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//ruuy
Central Intelligence
Washington, D.C. 20505
5 November 2015
Mr. John P. Fitzpatrick, Director
Information Security Oversight Office
National Archives and Records Administration
Washington, D.C. 20408-0001
Dear Mr. Fitz trick:
(Ti) In response to the Information Security Oversight
Office (1500), the Central Intelligence Agency (CIA) submits
the enclosed FY 2015 Agency Annual Self-Inspection Program
Data Report. This report covers the period from
1 October 2014 to 30 September 2015.
(U//FOU0) CIA built upon its successes from last
year's report and continues to find great value in this
exercise. In the 2,614 documents we reviewed, we found that
portion marking continues to be a great shortcoming, but
derivative classifiers tend to classify at the right level
for the right reasons. We also found our OCA training
numbers to be low, but this is due in part to shifts in
personnel from OCA positions to newly created mission
centers and directorates. CIA will review its OCA
delegations in the coming months, likely increasing the
number of OCAs to accommodate ten new mission centers and
one new directorate. CIA will also use this review as
opportunity to ensure that far more of our OCAs are properly
trained by the end of FY 2016.
UNCLASSIFI OUO
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(U) Please contact Mr. Harry Cooper, Chief,
Classification Management and Collaboration Group, at 703-
if you have any questions regarding the FY 2015
self-inspection report.
Jo ph W. Lambert
Director, Information Management Services
UNCLASSIFIED//FOLIO
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AGENCY ANNUAL SELF-INSPECTION PROGRAM DATA: FY 2015
(Submissions must be unclassified.)
I. Enter the agency name.
PART A: Identifying Information
1. Central Intelligence Agency
2. Enter the date of this report.
2. November 3, 2015
3. Enter the name, title, address, phone, fax and e-mail address of the Senior
Agency Official (SAO) (as defined in E.O. 13526, section 5.4(d)) responsible
for this report.
3.
Joseph W. Lambert
Director, Information Management Services (IMS)
CIA Washington DC 20505
(
4. Enter the name, title, phone, fax, and e-mail address of the individual or
office responsible for conducting self-inspections and reporting findings.
4. Harry P. Cooper, Jr.
Chief, Classification Management and Collaboration Group (CMCG)
CIA Wachinnton no 7r)r)
(
5. Enter the name, title, phone, fax, and e-mail address for the point-of-
contact responsible for answering questions regarding this report.
5. Harry P. Cooper, Jr.
Chief, Classification Management and Collaboration Group (CMCG)
CIA, Washington, DC 20505
(t
PART B: Classified National Security Information (CNSI) Program Profile Information
6. Has your agency been designated/delegated as an original classification authority (OCA)?
6. 0 Yes 0 No
7. Does your agency perform original classification activity?
7. 0 Yes 0 No
8. Does your agency perform derivative classification activity?
8. 0 Yes 0 No
9. Does your agency have an approved declassification guide and declassify CNSI?
9. 0 Yes 0 No
PART C: Self-Inspection Program Activity: Number of Self-Inspections Conducted
In FY 2014 and prior years, this information was reported on Standard Form 311, "Agency Security Classification Management Program Data."
10. Enter the number of self-inspections of the classified national security information program that were conducted by
your agency during the reporting period. (Note that this does not include routine after-hours security checks.)
10. 1 7
PART D: Description of the Program
A description of the agency's self-inspection program to include activities assessed, program areas covered, and methodology utilized. The
description must demonstrate how the self-inspection program provides the SAO with information necessary to assess the effectiveness of the CNSI
program within individual agency activities and the agency as a whole.
Responsibility
11. How is the SAO involved in the self-inspection program? (Describe his or her involvement with the self-inspection program.)
The SAO delegates responsibility to CMCG for the self-inspection program, approves the annual
self-inspection plan, receives briefings on its results and recommendations, and approves follow-on
actions.
12. How is the self-inspection program structured to provide the SAO with information necessary to assess the agency's CNSI program in order to
fulfill his or her responsibilities under section 5.4(d) of E.O. 13526?
During FY15, while conducting ongoing self-inspection of documents in the Washington Metro Area (WMA), CMCG engaged field
location counterparts through travel. Following each travel opportunity, the SAO received a memo with the results. The self-inspection is
designed to cover compliance with all 5.4(d) areas of responsibility and to identify best practices and areas of improvement.
13. Whom has the SAO designated to assist in directing and administering the self-inspection program? Who conducts the self-inspections?
