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    Independents/Firms who provide services to the Government of Canada (even as subcontractors/independent contractors to other firms) must register in the Industrial Security Program

    The Industrial Security Sector (ISS) of Public Works and Government Services Canada (PWGSC) requires all individuals operating as independent contractors to register in the Industrial Security program and obtain an organizational security clearance in addition to their personal security clearance. Independent contractors are defined as “any individual business entity, including: independent contractors, independent and freelance consultants, and independent suppliers and business owners”.

    Why Register?

    When an independent contractor wishes to work for the Government of Canada on a contract that requires a security clearance, that contractor must register in the ISP as an organization, in conformance with the Treasury Board of Canada’s Policy on Government Security. Registration in the ISP provides independent contractors with their own organizational security clearance. This clearance allows independent contractors increased mobility and flexibility to participate in contracts across federal government organizations; and facilitates entering into a subcontract without experiencing delays for security screening. Registration also allows ISS to enforce program compliance by ensuring all contractual security requirements are carried out through the supply chain, from the Prime contractor to any of its subcontractors, including independent contractors.

    ISS emphasizes that ensuring compliance with the ISP is a shared responsibility:

    “By working together to register all suppliers in the ISP, from the Prime contracting organizations to subcontractors, including independent contractors, ISS can continue to help industry participate in Government of Canada and foreign government contracts, while maintaining the Government of Canada’s security posture.”

    Organizational Security Clearance vs. Personal Security Clearance

    An organizational security clearance, depending on the type of clearance applied for, allows an organization and its security-cleared employees access to Protected or Classified information, assets and secure work sites as part of a contract, and as long as they have a need-to-know.

    A personal security clearance (such as Reliability or Secret) is not the same as an organizational security clearance. Security clearances for individuals are issued by the Government of Canada and are held by the employing organization – and not the individual – for work on contracts of a sensitive nature. For more information on personal security clearances, refer to Personnel Security Screening.

    If a federal government contract has security requirements, an independent contractor must hold both types of clearances:

    • The contractor must be registered in the ISP and have an organizational security clearance before beginning work on the contract
    • The contractor’s assigned personnel must have Reliability status, or a security clearance at the level required to work on that contract

    ISP Registration Process for Organizations That Employ Contractors

    Process for independent contractors previously cleared as employees
    To help organizations become compliant, specifically those who have previously cleared independent contractors as employees, ISS is implementing a measure to allow Prime contractor organizations who are registered in the ISP, to sponsor independent contractors into the ISP in a timely and controlled manner, without negatively affecting the delivery of services to the Government of Canada.

    Effective immediately, any organization already registered with the ISP that requests a Reliability Status (RS) or Personal Security Clearance (PSC) duplication or update for an independent contractor taking part in a Government contract awarded with a Security Requirements Check List (SRCL), is required to initiate the separate registration of that independent contractor with the ISP, while work on the government contract is being performed.

    Process for independent contractors without personal or organizational security clearance
    The above measure does not apply in the case of new resources, independent contractors who are unscreened / non-ISP registered. To obtain a Reliability status or personal security clearance for unscreened / non-registered independent contractors, the Prime contracting organization must first sponsor them for registration in the ISP, following the regular sponsor process as described in the Industrial Security Manual.

    Independent Contractors and ISP Registration

    If you are an independent contractor who works on federal government contracts, you must register in the ISP and obtain an organizational security clearance. To register in the ISP, a Government of Canada Approved Source must sponsor you and submit a Request for Private Sector Organization Screening (PSOS) on your behalf. Check with the organization to which you are subcontracting to determine whether they can act as an Approved Source for you. For a definition and list of Approved Sources, refer to How to Register in the Industrial Security Program.

    As an additional option, independents who provide professional services may be able to qualify for the ProServices Supply Arrangement and can request sponsorship from the ProServices team at PWGSC. Please Contact Us if you require additional information on this option.

    More Information

    For more information on the organizational and personnel security screening processes, go to the ISS website, or contact ISS at ssi-iss@tpsgc-pwgsc.gc.ca, telephone: 1-866-368-4646.

    2 responses to “Independents/Firms who provide services to the Government of Canada (even as subcontractors/independent contractors to other firms) must register in the Industrial Security Program”

    1. Jo-Anne Barton says:

      HI ,

      Can you please tell me when this article was written? Also – is the writer saying that ALL independent contractors must hold an ISP?

      Thanks

    2. Keith Parker says:

      Hi Jo-Anne,

      This article was posted in August 2014. Yes, my understanding is that all independent contractors who work on Government of Canada contracts need to have their own organization DOS clearance (or higher, depending on the security level of the contract) in addition to their personal clearance (which would be held within their company).

      The information that was provided in August 2014 indicated that the practice where firms would clear independent contractors under the firm’s security clearance would be phased out. I do not believe this applies if the independent contractor is being brought on as an employee of the firm.

      We have not seen any information since August 2014 on this specific subject and we do not know if ISS followed through on the initiative.

      Hope this helps.

      Keith

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