The following procedure applies to all personnel who possess a U.S. Government security clearance under University of Alabama at Birmingham sponsorship (also known as Key Management Personnel).
The significance of a security incident does not depend upon whether information was actually compromised. It depends upon the intentions and attitudes of the individual who committed the violation. Ability and willingness to follow the rules for protection of classified information is a prerequisite for maintaining a security clearance. Although accidental and infrequent infractions or minor violations are to be expected, deliberate or repeated failure to follow the rules is definitely not. It may be a symptom of underlying attitudes, emotional, or personality problems that are a serious security concern.
The following behaviors are of particular concern and may affect your security clearance:
A pattern of routine security violations due to inattention, carelessness, or a cynical attitude toward security discipline.
Taking classified information home, ostensibly to work on it at home, or carrying it while in a travel status without proper authorization.
Prying into projects or activities for which the person does not have (or no longer has) a need to know. This includes requests for classified publications from reference libraries without a valid need to know, or any attempt to gain unauthorized access to computer systems, information, or databases.
Intoxication while carrying classified materials or that causes one to speak inappropriately about classified matters or to unauthorized persons.
Deliberate revelation of classified information to unauthorized persons to impress them with one's self-importance.
Copying classified information in a manner designed to obscure classification markings. This may indicate intent to misuse classified information.
Making unauthorized or excessive copies of classified material. Going to another office to copy classified material when copier equipment is available in one’s own work area is a potential indicator of unauthorized copies being made.
Failing to report requests for classified information from unauthorized individuals.
B. Security infraction – A security incident that, in the judgment of the UCO/FSO, does not result in actual or possible compromise of the information. For example, at the end of the workday, an employee fails to record the closing of a security container or vault door on the SF-702 log sheet. Infractions are more administrative in nature, but are required to be documented to deter patterns of neglect or disregard for security procedure.
C. Security violation – A security incident that, in the judgment of UCO/FSO, could result in the actual or possible compromise of the information. For example, not securing a security container or vault door at the end of the workday or when there are no cleared personnel present.
E. Collateral security clearance - A security clearance with no special access authorizations, e.g. SCI or SAP. Top Secret, Secret, and Confidential are collateral security clearances.
The FSO, or her/his designee, is responsible for conducting security inspections of those facilities or areas that are utilized to store, process, or work with classified information, materials or equipment. Inspections will be conducted on a routine basis; however, they can also be conducted on an unannounced basis depending upon the situation. A facility or area that is prone to security violations may be inspected on a more frequent basis.
Failure to report a security violation is itself a security violation and may be a very serious concern. Upon the discovery or report of a security incident, the UCO/FSO will open a file on the incident, start an investigation, and initiate the UCO/FSO Record of Incident form.
The UCO/FSO, or her/his designee, will conduct an investigation of the reported security incident that will include, but not be limited to, personal interviews of person or persons involved, site visitation where the security incident occurred and the gathering of any additional information that pertains to the security incident investigation. All information will become part of the security incident file that will be kept in the UCO/FSO facility. The individual suspected of the incident will also be able to make a statement that is a part of the Record of Incident form.
The security incident will be adjudicated by the FSO utilizing only the information that is obtained from the incident investigation and that is documented. After the incident is adjudicated a final report will be written and forwarded along with all investigative documentation to the University Compliance Officer (UCO) for review. After review and approval by the UCO the individual(s) involved will be informed in writing of the findings.
All records associated with a security incident investigation will be kept in the office of the FSO. All records are open to those personnel directly involved in the security incident; however, they cannot be removed or copied.
As stated previously, infractions are more administrative in nature. You can be issued an infraction for leaving classified material out on your desk even if you are in a vaulted area that is approved for classified materials and there is a 24/7 monitored and approved alarm system which was operational and in use when the material was left out on the desk.