(If the SAO conducts the self-inspections, which may be the case in smaller agencies, indicate this.)
The Chief of CMCG, an SES-level officer, is designed to assist in directing and administering the
self-inspection program. A number of classification specialists in CMCG conduct the self-inspections.
Approach
14. What means and methods are employed in conducting self-inspections? (For example: interviews, surveys, data calls, checklists, analysis, etc.)
CMCG continues to utilize best practices developed during FY14, including a standard operating procedure, working with records
management colleagues to capture electronic records, and collaborating with colleagues in the field to access their records. CMCG
further refined its assessment worksheets to streamline collection and better address questions posed by the SAO, CMCG, and ISO�.
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is. If your agency performs different types of inspections (e.g., component self-inspections, command inspections, compliance reviews, etc.),
describe each of them and explain how they are used. If not, indicate NA.
CMCG continued to review documents across all components of CIA through document sampling and classification
assistance throughout FY15. CMCG also engaged in 16 field location visits during FY15, which are counted as
separate self-inspections in Part C, above. CMCG continued to conduct the annual Classification Count and analysis.
16. Do your agency's self-inspections evaluate adherence to the principles and requirements of E.O. 13526 and its implementing
effectiveness of agency programs covering the following areas? (Select all that apply.)
directive and the
Management and oversight
[i] Original classification 0 Security violations 0 Safeguarding 0
0 Derivative classification 0 Declassification 0 Security education and training
17. Do your self-inspections include a review of relevant security directives and instructions?
17. ()Yes ONo
18. Do your self-inspections include interviews with producers (where applicable) and users of classified information?
18. ()Yes ONo
Approach: Representative Sample
(If your agency does not classify information, indicate NA.)
19. Do your self-inspections include reviews of representative samples of original and derivative classification
actions to evaluate the appropriateness of classification and the proper application of document markings?
19. ()Yes 0 No ONA
20. Do these reviews encompass all agency activities that generate classified information?
20. �Yes 0 No ONA
21. Describe below how the agency identifies activities and offices whose documents are to be included in the sample of classification actions.
(Indicate if NA.)
In the WMA, CMCG deliberately sampled documents that reflect the five major business areas of the agency. In field locations, CMCG
worked closely with officers to ensure that the reviewed documents reflected an accurate depiction of their unique missions. The
diversity of locations provided CMCG with a sample of all the activities encompassed by CIA's mission.
22. Do the reviews include a sampling of various types of classified information in document and electronic
formats?
22. ()Yes 0 No ONA
23. How do you ensure that the materials reviewed provide a representative sample of the agency's classified information? (Indicate if NA.)
In the WMA, CMCG worked with IMS records management colleagues to collect a sample of documents that covered all agency
components. This yielded material across the spectrum of the CIA mission. CMCG also reviewed analysis and reporting published on
internal portals so as to evaluate trends of classified materials disseminated outside of the agency. CMCG continued to conduct visits to
field locations, which provided a unique sample of documents related to the day-to-day mission critical activities of CIA.
24. How do you determine that the sample is proportionally sufficient to enable a credible assessment of your agency's classified product?
(Indicate if NA.)
CMCG has continually assessed the documents reviewed to ensure the sample represents all major business areas and the missions/responsibilities
of those areas. CMCG deemed that this sample was sufficient to enable a credible assessment, based on the requirements of 32 CFR 2001.60.
CMCG also determined that documents from 16 field locations represent the spectrum of documents associated with CIA operations.
25. Who conducts the review of the classified product? (Indicate if NA.)
Designated CMCG full-time classification specialists conduct document reviews. For field reviews, CMCG designates teams of three
individuals to conduct classification reviews, interview field personnel, and provide training on classification policies, practices, and
employee obligations regarding their secrecy agreements.
26. Are the personnel who conduct the reviews knowledgeable of the classification and marking requirements of
E.O. 13526 and its implementing directive?
26. 'Yes ONo ONA
27. Do they have access to pertinent security classification guides? (Indicate if NA.)
27. ()Yes ONo ONA
28. Have appropriate personnel been designated to correct misclassification actions? (Indicate if NA.)
28a. If so, identify below.
28. ()Yes �No ONA
Frequency
29. How frequently are self-inspections conducted?
CMCG conducts the self-inspection year round. 16 field location visits took place over approximately seven months of FY15.
30. Describe the factors that were considered in establishing this time period?
Field location visits require extensive coordination with the respective offices to facilitate access in a manner that would not disrupt mission
critical activities. Document inspection in the WMA continued year-round in order to allow CMCG sufficient time to identify possible data
gaps within the sample and to provide opportunity to return to IMS records management partners for additional documents.
