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Headquarters Information Security Program

Office of Headquarters Security Operations

HSO SPOTLIGHT No. 003-2009 Key Management Personnel (KMP)

What is the issue: Processing KMP Access Authorizations (Security Clearances)
Why do we need this?:  Requirement of DOE Order 470.4-1
Who is impacted?: HSOs and KMPs
What does the HSO need to do?:  Include KMPs in their normal process and procedures for initiating and approving access authorizations
 

DOE Manual 470.4-1 requires each contractor seeking a facility clearance to submit a list of certain company officials, such as owners, officers, directors, partners, regents, trustees, or other executive personnel who may be designated as a Key Manager. This list is reviewed by the Office of Headquarters Security Operations, Headquarters Information Security Program, HS-1.312, and a determination is made as to exactly which individuals will be designated as Key Managers and, therefore, are required to obtain an access authorization.

Currently, HS-1.312 is processing KMPs for access authorizations as part of the Foreign Ownership, Control or Influence (FOCI) and Facility Clearance (FCL) approval process. In order to provide more comprehensive support to the contractor and contract operations, this process will now be completed by the HSO of the responsible procuring organization. KMPs will still be identified by HS-1.312; however, the appropriate HSO will be notified of the needed clearances and will be expected to complete the necessary coordination of paperwork, initiation into e-QIP, and all other clearance-related processing. In addition, HS-1.312 will no longer maintain sponsorship of these individuals in the Management Information System.


HS-1.312 will follow this process when notifying the responsible organization of necessary clearances:

  • FOCI submission will be reviewed to identify the KMPs
  • HS-1.312 will notify the HSO of the responsible organization of the names of Key Managers and their company affiliation
  • HS-1.312 will notify the contractor of the identity of the responsible HSO, the names of the people identified as Key Managers, and what access authorization is required

For those contractors holding multiple contracts with many organizations, HS-1.312 will determine the contract requiring the highest security access level via the Safeguards and Security Information Management System. The procuring organization with the contract requiring the highest security access level will become the responsible organization for the KMPs.

If you have questions or concerns about this HSO Spotlight, please contact the Office of Headquarters Security Operations, FOCI/FCL, at (301) 903-8068.
This page was last updated on May 09, 2012