Phase 1 of changes to the security screening process

The Contract Security Program (CSP) has implemented the changes in phases to support government clients and stakeholders in adjusting their internal procurement policies, practices and procedures. The first phase was implemented on October 4, 2021, to give you enough time to review the updated communications products and guidance prior to implementing any necessary changes in your organization.

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Background

Changing the eligibility criteria for personnel security screening

An analysis of the CSP processing volumes revealed that more than 80% of private sector personnel screened over the last 5 years have not been associated with a contract or subcontract with security requirements. The processing of personnel security screening requests, irrespective of whether or not they were supported by a valid contractual requirement, has meant that those with a legitimate need for security screening have had to wait longer than needed.

As such, to enhance important security services and advance the Procurement Modernization agenda, Public Services and Procurement Canada (PSPC) implemented changes to its CSP’s security screening process in phases, starting with the eligibility criteria for personnel security screening on October 4, 2021.

Change that came into effect on October 4, 2021

As of October 4, 2021, personnel security screenings are conducted for individuals who:

Benefits of this change to private sector organizations like mine

By refocussing personnel security screening activities on individuals with a valid security requirement, the expected benefits are:

  • faster processing of personnel security screenings
  • better support to industry in the delivery of important services and activities for the benefit of Canadians
  • reduced burden on industry, particularly on company security officers (CSOs) and alternates
  • improved timelines for active and emergency procurements

Change applies to all personnel security screening requests

This change applies to all new requests, including to update, upgrade, reactivate, transfer and duplicate security screenings received on or after October 4, 2021. Requests received prior to October 4, 2021 have remained in the queue to be processed.

Federal procurement process is aligned with this change

This change applies to all federal procurements for goods, services and construction.

PSPC contracting officers that award contracts on behalf of other government departments will no longer require bidders to hold the necessary security clearances at the date of bid closing in the bid solicitation documents. Instead, bidders will have until the date of the contract award to obtain the necessary security clearances. This approach is already available in PSPC’s Standard Templates for PSPC contracting officers.

Flexibility within the Contract Security Program

The CSP will, until further notice, continue to accept personnel security screening requests in anticipation of a future requirement from:

  • organizations who are required to hold the necessary personnel security screening at bid closing
    • for non-PSPC issued contracts
    • for requests for standing offers (RFSOs) and requests for supply arrangements (RFSAs)
  • underrepresented organizations

General instructions on how to justify the security screening requirement

CSOs and alternate company security officer (ACSOs) are required to justify the security requirement in their personnel screening requests using a list of 12 acceptable scenarios and corresponding justifications.

Justification for security screening requirement

The justification for security screening requirement field in section A of the Personnel screening, consent and authorization form (TBS/SCT 330-23E) is mandatory for all requests in order to establish the need to know of the individual and must include the following elements, as applicable:

  • Scenario number (must be provided for all requests)
    • select 1 scenario number from the list below
      • for example, if your request falls under the second scenario, write/type “Scenario 2”
  • Name of department or agency (must be provided when selecting scenario 1 and scenarios 6 through 12)
    • write/type the name of your government client department or agency
      • this is the department or agency your organization is / will be delivering goods or services to

      Tip: on CanadaBuys tenders, the client department or agency is referred to as the end user entity.

  • Brief description of the work (must be provided when selecting scenarios 1, 2, 4, 5 and 12)
    • write/type a brief description of the work the individual will be performing on the contract, subcontract or lease (a job title is not sufficient)

      Tip: limit the use of acronyms.

Position/competition/contract number

This field is mandatory for all requests, except when selecting scenarios 3, 6 and 7.

If you have selected scenario 1, 2, 4, 5, 8, 9, 10, 11 or 12, refer to the list of scenarios to determine which number you must provide

Note

The “position/competition/contract number” field is not available in the online industrial security services (OLISS). If your organization is completing the form using OLISS, please provide the applicable tender, request for proposal (RFP), standing offer (SO), supply arrangement (SA), contract, subcontract or lease number related to the scenario you choose under the “Justification for request” field instead.

