INSA Security Clearance Reform Recommendations

Since 1947 the average spy began committing espionage after 12 years of service. That highlights why periodic reinvestigations (PR) are critically important.

The influential Intelligence and National Security Alliance (INSA) has released the Security Reform Policy Council white paper on Leveraging Emerging Technologies in the Security Clearance Process. INSA includes a number of connected, heavy hitters so this is a preview of what may be coming to pass in security clearance reform.

There is commitment from all ends of the spectrum, agencies, contractors and politicians, to do something about security clearance reform. But it’s not as easy as it may seem on the surface. There are multiple agencies with varying databases as well as a workforce of investigators and adjudicators that is not currently staffed or trained to work with the changes that are being proposed.

An Army project using the automated continuing evaluation system (ACES) that was developed in 2005 found that about 20% of cases revealed something of adjudicative interest. That’s a potential for much more information for adjudicators to consider and weigh in making decisions.

But all agree that with today’s pace of life that a periodic reinvestigation every five or ten years doesn’t meet the nation’s needs. The INSA concept is compared to triage in an ER and a focus on continuous monitoring and evaluation:

The group’s recommendations:

1. Incorporate an enhanced PR into the security clearance process. Continuous monitoring and evaluation to evaluate current data and provide a more realistic whole person review of a cleared individual’s habits and life changes.
2. Move to an online clearance information reporting application. A centralized clearance repository that provides instant access to the most current data for investigations and adjudications.
3. Make use of internal agency databases. Link the above-referenced online reporting application to each agency’s internal database where information such as performance reviews, foreign travel and financial disclosure information is found.
4. Use an enhanced PR to target high-risk cleared population. Maintain risk profiles and set escalation flags for individuals who are cleared at multiple levels on differing contracts or at multiple agencies.
5. Leverage an enhanced PR as a deterrent and accountability booster. Theoretically since there is more accountability, clearance holders will be more “careful, accurate and timely” in reporting foreign contact, financial issues, personal relationships and so on.
6. Partner with the insider threat and counterintelligence efforts. Accurate big data analysis should help determine suspicious behavior profiles.
7. Identify a proof of concept population. Proposes piloting with the SCI population, which is only 4% of clearance holders.
8. Set expectations with a cost-benefit analysis, metrics and technology standards. Essentially have agencies define up front the potential pitfalls.
9. Start early to train investigators and adjudicators to be prepared for new ways of doing business. A clear understanding that training the affected workforce of adjudicators and investigators is key to successful clearance reform.
10. Ensure civil liberties and privacy concerns and general counsel representatives are active participants in CME planning. Recognition that some may feel there are inherent civil liberty issues and that the Civil Liberties Privacy Office and general counsels will need to be involved.

At an INSA presentation panelist Kirk McConnell, Staff Member on the Senate Armed Services Committee expressed concern that the group is proposing “bolting on continuous evaluation” to the security clearance process, as opposed to instituting real reform. What do you think?