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Coverage
31. How do you determine what offices, activities, divisions, etc., are covered by your self-inspection program? What agency activities are
assessed?
CMCG engaged in document review and personnel interviews in field locations and performed extensive document
review and data analysis in the WMA. CIA had five major business areas, and CMCG deliberately sampled
documents that reflect these components and their respective areas of responsibility within the broader CIA.
32. How is the self-inspection program structured to assess individual agency activities and the agency as a whole?
CMCG carefully considers the type of function performed in each component and the types of documents that each of these
components produces. Classification assistance questions and results from previous years self-inspections help to shape this
consideration. CMCG also considers the demanding circumstances surrounding work in the field and in high-tempo areas of CIA as it
pertains to understanding how officers in the field classify information.
Special Access Programs (SAP)
(If your agency does not have the authority to create SAPs, indicate NA.)
33. If your agency has any special access programs, are self-inspections of the SAP programs conducted annually?
33. ()Yes ONo ONA
34. Do the self-inspections confirm that the agency head or principal deputy has reviewed each special access
program annually to determine if it continues to meet the requirements of E.O. 13526?
34. �Yes ONo ONA
35. Do the self-inspections determine if officers and employees are aware of the prohibitions and sanctions for
creating or continuing a special access program contrary to the requirements of E.O. 13526?
35. �Yes ONo ONA
Reporting
36. What is the format for documenting self-inspections in your agency?
CMCG documents its self-inspection through standardized document checklists, followed by data aggregation spreadsheets. CMCG also uses standardized forms for field
personnel interviews. Following each field visit, CMCG prepares a classified trip report that analyzes findings and after-action opportunities related to classification training and
practice improvements. As requested, CMCG briefs the SAO on these visits and overall progress. At the end of the self-inspection, CMCG prepares the annual report and briefing
materials for the SAO and other senior officials, as necessary.
37. Who receives the reports?
The SAO; Chief of CMCG; the Chief Information Officer; other agency senior officials, as necessary; 500.
38. Who compiles/analyzes the reports?
The CMCG Analysis and Review Staff.
39. How are the findings analyzed to determine if there are problems of a systemic nature?
CMCG aggregates data from the document checklists and personnel interviews in spreadsheets, then develops formulas that identify opportunities for
improvement in the reporting areas required by ISO�. CMCG also tracks and analyzes trends in classification derivative choices, application of dissemination
controls, classification differences between WMA and field locations, and classification differences between the five major agency components. The final
analysis helps CMCG identify potential areas for improvement in both customized and agency-wide original and derivative classifier training.
40. 1-low and when are the results of the self-inspections reported to the SAO?
CMCG briefs the SAO after completion of data analysis and production of draft findings and recommendations. The annual
self-inspection program data form is submitted to the SAO before it is released to 'SOO. Once the SAO approves the findings
and recommendations, CMCG submits the form to [SOO and begins implementation of recommendations as necessary.
41. How is it determined if corrective actions are required?
CMCG carefully analyzes its document review and interview data for opportunities for improvement in
agency-wide classification practices. If/when patterns are evident, either in a particular business area
or agency-wide, CMCG develops possible corrective action for consideration by the SAO.
42. Who takes the corrective actions?
This depends on the finding: CMCG, IMS records management partners, field offices when necessary.
43. How are the findings from your agency's self-inspection program distilled for the annual report to the Director of ISOO?
CMCG continues to conduct analysis of documents via spreadsheet. This information is distilled into findings for the Director of !SOO.
Self-inspection findings are also supported by day-to-day classification support, training provided by CMCG to CIA, and data collected
during the annual classification count.
44. Has the SAO formally endorsed this self-inspection report? If yes, please provide documentation. 44. 0 Yes ONo
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PART E: A summary of the findings of your agency's self-inspection program
The summary should present specific, concise findings from your self-inspection program for each of the required program areas below. It is not a
description of the requirements of the agency's CNSI program. Rather, the summary outlines the essential self-inspection findings based on the
compilation and/or distillation of the information contained in the agency's internal self-inspection reports, checklists, etc. In large agencies where
findings are drawn from multiple agency offices and activities, the findings that are reported here may be the most significant or most frequently
occurring.
45. Original Classification:
The self-inspection determined that the number of original classifiers (OCAs) was kept at the lowest possible
level, based on demonstrable and continuing need to exercise this authority, per E.O. 13526, Sec. 1.3.
