When employees steal proprietary information, they don't just cause headaches for the organization—they erode confidence in the trustworthiness of screened employees and vetted business partners. Following the recent spate of high-profile incidents—including leaks by U.S. National Security Agency contractor Edward Snowden in 2013, violent attacks on Fort Hood by Major Nidal Hasan in 2009, and Washington Navy Yard shooter Aaron Alexis in 2013—the U.S. government determined that existing vetting processes and security standards for sensitive programs were inadequate. Key policy changes were implemented, including a new requirement for government organizations and certain government contractors to establish an insider threat program. The requirements changed the way government-affiliated organizations approached employee management and codified existing insider threat practices.
What does that mean for private sector organizations, even if they don't work with the government? Certain features of a U.S. Department of Defense (DoD)-style insider threat program may be relatively easy to implement and offer considerable security enhancements. Traditional administrative and physical security practices—locked doors, alarm systems, and inventory controls—are focused externally and are largely ineffective at preventing employees and other authorized persons from committing harmful acts.
Integrating an insider threat policy with employee and event best practices can create a well-rounded employee management program that benefits workers and the organization. Educating employees on how to recognize and report potential insider threat information can also have a positive effect on the organization's culture and emphasize everyone's role in keeping a safe, secure work environment.
Concurrent Technologies Corporation (CTC), an independent, nonprofit organization that conducts applied scientific research and development for government and industry, faced this exact challenge upon the creation of a nuclear research facility.
With industrial space and laboratories in five states, and more than 25 percent of employees telecommuting, CTC's potential insider threat profile is typical among many technology companies in the United States. Protection of sensitive government programs, client information, and intellectual property is paramount to success in a highly competitive environment.
But the August 2017 establishment of CTC's Center for Advanced Nuclear Manufacturing (CANM) in Johnstown, Pennsylvania, created new insider threat challenges that CTC had to address. The CANM is designed to bring fabrication technology and materials expertise to the emerging next generation of commercial nuclear power plants and will conduct business only with private sector organizations that are working on small nuclear reactors. While CTC works with both industry and sensitive government programs—and must abide by federal insider threat policies—it wanted CANM to have a government-grade insider threat program that would defend against all kinds of manmade threats—from petty theft to intellectual property issues to event management.
A planned ribbon cutting and open house event at the CANM would place about 75 visitors in close proximity to CTC's intellectual property and advanced technology—and would serve as the first real test of the organization's new insider threat policy.
Tailoring a Solution
The FBI, U.S. Department of Homeland Security (DHS), and U.S. Defense Security Service provide tools for industry organizations to develop insider threat programs, including online training courses and brochures available through public websites. The tools identify specific behaviors that may indicate the presence of an insider threat.
Simply educating employees on what to watch for may improve the chances of averting a workplace incident. Other insider threat program features, such as information sharing and incident reporting, could also prove beneficial. Initiatives can be tailored to fit the organization, and security practitioners may find that their programs already include parts of the overall insider threat framework outlined in government directives.
This was true for CTC as it began to build a more robust insider threat program. While the organization had taken an informal approach to communicating potential employee issues, it was nowhere near the formalized program needed. To make sure the program covered all threats, CTC created an insider threat working group.
Comprehensive support. An insider threat program relies on buy-in throughout the organization. A single official with authority to develop policies and procedures should be appointed to manage the program. He or she should also be responsible for determining when to report substantive insider threat information to law enforcement and other entities outside the organization.
CTC appointed an insider threat program official and established a working group with membership based on relevant roles, including representatives from security, human resources, IT, executive management, and ethics and compliance. The working group conducted several program reviews and established the types of activities to watch out for or report.
The group also ensured that all employees completed awareness training in the time leading up to the CANM open house and helped foster a culture of communication so that employees would not hesitate to report concerns about visitors or fellow employees. Line employees are often the first to sense that something is off—if they notice changes in an employee's routine or behavior, they should know how to safely and effectively communicate the information to team leaders without fear of retribution.
Security staff and senior managers stood ready to work with department managers and labor representatives to reduce or eliminate social barriers to reporting. Reporting policy violations and unusual or suspicious behavior must not be viewed as tattling. Instead, it should be emphasized that timely reporting may save the company or business unit from significant financial loss, unfair competition, or even a tragic incident.