Refer to the examples included in the list of scenarios to ensure you are providing the right information and level of detail. The examples provided below are made up scenarios and for reference purposes only.

Scenarios that are accepted as justification to process personnel security screening requests

The following is a list of examples of valid security requirements that CSOs and alternates can reference in their personnel security screening requests.

Scenario 1

A request specifically related to an active tender that requires the bidder (for example, the organization preparing the bid submission) to identify the name of their proposed resources in their bid submission and hold security screenings for these at the date of contract award.

  • Justification of security screening requirement
    • scenario number
    • brief description of the work to be performed
    • government department/agency name
    • RFP, tender or solicitation number (for OLISS requests only)
  • Position/competition/contract number (for manual requests only)
    • RFP, tender or solicitation number
  • Examples of a complete justification
    • scenario 1 –  individual to perform forensic accounting activities for an upcoming Canada Revenue Agency (CRA) contract
      • tender number – 123-4567
    • scenario 1 – individual to produce an annual report on government spending for the Privy Council Office
      • tender number – 123-4567

Scenario 2

Work performed on an active contract, subcontract or lease with security requirements.

  • Justification of security screening requirement
    • scenario number
    • brief description of the work being performed
      • for any trade related duties, include a work site location
    • contract, subcontract or lease number (for OLISS requests only)
  • Position/competition/contract number (for manual requests only)
    • contract, subcontract or lease number
  • Examples of a complete justification
    • scenario 2 – electrician for Department of National Defence (DND) to renovate guard house at Canadian Forces Base Winnipeg
      • subcontract number – 123-4567
    • scenario 2 – individual to map out processes, concept of operations, and service level agreements
      • contract number – 123-4567

Scenario 3

A security screening request for a key senior official (KSO), CSO or ACSO.

  • Justification of security screening requirement
    • scenario number
    • individual’s security role (KSO, CSO or ACSO)
  • Position/competition/contract number
    • not applicable for manual and OLISS requests
  • Examples of a complete justification
    • scenario 3 – new KSO
    • scenario 3 – to be appointed as CSO

If your organization already holds a security clearance with the CSP and needs to request a personnel screening for a new CSO or ACSO using OLISS, your organization must first submit the appropriate appointment form to the CSP by email at tpsgc.ssiinscription-issregistration.pwgsc@tpsgc-pwgsc.gc.ca. If your organization is completing the screening request manually, you must send the personnel security screening documentation for the new CSO or ACSO with the appointment form to tpsgc.ssiinscription-issregistration.pwgsc@tpsgc-pwgsc.gc.ca.

If your organization holds a facility security clearance and has a new KSO to report, your CSO or ACSO must first notify to the CSP by email at tpsgc.ssiinscription-issregistration.pwgsc@tpsgc-pwgsc.gc.ca prior to requesting a personnel screening for the individual in OLISS. If your organization is completing the screening request manually, your CSO or ACSO must include the personnel security screening documentation for the new KSO in their email notification to tpsgc.ssiinscription-issregistration.pwgsc@tpsgc-pwgsc.gc.ca.
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Scenario 4

A request specifically related to a document safeguarding capability. For example, the employee needs the security status or clearance to gain access to the operation or security zone.

  • Justification of security screening requirement
    • scenario number
    • brief description of the work being performed
    • contract, subcontract or lease number (if applicable, for OLISS requests only)
  • Position/competition/contract number (if applicable, for manual requests only)
    • contract, subcontract or lease number
  • Examples of a complete justification
    • scenario 4 – person will be reviewing secret drawings in the security zone for DND
      • contract – 123-4567
    • scenario 4 – this employee is a mail clerk who sorts/delivers correspondence who needs a clearance to gain access to the operation and security zones

Scenario 5

A request specifically related to a SO or SA with security requirements.