Original classifier training was frequently provided and, in keeping with this training, OCAs understood that
their authority is only to be exercised in the rare case that an Agency classification guide does not provide
sufficient guidance, and there appears to be a need for classification, based on E.O. 13526 criteria.
46. Derivative Classification:
From a sample of over 2,100 documents, the self-inspection found that 5.02% of documents were overclassified and 3.03% were
underclassified. Specifically, 17.31% of documents classified as TOP SECRET (TS) were overclassified, including 16.83% that
should have been SECRET (S). 2.84% of documents classified S were overclassified, with 2.07% that should have been
CONFIDENTIAL (C). Less that 1% of C documents were overclassified, but 1.76% of C documents were underclassified. Most
prominently, the self-inspection found that 87% of sampled documents lacked portion marking. CMCG also noted that 2% of
sampled documents had an inappropriate ORCON/NOFORN caveat.
47. Declassification:
CIA continued declassification program improvements with additional metrics and statistical reports to better manage Freedom of Information Act (FOIA),
Privacy Act (PA), and Mandatory Declassification Review (MDR) declassification efforts. In FY15, initial FOIA/PA backlog increased 43% and MDR backlog
decreased 45%. The Agency reduced the FOIA/PA appeals backlog by 4% and the MDR backlog by 18%. The Agency closed nine of the 10 oldest FOIA initial
cases and five of the 10 oldest FOIA appeals cases. The CIA automatic declassification program in FY15 received a 100% score in the !SOO assessment
(external !SOO assessment vice "self-assessment"). The 'SOO assessment evaluated missed exemptions, missed referrals, and improper exemptions. Our
own internal quality assurance program for automated review, which looks at 100% of declassified documents, has identified a less than 2% error rate prior to
official declassification (errors are subsequently corrected). Once released, errors identified by ourselves, other government agencies, or the public are rare.
48. Safeguarding:
The review found that the Agency has a robust program for safeguarding classified information. Within the components, instructions are
in place and staff and contract employees are aware of the policies and procedures. The Agency has a diverse training and education
program designed to address each aspect of safeguarding national classified information such as classification; personnel reporting
requirements; and cyber security. Within each of the safeguarding disciplines, the Agency strives to develop proactive measures versus
reactive measures to secure classified information. Following E.O. 13526 and the Intelligence Community Directives (ICDs), the Agency
has revised numerous regulatory issuances to provide specific guidance to employees and contractors.
49. Security Violations:
The review determined that the Agency has a well-developed program to ensure security violations are investigated, adjudicated,
and recorded in alignment with E.O. 13526, Presidential Decision Directive 12, ICDs 703 and 704, and with procedures established
by the Department of Justice and the Federal Bureau of Investigation. Violations are recorded and tracked to prevent repeated
violations. Employees receive one-on-one counseling when incidents do occur. The Agency has a sustained record of providing
training and employee awareness to prevent security violations. The Agency's number of security violations has remained
consistent between FY14 and FY15.
50. Security Education and Training:
The review concluded that the Agency's program for Security Education and Training supports multiple training
levels--from orientation for new hires, to mandatory refresher courses, to in-depth, area-specific training for
employees and contractors. Employee awareness is high as a result of regularly offered special courses and
lectures. The Agency's program to record all training and enforce mandatory training requirements ensure the
opportunity for all employees to demonstrate a sound understanding of safeguarding classified information.
51. Management and Oversight:
CMCG provides year-round classification assistance to CIA and its partners. This includes professional courses for classification specialists, training for new
personnel in the fundamentals of classification, as well as training for various components and federal partners. CMCG also provides original and derivative
classifier refresher training and a classification assistance service that provides real-time assistance to Agency personnel. Based on the initial success of the
program in FY14, CMCG has increased the number of classification referents deployed to Agency business areas, which provides improved classification
assistance to a second business area. These functions provide insight into the types of problems that are encountered on a daily basis and helps CMCG
strengthen classification training, classification guide development, and regulatory policy adjustments which provide meaningful support to the workforce.
CMCG brings issues to the attention of the SAO, who consults with the CIO, Agency Executive Director, and others as appropriate.
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PART F: An assessment of the findings of your agency's self-inspection program
The assessment discerns what the findings mean. The assessment is an evaluation of the state of each element of your agency's CNS1 program
based on an analysis of the specific, concise findings of the self-inspection program. It reports what you have determined the findings indicate about
the state of your agency's CNSI program.
