Ensure their ongoing suitability (for clearance holders)
Your organisation must consider personnel security throughout a national security clearance holder’s employment. While recruitment and departure processes offer clear opportunities to manage the risks associated with a clearance holder, the most challenging and critical stage of the personnel security lifecycle is managing the clearance holder throughout their employment.
Summary of your responsibilities
Your organisation must help clearance holders meet their responsibilities and ensure they remain suitable to hold a clearance. To meet these responsibilities:
- Publish clear communications about security
- Provide security awareness training and updates
- Conduct security briefings when necessary
- Prepare clearance holders for any international travel
- Ensure clearance holders report changes in their personal circumstances
- Ensure clearance holders report any suspicious contacts and behaviour
- Report any change in a clearance holder’s personal circumstances
- Report and respond to security incidents, including suspicious contacts
- Manage emergency access to classified information, assets, and work locations
- Report changes to a clearance holder’s security clearance level
- Regularly review clearances and check for changes in personal circumstances.
Publish clear communications about security
Your organisation must ensure clearance holders have access to clear policies and procedures that:
- explain your security requirements
- outline all legal, regulatory, and compliance requirements.
Provide security awareness training and updates
You can help a clearance holder meet their responsibilities by providing security awareness updates and training. Training should take place at least once a year.
Conduct security briefings when necessary
You should conduct additional security briefings or debriefings with clearance holders when appropriate.
For more information about security briefings, see: Set the right expectations
Prepare clearance holders for international travel
When clearance holders travel overseas for work or personal reasons, they risk being targeted by foreign intelligence services with the capability and intent to target New Zealand interests.
Clearance holders may be of interest to foreign intelligence services for several reasons, including New Zealand’s:
- position on international issues and agreements such as trade
- strategic perspective and intentions on domestic policies
- innovations in science and technology
- agriculture, primary industries, and other sectors that attract significant interest from foreign investors
- defence and intelligence capabilities.
Remember that your clearance holders could be exposed to the same risks in New Zealand at conferences or while hosting international delegations.
Your organisation is responsible for managing any risks with international travel and ensuring that you give travel briefings for work-related trips.
To help prepare clearance holders for travel, make sure they read the following guide: Advice for New Zealand Government officials travelling overseas for business
When to report clearance holders international travel plans
If a clearance holder holds Sensitive Compartmented Information (SCI) briefings, they’ll need additional approval to travel to specified countries.
For further advice contact: email@example.com
Ensure clearance holders report significant changes in personal circumstances
Make sure your organisations clearance holders report any significant change in their personal circumstances, so you can check whether it affects their trustworthiness and their ability to retain a clearance.
For further guidance on assessing a clearance holder’s continued suitability if a security incident, change in personal circumstance, or HR issue is reported, refer to the following guidance: Assessing and acting on changes in a clearance holder’s circumstances.
What ‘significant change’ means
The following changes in a clearance holder’s circumstances are significant and must be reported to your organisation’s chief security officer (CSO).
- Starting or ending a close personal relationship
- Living in or visiting foreign countries
- Relatives living in foreign countries of security significance
- Changes in citizenship or nationality
- Changes in financial circumstances (for example, significant increases in wealth or debt)
- Changes in health or medical circumstances (for example, a serious medical condition could change a clearance holder’s behaviour or cause financial difficulties, and prescription drugs can affect people’s judgement)
- Involvement in criminal activity
- Involvement with any individual, group, society or organisation that may be of security concern
- Disciplinary procedures or security incidents
- Any other changes in circumstance that may be of concern to your organisation.
Reporting significant changes to your CSO
Your clearance holders must immediately report any significant change in their personal circumstances to your CSO and to their manager (when relevant). This reporting requirement helps to mitigate any possible conflicts of interest.
If your CSO is unsure whether a change in personal circumstances has significant implications for the holder’s clearance, they should seek advice.
For advice, contact: firstname.lastname@example.org
If other people in your organisation become aware of a significant change in a clearance holder’s circumstances — a change that may affect their suitability to retain a clearance or uphold your organisation’s security standards — they should report the change to your CSO.
Recognising and assessing a significant change in circumstance
When you know about a change in circumstance early on, it usually makes it easier to deal with the issue and prevent it from becoming a security concern. You can then reduce the risks to the clearance holder and your organisation.
What to do when your organisation is aware of a significant change
When a significant change in circumstance is identified or reported, your organisation must conduct a risk assessment based on whether the clearance holder can continue to hold a clearance. If you have doubts about continuing the clearance, your organisation should suspend or cancel it until the risk is mitigated or assessed as no longer present.
When your organisation must notify the NZSIS of a significant change
When a change in circumstance is considered significant or likely to present a risk to national security, your organisation must notify NZSIS vetting.
The NZSIS may consider it necessary for your organisation to submit a new vetting request for the clearance holder. If the NZSIS is satisfied that the clearance holder remains suitable to retain a clearance, then it will make a positive recommendation. The risk management advice may include specific measures your organisation must take.
Ensure clearance holders report suspicious contacts
A clearance holder must report any suspicious contacts or requests to access your organisation’s classified information, assets, or work locations to their CSO.
Instances of suspicious contacts or requests include, but are not limited to, contact with:
- foreign officials and foreign nationals
- criminal groups or people
- other suspicious people.
Completing a suspicious contact report
Your clearance holders should complete a contact report when an official or social contact appears suspicious, ongoing, persistent, or unusual (SOUP) in any respect. This contact could be with:
- embassy or foreign government officials within New Zealand
- foreign officials or nationals outside New Zealand, including trade or business representatives
- any individual or group, regardless of nationality, that seeks to obtain official or commercially sensitive information that they do not have a valid ‘need-to-know’.
Assessing a suspicious contact report
Your organisation should assess all suspicious contact reports to work out whether you need to:
- collect contact reports from other concerned people, and assess those reports
- advise the NZSIS of contacts that may have national security implications
- do an internal investigation (see Reporting incidents and conducting security investigations)
- contact the NZ Police (see below).
Sometimes a clearance holder’s suspicious contacts may be of a criminal or business nature that involves a conflict of interest or gives a potential unfair advantage. Your organisation should have a clear process to investigate these contacts and, if appropriate, notify appropriate authorities for further investigation (for example, NZ Police, Serious Fraud Office).
Manage emergency access to classified information, assets, and work locations
For information on managing emergency access, go to: Manage their security clearance
Report changes to a clearance holder’s security clearance level
For information on reporting changes, go to: Manage their security clearance
Regularly review clearances and check for changes in personal circumstances
While the vetting process for a clearance gives your organisation a certain level of assurance about a person’s suitability to hold a clearance, that assurance only applies to the time when vetting took place — it doesn’t guarantee future suitability. For that reason, if you’re the organisation sponsoring the clearance, you need to:
- review all security clearances to ensure you maintain the necessary level of assurance
- check regularly to see if your clearance holders’ circumstances have changed.
To support your organisation manage the ongoing suitability of national security clearance holders, annual security appraisal forms (ASAF) are available.
ASAF for national security clearance holders – Send this form to clearance holders to complete upon their anniversary or a date determined by the organisation.
ASAF for managers of national security clearance holders – Send this form to line managers to complete upon receiving a completed form from the national security clearance holder.
ASAF for security teams or chief security officer –This form is for security teams to use to review both the completed forms above. Use it to assess any concerns, or identify the need to implement management plans for clearance holders.
Use these forms in their editable PDF version or use word versions to adapt to your organisations’ requirements.
If your organisation no longer has the necessary assurance, remember that you can review, suspend, cancel, or withdraw a clearance at any stage.
Page last modified: 5/06/2020