On May 2, 2022, Public Services and Procurement Canada (PSPC) will implement further changes to the Contract Security Program (CSP). These upcoming changes relate to the organization’s security screening process and follow changes to the personnel screening process implemented in October 2021.
As we mentioned in our previous newsletter, Upcoming Changes to the Federal Contract Security Program Could Pose Challenges for Industry (and Government), the CSP will limit security screening to organizations that actively participate in a supply with security requirements. While the CSP had already flagged many of these upcoming changes, the latest update provides more details and some previously unannounced changes that will go into effect.
We highlight the most important changes below.
Changes to the organization’s current security screening process
CSP will now screen new organizations and renew or upgrade the security clearance of current or former registrants who:
- responded to a government solicitation with security requirements
- will be awarded a contract (competitor or sole source) or standing offer/supply arrangement with security requirements
- will be awarded a subcontract with security requirements
- are involved in a multinational program
- are underrepresented.
Consistent with CSP’s intent to limit clearances to organizations involved in active federal procurement, CSP:
- re-evaluate organizations pre-screened for continued CSP eligibility in accordance with existing policy requirements outlined in the Contract Security Manual and Organization Security Agreement; and
- review all outstanding organizational security screening requests and close those that do not meet the new eligibility criteria.
Once terminated, an organization may reactivate its security clearance if it is active in another tender process or is awarded a contract or subcontract with security requirements in:
- Two years from date of termination for DOS and reliability status
- One year from date of termination of FSC at Secret/Top Secret/NATO levels and equivalent personnel security clearances
New screening processes
The CSP introduces a new interim security clearance for Canadian organizations that need access to protected or classified information during the pre-solicitation stage of a procurement process. Similar to processes used by other countries, a provisional authorization will allow a limited number of the bidder’s employees to obtain provisional authorization for the duration of the bid solicitation only.
Once the Bidder is confirmed as responding to a solicitation process, the Bidder will be invited to complete the Organization Screening Process (for DOS or FSC).
Foreign bidders will still be required to obtain assurances of authorizations in their home country.
New options for contractors
Prime contractors may, in certain situations, request and conduct personnel security checks for subcontractor personnel (instead of the subcontractor having to obtain their own security clearance). However, this option is not available to all sub-processors and requires a case-by-case analysis of factors such as the size of the sub-processor, the type of information to be accessed and whether the information is retained on site. of the main contractor.