Team approach. Effective information sharing and collaboration among security stakeholders in the organization are essential for a stalwart insider threat program. Functional leaders—like the ones in CTC's insider threat working group—typically monitor organizational performance in areas relevant to detecting a potential insider threat. For example, larger organizations usually rely on a CISO to detect violation or circumvention of policies regarding systems access, file transfers, software installation, and other network activities. Likewise, the human resources department should track, analyze, and share information on trends in employee misconduct, including harassment complaints and drug testing. In reviewing such information, the team must take care to protect employee privacy and focus only on security-relevant factors that might create concerns of an insider threat and identify needed adjustments in policies and training.
For special events and unusual situations, organizations should not shy away from reaching out for help. The CTC insider threat program's leader contacted the FBI private sector coordinator, Defense Security Service representatives, and local law enforcement officials several weeks before the open house to inform them about the event and to obtain updated threat information. The FBI coordinator participated in an event rehearsal and walkthrough, and provided a tailored counterintelligence briefing to CANM engineers, program managers, and support staff, offering specific recommendations to limit risk while accomplishing overall open house objectives.
Training. Employees should feel that they share a common security interest—success for themselves and for the entire organization requires their commitment to protecting intellectual property, proprietary information, and other valuable resources. Leaders must emphasize these points and encourage employees to actively support security programs and procedures. Employee commitment and loyalty to a common cause cannot be assumed, particularly in industries that experience high employee turnover.
Training employees to watch for specific activities and behaviors that may indicate an insider threat is the key to viable information reporting within the organization. Employees tend to recognize differences in a coworker's attitude, work ethic, or behavior well before an incident occurs, so they must know when and how to report concerns. Employees must also know how to recognize suspicious emails, scams, phishing attempts, and social engineering tricks to avoid becoming an unwitting insider or being coerced into providing information or other assistance. Training should also emphasize the importance of following basic rules aimed at mitigating risk, such as locking or switching off computer workstations when unattended.
CANM employees were trained in traditional insider threat identification messages but were also given tips on identifying and reporting suspicious behavior at the open house event.
Because engineers, program managers, and event staff integrated security best practices into their job requirements, enhanced security was everywhere yet remained unseen at the event.
Written plans. The insider threat working group at CTC identified all written guidance regarding employee behavior, from harassment policies and timekeeping systems to travel plans and procedures and integrated it into the plan. The insider threat program features a risk mitigation plan that identifies insider threat stakeholders, roles and responsibilities, resources, policies, and procedures. The team of stakeholders meet periodically to review the plan, share and assess potential insider threat information, and determine additional actions needed to protect people, operations, intellectual property, and other resources.
For example, at a stakeholder meeting, someone in charge of travel finances might point out that the rental car budget for the previous month was 20 percent larger than normal. Human resources personnel can revisit employee travel dates and potentially identify excessive use of rental vehicles for personal travel. The same insider threat reporting procedures should be followed to address the problem.
Redefining Insider Threats
CTC's reevaluation and preparation paid off—the open house event went smoothly for staff and visitors alike.
CTC security officials are also reaping longer-term benefits from the CANM experience. For example, the department is improving its approach to training by conducting lunchtime seminars and more personal interviews with employees to reinforce the significant role that each employee plays in countering insider threats, even if security is not their primary role.
In addition to the CANM program, other business changes prompted CTC to reassess potential threats and strengthen routine security procedures. New contracts with government clients outside the DoD brought new requirements and concerns for protecting sensitive information processed and stored on company networks. The company invested in new equipment, and other areas of business development brought increased interaction with international customers—along with added challenges for ensuring compliance with American export laws.
By thinking outside the box in regard to an insider threat, CDC was able to create a well-rounded employee management policy that is capable of addressing a variety of organizational concerns. Addressing a wide scope of potentially problematic employee-related activity—not just intellectual property or workplace violence concerns—through an insider threat lens strengthens the entire program and makes it more adaptable for addressing other business concerns.
As an example, security staff worked with shop floor staff and project managers to revise the facility's access control plan. Doors to certain industrial areas within the 250,000-square foot CANM were closed to employees who did not have a clear need for access. Facility access hours were restricted for many employees, and a proximity card in addition to a six-digit PIN is now required to use doors that are not routinely monitored. Process owners and senior managers fully grasped the need for such procedural changes and strongly supported the recommendations.
As international business contacts expanded, the security, contracts, and export compliance departments worked closely with program managers to ensure that export licenses encompass all international dealings involving protected technologies. The company's enterprise visitor system, internally developed in 2012 and upgraded in 2015, electronically routes international visit requests for coordination and approval. This ensures that the right managers and technicians are informed, projects are shrouded, or operations are suspended or rescheduled as needed.
