Headquarters Information Security Program

Office of Headquarters Security Operations

HSO SPOTLIGHT No. 016-2008 Proper Marking and Disposition of Classified Draft and Working Paper Documents

The Office of Independent Oversight, within the Office of Health, Safety and Security (HSS), conducted a recent security inspection of DOE Headquarters. The inspection evaluated the performance of responsible Headquarters Elements across the spectrum of protection related topical areas including Classified Matter Protection and Control (CMPC). One item noted is the need to re-emphasize the requirement for cleared Headquarters employees to properly mark and disposition classified draft or working paper documents.

The Headquarters Facilities Master Security Plan in Section 18, “Protection of Classified Matter in Use” and DOE M 470.4-4, “Information Security” provide the guidance for the marking and retention of classified draft and working paper documents. All cleared employees are required to mark potentially classified draft or working paper documents as specified below. The terms "draft" and "working paper" documents are interchangeable. There is no difference between the two terms.

All potentially classified draft and working paper documents are considered to be interim production stages toward the generation of a final document. As such, all hard copies of draft and working paper documents must contain the following markings:

• the date created;
• the estimated highest potential overall classification level of the draft or working paper at the top and bottom of the outside of the cover page (if any), on the title page (if any), on the first page of text, and on the outside of the back cover or last page. Each interior page of a classified document must be marked at the top and bottom with the highest potential classification level of that page (including unclassified) or the overall classification of the document;
• the overall category (if RD or FRD) of the draft or working paper must be marked on the cover page (if any), title page (if any), or the first page of text. The category marking is not required on draft and working paper interior pages that contain RD or FRD information;
• the annotation “Working Paper” or “Draft” must be marked on the first page of text; and
• any applicable caveats or special markings must be annotated on the cover page (if any), title page (if any), or the first page of text.

Markings prescribed for a final classified document (see DOE M 470.4-4) must be applied when a draft or working paper meets any of the following requirements:

• released by the originator outside the activity, office, or a formally defined working group of individuals participating in a specific activity or project;
• retained for more than 180 days from the date of origin; or
• is no longer being revised and is considered to be a final document

NOTE: Classified documents that are updated on a frequent basis, commonly referred to as “living” documents (e.g., documents that are part of an ongoing experiment, study, or working group) may be considered as originating on each date they are changed. Each time the document is updated, the date must be lined through (without obliterating the preceding date) and the new date affixed to the document. The date of each revision, addition or change must be clearly indicated on the document. Another option is to attach a change sheet to the front of the document which lists the date of each change. Classified working papers and drafts may be transmitted within working groups without being marked as final documents.

Drafts or working paper documents retained after 180 days must be marked as final documents; however, it is often difficult to identify such documents when stored and comingled with other documents. One way to easily identify these documents is to create a separate “Draft” or “Working Paper” folder that is placed within your security container which contains all your “draft” or “working paper” documents. The file should be reviewed monthly by the document custodian or security container custodian to ensure no draft or working paper documents are retained past 180 days without being marked as final documents. An alternative suggestion is to maintain a working paper log, including dates of origination, and review the log monthly.

Finally, classified draft and working paper documents retained past 180 days without being reviewed for classification and marked as final documents are improperly marked documents. Failure to comply with the requirements for reviewing and marking such documents may result in the issuance of a security infraction. As such, if you are in possession of such documents, regardless of whether you are the originator, you must either destroy them before day 181, return them to the originator for proper classification marking prior to day 181, or submit them to your organization’s classification representative or derivative classifier for proper classification review, determination and marking.

Required Actions:

HSO Program Manager Comment
A training session for HSOs will be held in the November/December 2008 timeframe and will be devoted to this and other CMPC issues.

If you have any questions regarding this HSO Spotlight, please contact the Information Security Program at (301) 903-9990.