The assessment should inform the SAO and other decision makers of significant issues that impact the CNSI program. It should be used to determine
how security programs can be improved, whether the agency regulation or other policies and procedures must be updated, and if necessary resources
are committed to the effective implementation of the CNSI program. The assessment should report trends that were identified during the reporting
period across the agency or in particular activities, as well as trends detected by making comparisons with earlier reporting periods. It can be used to
support assertions about the successes and strengths of an agency's program.
52. Original Classification:
During FY15, 9 of the 14 OCA actions involved approval of new classification guides developed in
collaboration with business areas in order to provide meaningful protection guidance to officers working with
these equities. CMCG continues to work closely with subject matter experts throughout the Agency to identify
other business areas, projects, programs, and/or topics that would benefit from more customized guidance
associated with classified material.
53. Derivative Classification:
CMCG continues to strive toward the highest standard for classifying material and continues to include lessons learned during the
self-inspection in planning for future actions. Proper portion marking continues to be a major shortcoming agency-wide and will be a specific
point of emphasis in all future training. Issues with classified information in cables and email signatures has been raised in many discussions
and agency authorities have sent reminders to users in the field to be especially vigilant about this reoccurring error. By the end of FY15, CIA
has created 24 Security Classification Guides (SCGs) and is in the process of developing another 23. Through FY16, CMCG will continue to
provide live support to personnel and develop on-demand web-based training and assistance that can reach officers worldwide.
54. Declassification:
IMS is pursuing a major new information technology initiative, Next Generation Information Management (NGIM). This initiative includes new tools based
on machine learning and artificial intelligence designed to significantly improve review accuracy, equity identification, and review efficiency. The Agency
continues to refine processes and management to improve its declassification efforts. The Information Review and Release Group is also taking
advantage of new resources and opportunities to increase training and outreach within the Agency and around the US Government. The Agency
understands that declassification work will continue to increase at a staggering pace and CIA will continue to identify and leverage new partnerships and
opportunities to meet the challenges ahead.
55. Safeguarding:
The Agency's safeguarding measures meet the needs of the mission; however, the Agency continues to seek
advancement through innovation and use of technology while testing the current methods. The Agency is
increasingly implementing metadata schema to enforce system safeguards. Improvements to these metadata
systems will enable greater precision with document security practices. The Agency continues to revise and
update policies and procedures to reflect modernization.
56. Security Violations:
The self-inspection affirmed that the Agency's education and training programs have developed a work force that
appropriately report security violations. The Agency is a front running within the IC with respect to developing,
implementing, and improving programs to enhance employee compliance with security regulations. For example,
the Agency had a comprehensive program for reporting contact with foreign nationals prior to the Presidential
Decision Directive 12. We continue to advance policy and procedures to inform the workforce and raise awareness.
57. Security Education and Training:
The Agency's security education and training program provides instruction for all levels and multiple aspects of safeguarding
classified information, specifically adapted to our mission. The Agency's modernization has resulted in a comprehensive review of
Agency training and employee development, including security education. The Agency maintains a fully developed curriculum to
ensure safeguarding of classified information; essential security education is mandatory for all employees and contractors. For
FY16, the Agency's web-based training for derivative classifiers will be compliant with the Americas with Disabilities Act, ensuring
increased accessibility for derivative classifiers.
58. Management and Oversight:
The self-inspection continues to provide unique opportunities for CMCG to interact with personnel from all
over the Agency and around the world. Travel allowed CMCG to better understand CIA's most active and
sensitive programs, provide in-person guidance and training, and hear firsthand about the ways CMCG can
improve support to its colleagues. CMCG will continue to improve its outreach to the Agency workforce and
work with its colleagues to develop meaningful, timely solutions for every situation.
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PART G: Focus Questions
Answer the questions below. If the response identifies a deficiency, it should be explained in Part D, Summary of Findings, under the relevant
program area, and should be addressed in Part H, Corrective Actions.
Training for Original Classification Authorities
Original classification authorities are required to receive training in proper classification and declassification each calendar year. (Section 1.3(d) of
E.O. 13526 and � 2001.70(c) of 32 C.F.R. Part 2001) (Indicate NA ifyour agency does not have original classification authority.)