With such low- or no-cost security enhancements in place, establishing an insider threat program required only a modest effort to formalize plans and procedures, chartering a working group, and expanding existing training. Other corporations working exclusively or extensively with government contracts can engineer similar results.
Increasing awareness of insider threats and encouraging employees to report suspicious behavior and policy violations has directly led to improved overall security. For example, information received in recent months from frontline employees has enabled managers to correct internal issues and mitigate vulnerabilities in how the company purchases, inventories, and accounts for low-cost supplies, equipment, and bench tools. Workers in the affected areas recognize how the changes reduce risk of pilferage and unauthorized use of company assets. Minimizing such losses helps the company control overhead costs, remain competitive, and protect jobs and salaries.
If an organization is unaccustomed to a regimen of safety and security rules during daily business operations, it may take months to evolve a security culture where employees are likely to bring their concerns forward and key supervisors can evaluate information and respond effectively. The advantages of starting now almost certainly outweigh the risk of what could come later.
Sidebar: How Nuclear-Level Security Influenced Today’s
Insider Threat Programs
Concerns about insider threats are not new. In the mid-1940s, during the highly secretive Manhattan Project—the United States' efforts to develop the world's first atomic weapons—leaders were most concerned that a trusted insider could be blackmailed or tempted to commit espionage for money. Losing atomic secrets to enemies could have drastic—and deadly—consequences. The art of protecting critical research, test activities, materiel and weapons production, and plans for use of nuclear weapons was woven into the Manhattan Project and remains a hallmark of security within U.S. Department of Defense (DoD) nuclear programs.
The personnel clearance process and the personnel reliability program (PRP) have been central in addressing insider threats to nuclear capabilities since the 1960s. Clearance processes are designed to screen people for trustworthiness and must be strictly followed prior to granting an individual access to classified nuclear design information, plans, capabilities, or operating procedures. A personnel clearance is based on favorable evaluation of factors such as the person's demonstrated financial responsibility, personal conduct, and allegiance to the United States. Cleared individuals are reinvestigated periodically to ensure continued access is appropriate. Those in unusually sensitive and critical positions may be subjected to polygraphs.
The PRP is an added layer of administrative security comprising procedures, automated notifications, tiered supervision, and other checks designed to ensure workers are mentally and physically fit at the time they perform critical tasks, such as nuclear command and control, maintenance, or armed security. PRP requirements and standards are risk averse—the slightest concern may result in temporary suspension from normal duties until circumstances change or a problem is resolved. A common reason for temporary suspension from duties under the PRP is use of prescription medication, which may cause drowsiness. Minor disciplinary infractions may also result in PRP suspension, triggering security measures that block access to restricted facilities and information systems.
Together, clearance processes and the PRP foster a heightened safety and security environment where workers are dutybound to report relevant information about themselves and others to appropriate authorities. Such an environment is essential based on the destructive power and political significance of the nuclear arsenal. Senior government and military personnel hold leaders within the nuclear community accountable for evaluating conditions that may detract from anyone's assigned tasks under PRP. For example, removal of the responsible unit commander is often the outcome of failure to properly adhere to PRP guidelines.
Historically, these stringent screening and reliability standards are seldom applied to government and contractor enterprises outside nuclear communities. Since 2013, however, government officials have increasingly acknowledged the threat of insiders. Personnel clearance processes are now bolstered with additional screening and random selection for background checks between the traditional timespans for periodic reinvestigation. Additionally, government clearance adjudicators may now review and consider social media information when determining overall eligibility for access to national security information.
A series of U.S. Department of Homeland Security and DoD documents and guidelines mandate insider threat programs for agencies and certain contractors but stop short of requiring self-reporting measures such as those associated with the DoD PRP due to cost, legal concerns, and other practical considerations. A PRP-like mindset, however, can be encouraged within any operation where inattention to detail, slowed reaction time, or lapse in judgment could result in injury, death, or unacceptable material or financial loss.
Ronald R. Newsom, CPP, is a retired U.S. Air Force officer now employed with Concurrent Technologies Corporation, a recipient of the DoD 2017 Colonel James S. Cogswell Award for sustained excellence in industrial security. Newsom is a member of ASIS International. He also serves as the Chair of the National Classification Management Society's Appalachian Chapter.