LETTER TO MR. STEVEN GARFINKEL FROM(Sanitized)

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP84B00890R000600140030-6
• Release Decision: RIPPUB
• Original Classification: K
• Document Page Count: 17
• Document Creation Date: December 16, 2016
• Document Release Date: July 21, 2005
• Sequence Number: 30
• Publication Date: October 22, 1981
• Content Type: LETTER

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fir. Steven Garfinkel
Director, Information Security
Oversight Office (7..)
General Services Administration
18th $ F Streets, N.W.
Washington)l D.C. 20405
Dear A7rankel:
14AM-degistry
cis RegIStly l
22 OCT 1981
Lu LEI u~L1
J Ll
Forwarded herewith is our fiscal year 1981 Agency Information. Security
Program Data (SF 311) report.
As was done last year, the statistics on classification decisions in
sections 7A-C of the report were obtained from an actual count over a
seven-day period (19-25 September) and projected to cover the reporting period.
Sincerely,
Director of Information Services
Directorate of Administration
Enclosure
DDA/OIS/FMD/RSB.
(19 October 1981)
Distribution:
Original-Addressee
.1-OIS Subject
1-OIS Chrono
1-RSB Subject: Reports to ISOO
1-RSB Chrono
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Continuation Sheet of SF 311
13. Narrative Report
A. DECLASSIFICATION. Describe actions to declassify information under
the systematic review procedures of the Order. Include discussion of
problem areas and give estimated date for transition to systematic review
of material as it reaches its 20th anniversary of origin.
The Classificiation Review Division (CRD) of our Office of Information
Services is responsible for the systematic review of Agency permanent records
over 20 years old. It is composed of officers from throughout the Agency
whose background and experience qualify them to make the necessary classification
judgments. Coordination with originating or responsible components is
available on those infrequent occasions when it is necessary. Over the past
year CRD has increased overall production by 5%, even though we have lost
the services of several reviewing officers. The requirement for our
classification review work on Agency-wide priorities other than 20-year
systematic review has increased measurably. Although the demand for CRD's
services is high, the productivity of those officers working on declassification
has been upgraded through increased clerical support and refinement of a number
of internal procedures. The review procedures CRD negotiated with other
agencies for two groups of interdepartmental records have been used as a
basis for further agreements on review of other interagency material. As a
priority matter, CRD continues to explore various methods of reviewing the
large quantity of records stored in non-paper form (film, microforms, ADP
media, etc.). However, shortage of qualified personnel, lack of required
office space and other resources for the expansion of the staff, and limited
vault and storage space in which to keep a. backlog of work readily at hand
remain as problems. Completion of 30-350 of the material necessary to make
the transition to 20-year review by 1988 now seems likely; we will
continue our efforts to complete the transition in compliance with the
Executive order.
B. TRAINING. Describe all major actions relating to information security
education and training, including special efforts toward limiting the.
amount, level, and duration of classified material generated, and
increasing public access to information declassified.
During this reporting period, the Office of Training and Education (OTH)
continued to familiarize Agency personnel with xecu'tive?Order?12065. In
regularly scheduled training courses, special seminars, and discussion groups,
OTE has addressed large numbers of employees at all grade levels-on their
responsibility to adhere to the Agency Information Security Program Handbook
and associated guides.
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Although emphasis has been placed on the originator's responsIhlity to
properly classify infor mat:ion, our records management courses have also
addressed the entire life cycle of records to include creation, use,
maintenance, and destruction of Agency records. Special efforts 1iave been
made to make the employee aware Mat the benefits derived from limiting the
amount of material created include a -reduction in the effort and cost of
maintaining and destroying classified information.
In addition, the Security Education Group of our Office of Security (OS)
addresses a wide variety of audiences in performance of its mission. Th.e
spectrum ranges from new employees entering on duty to senior Agency personnel
who have worked with classified information for many years. Regardless of
the type of audience, the Security Education Group regularly emphasizes the
employees' responsibility with respect to classified information. All
audiences are invited to raise questions in the areas of classification,
declassification, and storage of classified material.