  • Justification of security screening requirement
    • scenario number
    • brief description of the work to be performed
    • SO/SA number (for OLISS requests only)
  • Position/competition/contract number (for manual requests only)
    • SO/SA number
  • Examples of a complete justification
    • scenario 5 – providing onsite security guard services in secured Government buildings
      • MSO 1234567
    • scenario 5 – individual will be an IT software specialist for DND
      • SA#12345-6789012/001/DL

Scenario 6

A letter of interest requiring a status or clearance.

  • Justification of security screening requirement
    • scenario number
    • generic information on subject matter
    • government department/agency name
  • Position/competition/contract number
    • not applicable for manual and OLISS requests
  • Example of a complete justification
    • scenario 6 – responding to a letter of interest where we will require access to Protected B information regarding the development of a new software application for Canada Border Services Agency (CBSA)

Scenario 7

Industry engagement where protected/classified information is shared.

  • Justification of security screening requirement
    • scenario number
    • generic information on session
    • date of session
    • government department/agency name
  • Position/competition/contract number
    • not applicable for manual and OLISS requests
  • Example of a complete justification
    • scenario 7 – engagement session led by DND in April 2022 regarding upcoming military procurements
      • classified information will be discussed at the session and will require Secret clearance from participants

Scenario 8

A classified meeting/industry engagement in the context of the establishment of a procurement process, such as a bidders’ conference.

  • Justification of security screening requirement
    • scenario number
    • generic information on activity
    • government department/agency name
    • solicitation number (if available, for OLISS requests only)
  • Position/competition/contract number (if available for manual requests only)
    • solicitation number
  • Examples of a complete justification
    • scenario 8 – participate in bidder’s conference led by CRA to discuss requirements for upcoming contract on Cloud Services
      • solicitation number – 123-4567
    • scenario 8 – individual will be accessing Airforce Base for procurement process related to DND maintenance and storage facilities upgrades for new military aircraft

Scenario 9

A request for information where protected/classified information is shared.

  • Justification of security screening requirement
    • scenario number
    • generic information on subject matter
    • government department/agency name
    • reference or tender number (for OLISS requests only)
  • Position/competition/contract number (for manual requests only)
    • reference or tender number
  • Example of a complete justification
    • scenario 9 – request for information related to high security building construction for DND where blueprints will be shared
      • tender number – 123-4567

Scenario 10

An invitation to qualify with protected/classified information shared.

  • Justification of security screening requirement
    • scenario number
    • generic information on subject matter
    • government department/agency name
    • reference or tender number (for OLISS requests only)
  • Position/competition/contract number (for manual requests only)
    • reference or tender number
  • Examples of a complete justification
    • scenario 10 – employee is participating in the review and sharing of protected/classified information pertaining to technical capabilities required for a potential contract with DND
      • tender number – 123-4567
    • scenario 10 – individual is part of the bid team and will be required to review protected information provided by Canadian Security Intelligence Service
      • reference number – 1234567

Scenario 11

A RFP with protected/classified information shared.

  • Justification of security screening requirement
    • scenario number
    • role in RFP process
    • government department/agency name
    • RFP number (for OLISS requests only)
  • Position/competition/contract number (for manual requests only)
    • RFP number
  • Examples of a complete justification
    • scenario 11 – project manager required to review protected information
      • PSPC-RFP – 123-4567
    • scenario 11 – architect involved in technical specifications for protected bid submission related to PSPC-RFP 123-4567

Scenario 12

A non-PSPC managed tender that requires personnel screening at time of bid closing.

  • Justification of security screening requirement
    • scenario number
    • brief description of the work to be performed
    • government department/agency name
    • tender number (for OLISS requests only)
  • Position/competition/contract number (for manual requests only)
    • tender number
  • Examples of a complete justification
    • scenario 12 – individual will be retrofitting a secured office space
      • Environment and Climate Change Canada managed tender number – 123-4567
    • scenario 12 – cleaner will be responsible for maintaining various secured buildings
      • CBSA managed tender number – 123-4567

Using active contracts to request personnel screenings for an upcoming contract

You cannot use one of your active contracts to request personnel screenings for an upcoming contract. Organizations can only submit personnel screenings requests that fall under the list of acceptable scenarios provided by the CSP.

