Changes to the personnel security screening process: Phase 1

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.

Find information regarding changes to the organization security screening process: Phase 2.

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.

Changes to the personnel security screening process

The first phase was implemented on October 4, 2021. Its purpose was to give you enough time to review the updated communications products and guidance. This allowed you to implement the necessary changes in your organization.

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

• require access to protected or classified information, assets or sites to perform work on an active contract, subcontract or lease
• require access to protected or classified information, assets or sites during the pre-solicitation stage of a procurement process
• have been identified as a resource in a bid submission and are required to hold the necessary personnel screening at contract award
• are involved in a multinational program

In this section

• Benefits of this change to private sector organizations
• Change applies to all personnel security screening requests
• Federal procurement process is aligned with this change
• Flexibility within the Contract Security Program
• Guidance on justifying the personnel security screening requirement
• Using active contracts to request personnel screenings for an upcoming contract
• Contract to reference if your organization needs to hire someone to work on several active contracts with security requirements
• Validity period of personnel security screenings
• Organization security screening process
• Subcontracting process
• Required copies of all awarded subcontracts with security requirements
• Organizations with an active contract without any record in the Contract Security Program database
• Canadian suppliers bidding on foreign contracts
• Improving security screening timelines

Benefits of this change to private sector organizations

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 and requests for supply arrangements
• underrepresented organizations

Guidance on justifying the personnel security screening requirement

CSOs and alternate company security officers (ACSO) must provide a justification for the security screening requirement in their personnel screening requests using 1 of 3 justification types.

You can also refer to how to complete the Personnel screening, consent and authorization form (TBS/SCT 330-23E) for detailed guidance on completing the form.

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 justifications 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).

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.

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.

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:

• for subcontracts awarded to a Canadian supplier: tpsgc.ssicontrats-isscontracts.pwgsc@tpsgc-pwgsc.gc.ca
• for subcontracts awarded to a foreign supplier: tpsgc.dgsssiprojetintl-dobissintlproject.pwgsc@tpsgc-pwgsc.gc.ca

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.

Canadian suppliers bidding on foreign contracts

There will be no impact on Canadian suppliers bidding on foreign contracts with international and North Atlantic Treaty Organization (NATO) security requirements. 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.