The National Archives and Records Service (NABS) has already accessioned
some Agency records, and others are under consideration. NARS was given
printouts of a record group of finished intelligence from CRD's UP system
indicating the review decisions that were taken. Rost of the material was
declassified. This enabled NARS to take the indicated action on its own
copies, thus. making the information available to the public. In addition,
we continue to schedule teams of review officers to visit NARS and the
Washington National Records Center one day each week to review material of
CIA interest found in records of other agencies. Some of this material is
declassified and, therefore, becomes available to the public.
C. SAFEGUARDS. Describe actions to enhance safeguards, to include
control 6F reproduction, reduction of classified holdings, and improved
methods of destruction.
The Physical Security Division of OS enforces the safeguards required
by Executive Order 12065 and the implementing directives through a program of
.physical.security surveys, inspections, and audits. There are approximately
750 separate elements which are subject'to this program. These elements
include Agency Headquarters components, domestic facilities, foreign
facilities, and contractor facilities. This program is administered through
the use of approximately 24 professional officers with appropriate supervision.
The program centers around establishing physical security program standards
and procedural standards and the enforcement of these standards through
surveys, inspections, and audits.
D. BALANCING TEST. Describe extent of use of the balancing test
(E.O. 12065Section 3-303) and impact.on_Agency mission-.
The balancing test, in the context,-of.. litigation to. which this ARency is a
party, imposes no significant burden. Some Freedom of Information Act
plaintiffs have argued that the balancing test under Section 3-303 of
Executive Order 12065 is mandatory and that all classification review decisions
must include balancing by the appropriate Agency official. However, most
courts have rejected this argument and have held the balancing test to be
discretionary.
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1:. PROGRAM MANAGLM N '. Describe major problems encountered in
implementing I.O. 12065 and ISOO directives.
As reflected in paragraph 13C, the implementation.of. the Agency physical
security program requires a substantial dedication of mannower. Eowever,
because of the nature of the Agency mission, the sensitivity of the information
with which the Agency deals, and our charter to protect intelligence sources
and methods, the. implementation of Executive~Order 12065 has not required a
measure of physical protection over and above that already in existence.
Our most significant probl..em with implementation of F.O. 1.2065 continues
to be the potential damage to the national security posed by the declassification
of intelligence records, many of which by themselves may seem harmless but
when considered in the aggregate could cause significant harm. ?'oually
.significant are the staffing and logistical problems mentioned in na.ra.graph 13A
above. Further, the systematic review of the Agency's non-paper holdings
will be a major FY 1982 undertaking. We have just this year formed sore
guidelines for review of non-paper material. The evolving mechanism for
review of interdepartmental material will require futher adjustment. Finally,
the demand for classification review work on other Agency documents is running
quite high and will require continued attention and use of our assets.
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ROUTING AND TRANSMITTAL Sup Date
26 March 1981
To: (Name, CIVICS symbol, room number, a ~~S ~ut_ SP,
building. Agency/post) Initials Date
1. EO/DDA 5wr
ment
Coordination
REMARKS
2
Director,
Information Services
S?
1206 Ames
Bldg.
n
Fife
Note and Return
oval
-
For Clearance.
Per Conversation
fs
equested.
Correction
Prepare Reply
late
For Your Information
See Me
Investigate
Signature
Justify
3 - Action
Pls note 31 October deadline.
DO NOT use this form as a RECORD of approvals, concurrences, disposals,
STAT
Room No.-Bldg.
FROM: (Name, org. symbol, Agency/Post)
D-18 Hqs.
