Since the National Industrial Security Program Operating Manual (NISPOM) requires that the Facility Security Officer (FSO) be an employee, consultants and independent contractors may not serve as Facility Security Officers (FSO). This prohibition against consultants serving as Facility Security Officers is in clause 1-201 of the NISPOM. To have a consultant or independent contractor serve as your Facility Security Officer (FSO) would likely result in your organization being penalized for that violation during a Defense Counterintelligence and Security Agency (formerly known as the Defense Security Service) inspection of your security program. Also beware of consultants offering to manage your employees’ security clearances in the JPAS or DISS Web sites. For them to perform that work remotely puts your organization at risk of violating the DMDC’s official JPAS and DISS Account Management policies.
Thus, the approach we use to support your security program is carefully tailored to meet both your needs and the government’s FSO and JPAS/DISS requirements. To discuss your specific FSO or consulting needs and develop an arrangement that is both effective and appropriate, please contact us.