MARADMINS : 278/04
R 252032Z JUN 04
FM CMC WASHINGTON DC
TO MARADMIN
BT
UNCLAS
MARADMIN 278/04
MSGID/GENADMIN/CMC WASHINGTON DC//C4//
SUBJ/FOREIGN NATIONAL ADMINISTRATOR ACCESS TO THE USMC INFORMATION
/SYSTEMS//
REF/A/DOC/DODD 8500.1/24OCT2002//
REF/B/DOC/DODI 8500.2/06FEB2003//
REF/C/DOC/CJCSM 6510.01/25MAR2003//
REF/D/DOC/CJCSI 6510.01C/01MAY2001//
REF/E/DOC/SECNAVINST 5510.30A/19JUN2000//
POC/RAY A. LETTEER/GS-14/C4 CP HQMC/-/TEL:703-693-3490
/TEL:DSN 223-3490/EMAIL:LETTEERRA@HQMC.USMC.MIL//
NARR/REF A IS DEPARTMENT OF DEFENSE INFORMATION ASSURANCE (IA)
DIRECTIVE. REF B IS DEPARTMENT OF DEFENSE IA IMPLEMENTATION
INSTRUCTION. REF C IS CHAIRMAN OF THE JOINT CHIEFS OF STAFF IA AND
COMPUTER NETWORK DEFENSE (CND) MANUAL. REF D IS CHAIRMAN OF THE
JOINT CHIEFS OF STAFF IA AND CND INSTRUCTION. REF E IS DEPARTMENT
OF NAVY (DON) PERSONNEL SECURITY PROGRAM (PSP) REGULATION.//
GENTEXT/REMARKS/1. PURPOSE. THIS MESSAGE PROMULAGATES MARINE CORPS
POLICY REGARDING FOREIGN NATIONAL (FN) PERSONNEL OCCUPYING IA
MANAGEMENT AND ADMINSITRATOR ROLES ON UNCLASSIFIED INFORMATION
SYSTEMS. THIS MESSAGE IDENTIFIES RESTRICTIONS AND CONDITIONS THAT
LOCAL DESIGNATED APPROVAL AUTHORITIES (DAA) ARE RESPONSIBLE TO MEET
PRIOR TO DESIGNATING NEW FN PERSONNEL AS ADMINSTRATORS AND FOR THE
CONTINUED USE OF CURRENT FN PERSONNEL AS INFORMATION ASSURANCE
OFFICERS (IAO) AND ADMINSITRATORS ON UNCLASSIFIED MARINE CORPS
NETWORKS. FN ACCESS TO CLASSIFIED NETWORKS AND/OR SYSTEMS REQUIRES
ADDITIONAL STEPS DELINEATED WITHIN THE DOD PERSONNEL SECURITY
PROGRAM (DODD 5200.2-R).
2. ISSUE. REFS A AND B HAVE BEEN INTERPRETED BY SOME APPLICABLE
PERSONNEL AS BARRING FNS FROM ALL IA ADMINSTRATOR & PRIVILEGED USER
FUNCTIONS. USMC POLICY DOES NOT SUPPORT THIS INTERPRETATION AND THIS
MARADMIN SPECIFIES THE CONDITIONS AND RESPONSIBILITIES UNDER WHICH
THE MARINE CORPS WILL CONTINUE TO USE FNS WITHIN USMC INFORMATION
SYSTEMS IAW DOD POLICY.
3. POLICY.
A. REFS C AND D IDENTIFY IA FUNCTIONAL ROLES AND RESPONSIBILITIES.
BOTH NOTE THE CHANGE OF TERMS INFORMATION SYSTEM SECURITY MANAGER
(ISSM) TO INFORMATION ASSURANCE MANAGER (IAM), AND INFORMATION
SYSTEM SECURITY OFFICER (ISSO) TO IAO. REFS C AND D ALSO CLASSIFY
SYSTEM ADMINISTRATORS AS PRIVILEGED USERS WITH IA CONFIGURATION
ABILITIES. REF C CHARGES SYSTEM ADMINISTRATORS WITH ASSISTING THE
IAO IN KEEPING SYSTEMS SECURE.
B. IAW REF B, PARA 5.8.3, ALL IAMS WILL BE U.S. CITIZENS. REF B
MAKES NO EXCEPTIONS ON THIS RULE. ASSIGNMENT TO A PRIVILEDGED USER
ROLE, IAM, WITH IA MANAGEMENT ACCESS IS NOT ALLOWED FOR FNS. IAW
PARA 2.8 REF E, A GOVERNMENT CIVILIAN OR MILITARY MEMBER MUST BE
DESIGNATED AS THE IAM. CONTRACTOR PERSONNEL ARE NOT ALLOWED TO SERVE
AS AN IAM.
C. IAW REF B, PARA 5.9.5 ALL NEWLY APPOINTED IAOS SHALL BE U.S.
CITIZENS. FOREIGN NATIONALS WHO ARE DIRECT OR INDIRECT HIRES AND ARE
CURRENTLY APPOINTED AS IAOS ARE PERMITTED TO CONTINUE IN THEIR ROLES
PROVIDED THEY RECEIVE THE WRITTEN APPROVAL OF THE DAA, SERVE UNDER
THE IMMEDIATE SUPERVISION OF A US CITIZEN IAM, HAVE NO SUPERVISORY
DUTIES AND UNDERGO A NACLC OR EQUIVALENT INVESTIGATION IAW PARA 4.8
OF REF A.
D. FNS CAN NO LONGER BE HIRED, DIRECTLY OR INDIRECTLY, TO PERFORM IN
AN IAO CAPACITY; NOR CAN A FN BE PROMOTED OR ELEVATED INTO AN IAO
POSITION. AS FN IAOS LEAVE THE MARINE CORPS OR CURRENT IAO DUTIES,
US CITIZENS WILL REPLACE THEM.
E. IAW REF B, ENCLOSURE 3, FNS ARE PERMITTED TO RETAIN PRIVILEGED
USER/SYSTEM ADMINISTRATOR POSITIONS, INCLUDING IA CONFIGURATION
CAPABILITY OF RELEVANT COMPONENTS PROVIDED THEY RECEIVE THE WRITTEN
APPROVAL OF THE DAA, SERVE UNDER THE IMMEDIATE SUPERVISION OF A US
CITIZEN, HAVE NO SUPERVISORY DUTIES AND UNDERGO A NACLC OR
EQUIVALENT INVESTIGATION IAW PARA 4.8 IN REF A.
4. IN SUMMARY, MARINE CORPS SYSTEMS WILL MAINTAIN CURRENT FN
PRIVILEGED USERS AND IAOS IAW PROVISIONS SET FORTH IN PARA 3 ABOVE.
FN'S IN CURRENT IAO ROLES MAY CONTINUE SERVICE. HOWEVER, FUTURE
HIRING OF FN'S TO PERFORM AS IAO'S IS NOT PERMITTED.//