*U. S. GPO: 1978-0-261-647 %3354
OPTIONAL FORM 41 (Rev. 7-76)
Prescribed by GSA
FPMR (41 CFR) 101-11.206
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 ase 2005(Iat-Ab00899&00600140030-6
s Oversigh
{
4/ -Ol~~p
Administration Office Washington, DC 20405
;A, 13ai
Jai
I
Deputy irec inistration
Central Intelligence Agency
Washington, DC 20505
D
The purpose of this letter is to announce that Standard Form 311, Agency Information
Security Program Data (2/1981) will be in effect through the end of FY 1983. We are in
the process of having copies of the form printed. We will notify you of the particulars
concerning its availability as soon as possible. In order to provide reporting agencies
with as much lead time as possible to familiarize themselves with the form, we enclose a
copy of the draft.
The draft SF 311 (2/1981) includes the same categories of information appearing on
SF 311 (10/1979) for FY 1980; some items of information have been rearranged, however,
to facilitate ease of completion. Instructions concerning completion of SF 311 (2/1981)
continue to appear on the reverse of the form. A completed copy of the form which
pertains to FY 1981 actions is due in the ISOO no later than October 31;-1981. Unless
superseded by later instruction, copies pertaining to FY 1982 and FY 1983 activities are
due by October 31, 1982 and October 31, 1983, respectively.
I wish to emphasize that completion of all items listed on the form, including the
narrative section, is mandatory. ISOO analyzes and utilizes this information in preparing
its Annual Progress Report to the President. Therefore, it is essential that the answers
be complete and provide meaningful data.
If you have any questions concerning this reporting requirement, please contact me or
your ISOO liaison at 633-6880.
Sincerely,
STEVEN GARFIN'KEL
Director
Enclosure (1)
On file GSA Release Instructions apply.
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 SECURITY;PROGRAM DATA
AG Eft'R QK*-fiNi a 2005/08/02: C
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NAL INFORMATIO
5. STAFF OFFICE
FORM APPROVED OMB NO. 30
9 vv...
6J140030-6 INTERAGENCY
REPORT CONTROL
7 NUMBER
I 0230-GSA-AN
N (Name and
A. TOP SECRET
B. SECRET
C. CONFIDENTIAL
D. TOTAL
ORIGINAL
7. CLASSIFICATION
DERIVATIVE
DECISIONS
0 - 6 YEARS
OVER 6 - UP TO 20 YEARS
(a)
(b)
(c)
A. TOP SECRET
B. SECRET
C. CONFIDENTIAL
CASES FOR WHICH AGENCY IS RESPONSIBLE FOR
8. MANDATORY
FINAL DECISION
TOTAL
REVIEW,
CASES
DECISION TO
CASES
CASES
CASES
UNPROC-
PAGES
REQUESTS
CARRIED
OVER FRO
NEW
C
SES
DECLASSIFY
CARRIED
O
REQUIRING
REQUIRING
ESSED
REVIEWED
AND
A
OVER T
OVER 30
OVER 60
PREVIOUS
RECEIVED
GRANTED
GRANTED
DENIED
NEXT
DAYS FOR
DAYS FOR
fEst
APPEALS
PERIOD
IN FULL
IN PART
PERIOD
ACTION
ACTION
(a)
(b)
(c)
(d)
(e)
(f)
(g)
(h)
(i)
(j)
A. REQUESTS
B. APPEALS
9. SYSTEMATIC REVIEW FOR DECLASSIFICATION
10. NUMBER OF FORMAL IN-
SPECTIONS SURVEYS OR
11. NUMBER OF TOP SECRET
DOCUMENTS IN INVENTORY
A. REVIEWED
B. DECLASSIFIED
C. EXTENDED BEYOND
PROGRAM hEVIEWS CON-
20 YEARS
DUCTED
A. OVERCLASSIFI-
B. UNDERCLASSIFICA-
C. MISAPPLICATION
D. CLASSIFICATION E. EXT. OF CLASSIFI-
F. MISMARKING
CATION
TION
OF TIME LIMITS
WITHOUT CATION WITHOUT
AUTHORITY AUTHORITY
G. IMPROPER
H. UNAUTHORIZED
1. IMPROPER
J. UNAUTHORIZED K. UNAUTHORIZED
DESTRUCTION
ACCESS
STORAGE
REPRODUCTION TRANSMISSION
IMPORTANT: Comment on each of the items listed below on a continuation sheet. Attach exhibits when required. ADDRESS ALL ITEMS. Make answers
as complete as possible.