59. Does agency policy require training for original classifiers?
59. �Yes ONo ONA
60. Has the agency validated that this training has been received?
60. ()Yes ONo ONA
61. What percentage of the original classification authorities at your agency has received this training?
61. 67%
0 Actual 0 Estimated
62. Have any waivers to this requirement been granted?
62. �Yes ONo ONA
Persons who Apply Derivative Classification Markings
Persons who apply derivative classification markings are required to receive training in the proper application of the derivative classification
principles of P.O. 13526, prior to derivatively classiffing information and at least once every two years thereafter. (Section 2.1(d) of E.O. 13526 and
� 2001.70(d) of 32 C.F.R. Part 2001) (Indicate NA ifyour agency does not have any personnel who derivatively classify information.)
63. Does agency policy require training for derivative classifiers?
63. �Yes ONo ONA
64. Has the agency validated that this training has been received?
64. �Yes ONo ONA
65. What percentage of the derivative classifiers at your agency has received this training?
65. 93%
0 Actual 0 Estimated
66. Have any waivers to this requirement been granted?
66. ()Yes ONo ONA
Initial Training
All cleared agency personnel are required to receive initial training on basic security policies, principles, practices, and criminal, civil, and
administrative penalties. ([2001.70(b) of 32 C.F.R. Part 2001)
67. Does agency policy require initial training?
67. ()Yes ONo
68. Has the agency validated that this training has been received?
68. ()Yes ONo
69. What percentage of cleared personnel at your agency has received this training?
69. 100%
(0 Actual 0 Estimated
Annual Refresher Training
Agencies are required to provide annual refresher training to all employees who create, process, or handle classified information. ([2001.70(f) of
32 C.F.R. Part 2001)
70. Does agency policy require annual refresher training?
70. ()Yes ONo
71. Has the agency validated that this training has been received?
71. ()Yes ONo
72. What percentage of the cleared employees at your agency has received this training?
72. 93%
0 Actual 0 Estimated
Identification of Derivative Classifiers on Derivatively Classified Documents
Derivative classifiers must be identified by name and position, or by personal identifier on each classified document. ('ection 2.1(b)(1) of E.O.
13526 and � 2001.22(b) of 32 C.F.R. Part 2001) (Indicate NA ifyour agency does not derivatively classh(b information.)
73. Does your agency's review of classification actions evaluate if this requirement is being met?
73. �Yes ONo ONA
74. What percentage of the documents sampled meet this requirement?
74. 97.8%
75. What was the number of documents reviewed for this requirement?
75. 2,614
List of Sources on Documents Derivatively Classified from Multiple Sources
A list of sources must be included on or attached to each derivatively classified document that is classified based on more than one source document
or classification guide. (� 2001.22c(f)((b of 32 C.F.R. Part 2001)
76. Does your agency's review of classification actions evaluate if this requirement is being met?
76. �Yes ONo ONA
77. What percentage of the documents sampled meet this requirement?
77. 79.4%
78. What was the number of documents reviewed for this requirement?
78. 2,614
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Performance Evaluations
The performance contract or other rating system of original classification authorities, security managers, and other personnel whose duties
significantly involve the creation or handling of classified information must include a critical element to be evaluated relating to designation and
management of classified information. ('ection 5.4(d)(7) of E.O. 13526)
79. Does agency policy require this critical element in the performance evaluations of personnel in the
categories required by E.O. 13526?
79. 0 Yes 0 No
80. Has the agency validated that this critical element is included in the performance evaluations of
personnel in the categories required by E.O. 13526?
80. 0 Yes 0 No
81. What percentage of such personnel at your agency has this element in their performance
evaluations?
81. 100%
0 Actual Estimated
OCA Delegations
OCA delegations shall be reported or made available by name or position to the Director of the Information Security Oversight Office. (Section
1.3(c)(5) of E.O. 13526). This can be accomplished by an initial submission followed by updates on a frequency determined by the SAO, but at least
annually. (�2001.11(c) and �2001.90(a) of 32 C.F.R. Part 2001)
82. Have there been any changes in the delegations, by name and position, of original classification
authority in your agency since delegations were reported to ISO� in 2010.
82. ()Yes ONo ONA
83. Have all delegations been limited to the minimum required based on a demonstrable and
continuing need to exercise this authority?
83. �Yes ONo ONA
84. If changes have been made, have they been reported, by name or position, to ISOO?
84. ()Yes ONo ONA
Classification Challenges
An agency head or SAO shall establish procedures under which authorized holders of information, including authorized holders outside the
classiffing agency, are encouraged and expected to challenge the classification of information that they believe is improperly classified or
unclassified. (Section 1.8(b) of E.O. 13526) Classification challenges must be covered in the training for original classification authorities and
persons who apply derivative classification markings. 02001.71 (c) and (�2001.71(d) of 32 C.F.R. Part 2001)
85. Has your agency established procedures under which the classification of information can be
challenged in accordance with section 1.8(b) of E.O. 13526 and �2001.14 of 32 C.F.R. Part 2001?
