Snowden scandal sparks internal reviews

The Edward Snowden scandal has contractors looking internally and reviewing their security processes. What critical areas should you be taking a look at?

Most of the fallout from the Edward Snowden scandal has focused on the policy and politics of large-scale surveillance programs, and given Snowden’s connection to Booz Allen Hamilton, what role contractors should play in these programs.

The reality for contractors, though, is that the government will always need them to have high security clearances so they can work on sensitive intelligence systems.

For contractors, the Snowden scandal has raised awareness for the need to review internal processes meant to mitigate the chances of another security breach of this nature, and internal reviews are different for every company, there are some basic questions and issues that apply across the board.


Post-Snowden Security Checklist

Who has security clearances and what does that give them access to?

Who has current ‘need to know’ privileges?

Are access codes for email systems and data bases up to date?

Are access codes for former employees systematically purged?

Establish a code of business ethics and conduct.

Promote a sense of organizational commitment to compliance by:
     C-suite encourages employees to speak up about suspicions.
     Time off for compliance training.
     Communicate compliance as an important company value.


In general, contractors need to be “making sure there's clear information about who has security clearances, and for what purpose,” said Alan Chvotkin, Professional Services Council executive vice president and counsel.

Chvotkin has been talking to a number of security officers, whose job it is to manage and oversee security clearances within an organization. These security officers are “making sure that they have good information about which employees have security clearances, and what those clearances give them access to,” he said.

“Need to know” distinctions also need to be considered when it comes to security clearances. To access classified information, “there has to be a current need to know,” Chvotkin said, in addition to having the security clearance.

“If you don’t have that current need to know, then there’s some question to whether you should retain a clearance,” he said.

It’s important that this “need to know” distinction is always tested, which sometimes doesn’t happen in larger organizations, Chvotkin said.

Internal controls are also crucial, and need to be reviewed.

“Internal controls are everything from badges to access codes to authorizations,” Chvotkin said.

Authorization was one of the issues in the Snowden case, he added, as there’s a question of what Snowden was authorized to look at.

What complicates this question is the fact that these authorizations are often government decisions, not contractor decisions, Chvotkin said.

Along with authorizations, access codes are another particularly important part of internal controls in that they need to be consistently updated, but can easily fall to the wayside with all of the higher priority security concerns.

Access codes, in this case, are things like login credentials for e-mail systems and databases. The conventions of these credentials are sometimes easy to figure out, which puts importance on regular updating.

If you have an organization with a lot of turnover and former employees, they could potentially access the system in question if the access codes aren’t regularly updated; in other words, good IT hygiene is important, Chvotkin said.

“These are the areas where the vulnerability is the easiest, but it's also the easiest to fix,” he said.

In relation to all of these issues, companies should be checking part three of the Federal Acquisition Regulation, which relates to fraud and bribery, said Devon Hewitt, partner at Protorae Law.

Within part three of the FAR is clause 52.203-14, which dictates that contractors must establish a code of business ethics and conduct; it’s from this clause that many of a company’s internal controls are derived.

But what’s also important is promoting a sense of organizational commitment to compliance, Hewitt said; in other words, you need to make sure your employees are both committed to compliance, and have everything they require to report any suspicion of wrongdoing.

However, even had these processes all been in top shape, there is some speculation that what happened still would have transpired.

“I'm not sure that a background check here, either by the contractor or by the service that did the clearance, would have necessarily disclosed that he was going to be doing this,” Hewitt said.
Her question is whether anybody wondered about him, in general—if he espoused his beliefs to colleagues, and if that raised any red flags for anyone around him.

That’s why promoting organizational commitment to compliance is so important; if employees are encouraged to speak up with their suspicions, it’s all the more likely that security threats are detected in time to prevent severe repercussions, she said.

A good way to promote organizational commitment is to have the company’s chief operating officer communicate it as an important company value. Companies also should give employees time off to be trained in the various processes of the company.

“If there's a communicated commitment, I think employees feel far more comfortable to raise issues of noncompliance,” Hewitt said.

While it ultimately might be impossible to stop every threat, companies can still take precautions to avoid problems as best as they can.

“It's almost impossible to prevent a single action by a single individual. It’s impossible to adopt any method other than no access whatsoever, for anybody, that will guarantee that a Snowden type event will never happen again,” Chvotkin said.

But that doesn’t mean that companies shouldn’t try; “I think companies can take intelligent, reasonable, measured steps to minimize the risk,” he said.

Several companies contacted for comment on this story declined.

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