliance with the National Industrial Security Program Operating Manual (NISPOM), specifically outlined in 32 CFR Part 117.

3. Development of an Insider Threat Program

  1. The ITPSO oversees the creation of an ITP tailored to the company's size and operations. This includes policies, procedures, and mechanisms to detect, deter, and mitigate insider threats.

4. Coordination with the FSO and Security Team

  1. The ITPSO collaborates with the Facility Security Officer (FSO) and other stakeholders to ensure that the insider threat program aligns with the broader security program.

5. Submission of Required Documentation

  1. The ITPSO may assist in providing necessary documentation to the Defense Counterintelligence and Security Agency (DCSA) to demonstrate compliance, such as policies, training plans, and insider threat procedures.

After the FCL Is Approved

1. Program Implementation and Oversight

  1. The ITPSO leads the implementation of the ITP and ensures ongoing compliance with the insider threat requirements.
  2. This includes regular reviews and updates to policies and procedures.

2. Training and Awareness

  1. Ensures that all employees, including senior management, receive initial and annual insider threat training. Training must cover recognizing, reporting, and mitigating insider threats.

3. Monitoring and Reporting

  1. The ITPSO oversees the monitoring of activities and behaviors indicative of potential insider threats, leveraging both technical and behavioral monitoring tools.
  2. Reports suspicious activities to the appropriate internal and external authorities, such as the DCSA or law enforcement.

4. Maintaining Insider Threat Records

  1. Maintains records of insider threat training, incidents, and mitigation activities, ensuring documentation is accessible for DCSA inspections.

5. Collaboration with Security Functions

  1. Works closely with the FSO and IT personnel to address cybersecurity and physical security risks associated with insider threats.

6. Conducting Periodic Assessments

  1. Evaluates the effectiveness of the ITP through regular self-inspections, updates, and audits to ensure it meets current threats and regulatory requirements.

7. Responding to Insider Threat Incidents

  1. When insider threat incidents occur, the ITPSO coordinates the response, ensures proper investigation procedures are followed, and implements corrective actions to prevent future occurrences.