85. ()Yes ONo
86. Does your agency's training for OCAs and for personnel who apply derivative classification
markings cover classification challenges?
86. ()Yes No
87. Does your agency's training for all other cleared personnel cover classification challenges?
87. �Yes 0 No
Industrial Security
The National Industrial Security Program (NISP) was established under E.O. 12829 to safeguard Federal Government classified information that is
released to contractors, licensees, and grantees (hereinafter contractors) of the United States Government. The Secretary of Defense serves as
Executive Agent for inspecting and monitoring the contractors, who require or will require access to, or who store or will store classified information,
and for determining the eligibility for access to classified information of contractors and their respective employees. Besides the Department of
Defense (DoD), there are four other agencies that are Cognizant Security Agencies (('SAs): the Office of the Director of National Intelligence
(ODNI), the Department of Energy, the Nuclear Regulatory Commission, and the Department of Homeland Security, that are authorized to provide
operational oversight of their contractors. The heads of other agencies, except the Central Intelligence Agency (CIA), are required to enter into
agreements with the Secretary of Defense that establish the terms of the Secretary's responsibilities on behalf of these agency heads. The ODNI may
enter into an agreement with the CIA authorizing the latter to inspect and monitor contractor programs requiring access to intelligence sources and
methods, including Sensitive Compartmented Information.
88. Does your agency have contracts that require access to classified national security information
(CNSI), hereinafter referred to as classified contracts?
88. ()Yes 0 No
89. Is your agency one of the CSAs designated by E.O. 12829?
89. �Yes 0 No
90. If your agency issues classified contracts and is not a CSA, has it entered into an agreement with the
DoD to provide industrial security services, or in the case of the ODN1, with the CIA?
911 �Yes 0 No ONA
91. If your agency issues classified contracts, has your agency head designated a senior agency official
for the NISP?
91. �Yes 0 No ONA
92. If your agency issues classified contracts, does it provide the contractor with current security
classification guidance?
92. �Yes ONo ONA
93. Are the contractor's security requirements issued through either a specific contract clause or by a
Contract Security Classification Specification (DD-254)?
93. ()Yes 0 No ONA
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Enclosure 2
PART H: Findings of the Annual Review of Agency's Original and Derivative Classification Actions
In this section provide specific information with regard to the findings of the annual review of the agency's original and derivative classification
actions to include the volume of classified materials reviewed and the number and type of discrepancies identified.
94. Indicate the volume of classified materials reviewed during the annual review of agency's original and derivative
classification actions. (If your agency does not classify information, indicate NA.)
94. 2,614
95. Indicate the number of discrepancies found during the annual review of classification actions for each category below. For additional
information on marking, consult the ISO� marking guide.
95 (a) Over-classification: Information does not meet the standards for classification.
95 (a) 126
95 (b) Overgraded/Undergraded: Information classified at a higher/lower level than appropriate.
95 (b) 73
95 (c) Declassification: Improper or incomplete declassification instructions or no declassification instructions.
95 (c) 90
95 (d) Duration: A shorter duration of classification would be appropriate.
95 (d) 119
95 (e) Unauthorized classifier: A classification action was taken by someone not authorized to do so
95 (e) 0
95 (f) "Classified By" line: A document does not identify the OCA or derivative classifier by name and position
or by personal identifier.
,5 (f) 28
95 (g) "Reason" line: An originally classified document does not cite a reason from section 1.4 of E.O. 13526.
95 (g) 0
95(h) "Derived From" line: A document fails to cite, or cites improperly, the classification source. The line
should include type of document, date of document, subject, and office/agency of origin.
95 (h) 56
95(i) Multiple sources: A document cites "Multiple Sources" as the basis for classification, but a list of these
sources is not included on or attached to the document.
95 (i) 20
95 (i) Marking: A document lacks overall classification markings or has improper overall classification markings.
95 (j) 959
95(k) Portion Marking: The document lacks some or all of the required portion markings
95 (k) 2,227
95 (1) Instructions from a classification guide are not properly applied.
95 (1) 943
95 (m) Other: Unauthorized ORCON/NOFORN caveat .
95(m) 53
PART I: Corrective Actions
96. Describe actions that have been taken or are planned to correct identified program deficiencies, marking discrepancies, or misclassification
actions, and to deter their reoccurrence.