Contract to reference if your organization needs to hire someone to work on several active contracts with security requirements

The CSO or ACSO must reference the contract or subcontract that the employee will be primarily assigned to. For example, if the employee will be allocating 25% of their time to Contract A and 75% of their time to Contract B, the CSO or ACSO must reference Contract B in section A of the Personnel screening, consent and authorization form (TBS/SCT 330-23E).

Changes affecting the validity period of personnel security screenings

These changes will not affect the validity period of personnel security screenings. Personnel security screenings conducted before and after October 4, 2021 will continue to be valid per the date indicated on the individual’s Security screening certificate and briefing form (TBS/SCT 330-47E). Organizations are reminded of their responsibility to terminate personnel screenings that are no longer required and to perform aftercare on existing screenings.

Changes affecting the organization security screening process

These changes will not affect the organization security screening process. Changes to the organization security screening processes will be implemented at a later date.

Changes affecting the subcontracting process

These changes will not affect the subcontracting process. The CSP will continue to perform the necessary personnel security screenings on legitimate subcontractor resources with a valid security requirement to assist the prime contractor or lessor in delivering its contractual obligations. The CSP has also undertaken a review of its subcontracting process to explore ideas toward a simpler and more flexible process for prime and subcontractors alike. Information about the new and improved subcontracting process will be forthcoming. Until then, it is status quo.

Required copies of all awarded subcontracts with security requirements

The CSP continues to require copies of all awarded subcontracts and subcontract amendments with security requirements to ensure the timely and efficient delivery of personnel security screening services to subcontractors.

Prime contractors must send a copy of their subcontracts to the CSP, including copies of any subcontract amendments:

Organizations with an active contract without any record in the Contract Security Program database

It is the responsibility of the contracting department to provide the CSP with a copy of the contract or lease, including any amendments. Organizations that award subcontracts with security requirements to other organizations are responsible for providing copies of their subcontracts to the CSP.

In the case of contracts and subcontracts awarded to Canadian organizations by foreign governments, international organizations or foreign suppliers, the Canadian organization is responsible for providing a copy of the contract or subcontract to the CSP, including amendments.

Occasionally, the CSP does not receive a copy of the awarded contract, subcontract or lease. There can also be delays in entering the contractual information in the CSP database. If you have a copy of your contract, subcontract or lease you can provide it to the CSP at tpsgc.ssicontrats-isscontracts.pwgsc@tpsgc-pwgsc.gc.ca.

Impact on Canadian suppliers bidding on foreign contracts with international and NATO security requirements

There will be no impact. Canadian suppliers bidding on foreign contracts involving foreign or NATO classified information must continue to liaise with the CSP to ensure the foreign solicitation or contract is within the scope of the CSP and its international commitments.

Upon request from a foreign government partner, the CSP will continue to validate and update the Canadian supplier’s personnel security screenings, or initiate new ones, if the foreign government department or Canadian supplier can demonstrate that the requirement for a personnel security screening is associated to a legitimate procurement activity. In their justification, the foreign government department or Canadian supplier must provide a valid contract or solicitation number or details on the multinational program.

Improving security screening timelines

By implementing a more targeted approach to personnel security screenings, the CSP expects the following improvement in processing times for simple personnel security screening requests.

  • Reliability status
    • current: 7 business days, 85% of the time
    • target: 4 business days, 85% of the time
  • Secret clearance
    • current: 75 business days, 80% of the time
    • target: 35 business days, 80% of the time

These shorter processing times are not new service standards; they are targets set by the CSP, based on projections, to measure its performance. As the CSP implements the changes, it will monitor performance and adjust service standards accordingly.

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