Contracting Docs: OPM Seeks to Tighten IT Security of Background Investigation Companies


OPM first inserted updated IT security clauses into existing contracts in April.

Contractors that conduct background investigations for the federal government will have to report information security incidents to the Office of Personnel Management within half an hour, are required to use smartcards as a second layer of security when logging on to agency networks and must agree to let OPM inspect their systems at any time.

Those are new requirements OPM has written into draft contracting documents released last month that govern how the personal, often sensitive, information gleaned during background investigations should be stored on contractors’ computer systems.

The draft request for proposals is “intended to provide industry advanced notice of the pending solicitation as well as an opportunity to provide comments, feedback and recommendations that the government can consider prior to finalizing the solicitation,” OPM spokesman Sam Schumach told Nextgov in an email.

The security of OPM systems -- and of the system of private companies whose employees do most of the legwork in conducting background investigations -- came under scrutiny last summer when it was revealed hackers breached computer systems belonging to both OPM and its two major contractors. The hackers, purportedly Chinese cyberspies, were presumably on the hunt for information on the U.S. national security workforce.

OPM first inserted updated IT security clauses into existing contracts in April, OPM Chief Information Officer Donna Seymour told lawmakers at the time. However, the new contracting documents, posted to on Jan. 20, provide more detail about the crackdown on the security of contractor systems. Schumach said OPM is already tweaking the IT security provisions in the draft solicitation.

“Due to the ever-evolving nature of cybersecurity threats, the IT security clauses posted in the draft RFP represent recent revisions, but do not represent the most up-to-date revisions in progress, which will be finalized and issued with the formal solicitation,” he said.

Contractors Need to Encrypt Data

The new requirements mandate contractors have procedures for properly handling sensitive data, including encrypting data “while at rest and in transit throughout contractor networks, and on host and client platforms.”

OPM, itself, came under fire last summer when it was revealed the agency’s antiquated IT systems did not allow sensitive data to be encrypted. Under a plan announced Jan. 22 by federal officials, the government will shift responsibility for overseeing background investigations to a new entity within OPM, the National Background Investigations Bureau. The Defense Department will be responsible for building the bureau’s IT systems and for storing and securing sensitive data.

Contractors also must have policies for dealing with information security incidents and ensuring employees receive proper cybersecurity training before gaining access to OPM IT systems.

30 Minutes to Report Security Incidents

Contractors are required to report all information security incidents involving OPM information to the agency’s “situation room,” which is reachable via phone, email and fax 24 hours a day, according to contracting documents.

Companies have to report all information security incidents involving their IT systems “immediately upon becoming aware” of them, which means 30 minutes or less, per the draft RFP.

Under the terms of the contract, companies have to provide “full access and cooperation” as deemed necessary by OPM contracting officials to protect OPM data and information systems. Companies also have to “promptly” respond to all requests from OPM for system-related information, such as disk images and log files.

That seems to be a response to a situation involving one of OPM’s former contractors, U.S. Investigations Service. In 2014, the company -- which went out of business after being sued by the Justice Department for shoddy work -- notified OPM of a breach of its systems.

However, OPM contends the contactor blocked the Department of Homeland Security from fully inspecting company networks to probe the effects of the breach. The company has maintained it cooperated with federal investigators.

In August 2014, OPM suspended USIS from working on the contract, citing the company’s response to the cyberincident.

According to the draft document, OPM can unilaterally bring in other agencies, such as DHS, or third-party firms to help review security incidents.

Contractors are also barred from conducting their own post-incident reviews “that could modify or eliminate any existing technical configuration or information or forensic technical evidence” without approval of the OPM CIO, according to the draft RFP.

Two-Factor Authentication

Contractors are required to use personal identity verification cards to access OPM IT systems.

OPM, itself, before the big breach lagged on using smartcards as an added layer of log-on security. Before the hack, far fewer than half of agency employees -- 42 percent -- were required to use PIV cards to log on to the OPM network.

After the compromise, and a governmentwide “cybersecurity sprint” to quickly plug pressing security vulnerabilities, that percentage grew to 97 percent.

Among the other stipulations: Before contractors can use any commercial cloud service providers, they must obtain approval from the OPM CIO.

Cloud service providers used by background check contractors must also undergo third-party assessments under the Federal Risk and Authorization Management Program. Cloud service providers must allow access to all OPM data stored in the cloud, including data schemas and metadata

In addition to the USIS hack, which exposed personal information on an unknown number of DHS employees, another major OPM contractor, KeyPoint Government Solutions, announced in December 2014 its systems had been breached, potentially exposing data on 48,000 federal employees.

Officials told lawmakers they believe the hackers used stolen credentials from a KeyPoint employee to gain access to OPM’s networks and eventually steal personal information on some 2.5 million federal employees, contractors, retirees and prospective employees from OPM’s digital files.

The draft solicitation marks only the beginning stages of OPM issuing a new contract for background investigation fieldwork services -- the hired investigators who knock on neighbors’ doors, interview former employers and check police and court records of those people applying for federal jobs or positions to view sensitive information.

The current contract, which has a total ceiling of more than $2.4 billion, expires Nov. 30. OPM plans to issue a final RFP in March.

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