L'. DECLASSIFICATION. Describe actions to declassify information under the systematic review procedures of the Order. Include discussion of problem areas,
andagive estimated date for transition to systematic review of material as it reaches its 20th anniversary of origin.
B. TRAINING. Describe all major actions relating to information security education and training, including special efforts toward limiting the amount, level.
and duration of classified material generated, and increasing public access to information declassified.
C. SAFEGUARDS. Describe actions to enhance safeguards, to include control of recroduction, reduction of classified holdings, and improved methods of
destruction.
E. PROGRAM MANAGEMENT. Describe major problems encountered in implementing E.O. 12065 and ISOO directives.
T RD FORM 311 (REV. 2-81)
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AGENCY INFO TION SECURITY PROGRAM DATA RE
GENERAL INSTRUCTIONS.
Each department, agency, or analogous organizational entity that creates, handles, and/or stores national security information (as
defined in E.O. 12065) must submit a report in an original and one copy. Entries must be typewritten. Consolidate reports of
component activities. Submit reports to ISOO annually, on a fiscal year basis, no later than October 31. Do not include national
security information in the reporting form; send such information to the Director, ISOO,:by separate authorized means.
11. PROCEDURAL INSTRUCTIONS. -
Item 6. Enter in appropriate columns the number of Top Secret, Secret, and Confidential original classifiers authorized as of the
end of the reporting period. Make entry only for the highest level authorized; i.e., entries for individuals with Top Secret author-
ity shall be shown 2nlY under column (a) and not under columns (b) and (c). The same applies to those with Secret classification
authority.
Item 7. Enter in columns (a) and (b) an actual count of original classification decisions generated during the reporting period by
level and duration of classification. In column (c) enter an actual count of derivative classification decisions. Do not count repro-
duction or copies of records as classification decisions. Agencies that generate a high volume of derivative classification decisions
may request authorization from the Director, ISOO, to develop sampling methods in lieu of actual count. The request must be in
writing and must include: (1) a statement as to the reasons for the request, and (2) an explanation of the sampling methods pro-
posed. Agencies must inform the ISOO,, in writing, of any revisions to the approved sampling method. Sampling methods already
approved by the ISOO will continue in effect unless they are subject to revision. As used in this report the term classifica-
tion decision" means a decision to apply classification markings (either original or derivative) to records as defined in Section
3301 of Title 44, U.S.C. (Section 3301 of Title 44, U.S.C. defines the term "records" to include "all books, papers, maps,
photographs, or other documentary materials, regardless of physical form or characteristics") Under this definition classifi-
cation decisions would include decisions recorded on any media, including microforms, magnetic recordings, computer print-
outs, etc .__ _
Item 8A. -Enter in the appropriate columns mandatory declassification review requests carried over from the previous reporting
period, new ones received, and action taken on them. The sum of the cases recorded under columns (a) and (b) must equal the
sum of cases recorded under columns (c) through (f). Enter in column (i) the number of unprocessed cases. The term "unproc-
essed cases" means those for which the agency is not responsible for final action. They include: (1) cases in which the request was
withdrawn by the requester; (2) cases returned to the requester because the request did not reasonably describe the information;
(3) cases forwarded to another agency for final action; and (4) cases received from another agency for opinion only. Cases re-
corded in column (i) must not be counted under cases recorded under other columns.
Item 88. The same instructions given for completing Item 8A, above, apply to Item 8B, except that the information recorded in
these columns refers to mandatory review appeals.