CIA will continue to provide year-round classification training to all original and derivative classifiers.
Efforts are underway to provide more web-based training and quick help videos which will be
particularly helpful for officers in the field. Training for new employees will also continue and course
administrators have updated the content and methods to provide a better learning experience.
CIA intends to continue development of classification guides that address current practices in all
business areas. CMCG believes that guides addressing CIA's key functions will lead to better
derivative citations, provide better on-demand guidance, and reinforce declassification decisions.
Thorough guides will also provide a strong foundation for any future automated classification
assistance tools.
Emphasis on portion marking will be a continued theme for outreach and training across the Agency.
CMCG will reinforce the fact that almost all classified documents, regardless of how broad the
dissemination, must be portion marked to ensure both proper protection and dissemination of
information. CMCG has reiterated this in all training and outreach activities, and will continue to do so
as long as necessary.
CMCG has continued to increase the number of classification experts deployed to business areas,
building on the recorded success of its pilot program in FY14. CMCG has found that Agency personnel
appreciate the in-person assistance these forward-deployed classification officers (FDC0s) provide
and that FDCOs make significant contributions to resolving the increasing number of classification
questions CMCG regularly fields.
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Enclosure 2
PART J: Best Practices
Best practices are those actions or activities that make your self-inspection program and/or CNSI program more effective or efficient. They set your
program apart through innovation or by exceeding the minimum program requirements. These are practices that may be utilized or emulated by
other agencies.
97. Describe best practices that were identified during the self-inspection.
CMCG built much of its FY15 self-inspection practices on successes developed during FY14, especially
with travel, outreach, and data analysis. CMCG took time early in the process to revise the data
collection worksheets in an effort to speed up the review process and to quickly produce data relevant to
questions from !SOO and within CMCG. This effort increased production during the process of
inspection, which resulted in a larger volume of documents reviewed.
Travel to the field and in-person interviews with officers has produced unique insights into how some of
our operational personnel interact with classification rules, tools, and training. CMCG is careful to inform
all field locations that visits are for research on how to improve CIA's classification services, and will not
lead to any punitive reaction. CMCG finds that a candid demeanor leads to candid responses. CMCG is
actively mining these responses and the statistical data to refine training, software, and outreach.
PART K: Explanatory Comments
98. Use this space to elaborate on any section of this form. If more space is needed, provide as an attachment to this form. Provide explanations for
any significant changes in trends/numbers from the previous year's report.
028. CMCG often find that the reviewed documents cannot be easily edited to fix classification errors. However, CMCG highlights systematic errors
for officers or their local classification specialists in an effort to prevent future errors.
034. Annual recertification of CIA's SAPs is conducted by ODNI. CIA responds to ODNI's annual data call to recertify its SAPS, which is a process
separate from the annual self-inspection.
061. CIA just completed a modernization effort, which affected the number of staff in OCA positions during the end of the reporting period. Many
staff moved from positions with OCA to newly created positions that do not yet have OCA. In FY16, CIA will reassess OCA roles in the new Agency
structure and use the opportunity to ensure proper training is provided.
065. The reported 93% captures the Agency population within one year. This percentage may actually be higher than reported when assessing a
two-year period.
070. CIA requires that all officers complete their derivative classifier training on an annual basis, which also serves as the annual refresher training.
095(h). This number represents the number of classified documents that failed to cite at least one correct CIA Security Classification Guide (SCG).
Of these, 33 cited a legacy SCG, 8 incorrectly cited SCGs from other agencies, and 15 had no SCG in the classification block. CMCG further found
that 751 documents failed to cite at least one correct SCG and 855 document should have cited another SCG to address all of the classified equities
in the document.
095(k). As with previous years, CMCG found the lack of portion marking to be the greatest flaw in CIA's classification practices. CMCG found that,
generally, documents intended for external readership (e.g. finished intelligence, disseminated human intelligence reporting, interagency memos,
etc.) are portion marked and correctly, but documents intended for limited readership (e.g. emails, cables, spreadsheets, etc.) are not portion marked
at all. The lack of portion marking is a problem with cable traffic moreso than other products. Changes to our cable preparation system will be
considered as a means to solve this systematic issue.
095(I). This number represents the number of documents that 1) met the criteria for classification; 2) were marked as classified; 3) were classified at
the correct level; and 4) had cited at least one correct CIA SCG, but were found to be missing other reasonable CIA SCGs.
For ISOO USE Only
ISOO Analyst:
Date QC:
Analyst Initials:
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