Item 9. Enter in the appropriate columns actions taken as a result of systematic review for declassification of U.S. originated,
permanently valuable documents in the custody of the reporting activity. Report actions by number of pages.
Item 10. For the purpose of this report, an inspection, survey, or program review includes any formal independent evaluation
conducted within the agency of any aspect of the information security program established by E.O. 12065, to include policy,
procedures, and operations.
Item 11. Enter the actual number of Top Secret documents recorded as of the last annual inventory.
Item 12. An infraction is any error and/or impropriety in marking, destroying, handling, reproducing, transmitting, gaining
access and/or storing classified information in a manner which does not conform with the requirements of E.O. 12065 and its
directives. Actions which constitute an infraction are listed in blocks A. through K. Enter in the appropriate column the total
number of infractions detected as a result of inspections conducted during the reporting period. (See Item 10 above.) Infractions
reported on, this form should not include those "knowing and willful" violations of the terms of the Order and its directives
required by 5-504 of the Order to be reported to the Director, ISOO, as they occur.
Item 13. The "narrative report" section is designed to register descriptions of major accomplishments and problems detected
during the reporting period. Detailed narrative reporting is mandatory.
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10 gyp; 1981
t~ l.eU y S ry
MEMORANDUM FOR NATIONAL FOREIGN INTELLIGENCE COUNCIL.
SUBJECT: Waiver of Portion-Marking Requirement for In-Plant
Contractor-Generated SCI Documents
1. In response to a request by the Acting Chairman, NFIB, the
Director, Information Security Oversight Office (ISOO) has granted a
waiver from the portion-marking requirement of Section 1-504 of Executive
Order 12065, for sensitive compartmented information (SCI) material generated
by SCI contractors in contractor facilities. This memorandum is authorization
to implement the provisions of the waiver.
2. The provisions of the waiver are permissive rather than mandatory,
and cognizant Senior Intelligence Officers may continue to require
portion-marking where appropriate. Any document upon which the waiver is
exercised will be marked as follows:
"Warning - this document shall not be used as a
source for derivative classification."
3. In his approval letter (attachment B), the Director, ISOO, stated
that the waiver does not apply to certain types of information. Questions
concerning this provision may be directed to agency records management
personnel or to ISOO.
/a,/ ~nd nn~~ tl J. Ste z-_310
William J. Casey
Chairman
A. Letter from Acting Chairman, NFIB, to Director, ISOO
dated 7 January 1981.
B. Letter from Director, ISOO, to Chairman, NFIB, dated
3 March 1981.
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The Director of Centr; I !ntelli once
o CIS r err:sary-~'
~~-
1Vashin~Kun.O. C. 20M
DD/AA Registry
x>CL'tl'I Beg-
Mr. Steven Garfinkel
Director, Information Security
Oversight Office (Z)
General Services-Administration
18th & F Streets, N.W.
Washington, D.C. 20405
Dear Mr. Garfinkel:
As you are aware, for some time the Intelligence Community has
been working on a compartmented information program known as APEX, a
single community-wide system designed to replace the multitude of
compartmented systems already in existence. The primary objective of
APEX is to ensure that only information which is truly sensitive and
deserving of compartmentation is so marked and receives the protection
it deserves. Unfortunately, the conversion to APEX will be costly, both
in terms of dollars and human resources. It is therefore necessary to
determine areas where small modifications to current standards will
produce substantial cost savings.
We have determined that one of those areas is the portion marking
requirement of'Executive Order 12065. While we have no problem with the
portion marking requirement as applied to members of the Intelligence
Community, I do believe that this requirement, if imposed on government
contractors who do work for the Intelligence Community, would result in
costs which would greatly exceed any benefits derived therefrom.
For example, a recent survey of only a few contractors indicates that
the costs of portion marking by contractors will cost tens of millions
of dollars.
It is therefore requested that, in accordance with provisions of
E.O. 12065, you waive the portion marking requirement as it would apply
to in-plant contractor. generated sensitive compartmented information.
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Forwarded herewith is substantiation for the waiver request. Since we
intend to implement APEX in early 1981, I would appreciate your early
and favorable consideration.. of this matter.
Fran1 C. Carlucci
Frank C. Carlucci
Acting Chairman,.
National Foreign Intelligence Board
Enclosure
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Enclosure to Letter to Director, Information Security Oversight Office
SUBJECT: Waiver of Portion Marking Requirement for In-Plant,
Contractor Generated APEX Material
The following is submitted in accordance with ISOO Directive
No. 1, Section I, paragraph G.9: -
a. Identification of the information or classes of documents
for which such waiver is sought.
.All contractor generated sensitive compartmented
information (SCI) produced in contractor facilities
under a formal agreement between the government
and the contractor for services.or products.
Contractor/consultant produced material generated or
prepared within a government facility will meet the
requirements for portion marking as though it were a
government produced document.
b. A detailed explanation of why the waiver should be
granted.
The requirement for portion marking will increase
severely the man-hours to produce documents. Such
requirement will require additional personnel resources,
thereby increasing contract costs.
c. the agency's best judgment as to the anticipated
dissemination of the information or class.of documents for which
waiver is sought.
All contractor generated SCI material will be submitted
to the Program Managers for use or further distribution,
if any, or to others as directed.
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d. The extent to which the infon!ation subject to the waiver
may form a basis for classification of other. documents.
The majority of documentation generated by contractors is
of a technical or engineering nature and is an end product;
therefore, it is unlikely that such material would be used
as a basis for classification of other documents.
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 Services Oversight
,. Administration ()fficP ne-
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G ral Information Security
p,
19
Honorable William J. Casey
Chairman, National Foreign Intelligence Board
Washington, D.C. 20505
Dear Mr. Chairman:
By the provisions of Section 1-504, Executive Order 12065, each classified document
shall, by marking or other means, indicate clearly which portions are classified, with the
applicable classification designation, and which portions are not classified. The Director
of the Information Security Oversight Office may, for good cause, grant waivers of this
requirement for specified classes of documents or information. In his letter of
January 7, 1981, the Honorable Frank C. Carlucci, then Acting Chairman, National
Foreign Intelligence Board, requested a waiver of the portion-marking requirement as it
would apply to sensitive compartmented information (SCI) material generated by SCI
contractors in contractor facilities. The rationale for the waiver is the substantial cost
savings in terms of dollars and human resources.
After careful consideration of the points raised by Mr. Carlucci, and discussions with
officials from the Central Intelligence Agency and other agencies concerned with the SCI
program, I have concluded that portion-marking of SCI material generated in SCI
contractor facilities would pose an inordinate financial burden, far beyond the benefits to
be derived from the portion-marking of this information. Critical to my determination
are the facts that (1) the classified information at issue is not contained in permanently
valuAble records of the Government; and (2) the classified information at issue will not
be used as a source for derivative classification decisions outside the contractor facility.
A waiver is hereby granted from the portion-marking requirements of Section 1-504. of
Executive Order 12065, for SCI material generated by SCI contractors in contractor
facilities. To preclude the unnecessary classification or overclassification of
permanently valuable records of the United States, this waiver shall not apply to
information contained in any records so designated by the Archivist of the United
States. Further, any information transmitted outside the.-in-house -contractor. facility,
where it may be used as a source document in the derivative classification of other
information, must be portion-marked before its transmittal.
In order that ISOO can monitor this waiver and its exceptions as part of its ongoing
oversight responsibilities, I would appreciate receiving a copy of any instruction intended
to implement this decision. Please don't hesitate to contact me if you have any questions
or comments.
Sincerely,
STEVEN GARFINKEL
Director
On file GSA Release Instructions apply.
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