1 Introduction

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1.1 Purpose

The purpose of these requirements is to:

  • provide guidance on achieving a consistent and structured approach to determining personnel security controls in agency facilities
  • strengthen processes for the screening and evaluation of employees during the course of their employment
  • strengthen processes for reporting changes in circumstances
  • establish consistent terminology for personnel security across the New Zealand government
  • give agencies and employees a better understanding of the security clearance vetting and management processes.
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1.2 Audience

The audience for these requirements is:

  • New Zealand government security management staff and national security clearance holders
  • contractors to the New Zealand government providing protective security advice and services
  • any other body or person responsible for the security of New Zealand government people, information or assets.
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1.3 Scope

These requirements cover:

  • awareness of the relevance for security of changes in personal circumstances
  • personnel security risk review
  • developing a security culture
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1.4 Compliance requirements

A control with a ‘must’ or ‘must not’ compliance requirement indicates that use of the control is mandatory. These are the baseline controls unless the control is demonstrably not relevant to the respective agency and can be clearly demonstrated to the agency head or accreditation authority.

A control with a ‘should’ or ‘should not’ requirement indicates that use of the control is considered good and recommended practice.  Valid reasons for not implementing a control could exist, including;

  1. a control is not relevant because the risk does not exist,
  2. or a process or control(s) of equal strength has been substituted.

Agencies must recognise that not using a control without due consideration may increase residual risk for the agency.  This residual risk needs to be agreed and acknowledged by the agency head.  In particular an agency should pose the following questions:

  1. Is the agency willing to accept additional risk?
  2. Have any implications for All of Government security been considered?
  3. If so, what is the justification?

A formal auditable record of this consideration and decision is required as part of the governance and assurance processes within an agency.

The PSR provides agencies with mandatory and best practice security measures.

The controls detailed above describe if and when agencies need to consider specific security measures to comply with the mandatory requirements.

Also refer to the Strategic Security Objectives, Core Policies and the Mandatory Requirements.

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2 Changes of circumstances

A national security clearance is granted to an individual by the agency head of the sponsoring agency following a favourable recommendation from the New Zealand Security and Intelligence Service (NZSIS).

The NZSIS recommendation is based on the comprehensive collection and evaluation of a wide range of relevant information, including the candidate’s personal circumstances and a ‘whole-of-life’ assessment.

If and when a candidate’s personal circumstances change, the initial recommendation for a national security clearance may need to be reassessed by the agency and/or NZSIS.

This is particularly significant for holders of high-level national security clearances.

Some significant changes in personal circumstances may be used by foreign intelligence services, issue-motivated groups, criminal organisations or others to coerce or induce individuals into providing protectively marked information or equipment belonging to the New Zealand government.

Commercial organisations may also exploit changes in circumstances to obtain information that would give them an unfair advantage in negotiations with the government or to acquire intellectual property or other privileged information.

When the agency, or when necessary the NZSIS, are made aware of changes in personal circumstances, risks can be assessed and if necessary, mitigated.

As a consequence the clearance holder, the agency and the national interest will remain protected.

Prompt and voluntary reporting of changes in circumstances demonstrates the national security clearance holder understands and respects security standards and is one of the indicators of an effective security culture within an agency.

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3 Reporting of significant changes of circumstances

National security clearance holders must report any changes in their personal circumstances at the time they occur to their Chief Security Officer (CSO).

Some changes in circumstance may have an effect on the agency’s operations and a clearance holder’s continued suitability to hold a security clearance.

A clearance holder should also advise management of significant changes in circumstances to assist in mitigating any possible conflicts of interest.

Managers should report any changes in circumstances relating to their staff to the CSO if they become aware of these changes and are unsure whether the changes have been notified by the clearance holder to their CSO.

Employees should also report significant changes in circumstances in other employees to their CSO if they believe it may affect that individual’s suitability to retain a security clearance or the security standards within the agency.

Where a report is received from a third party the reliability and validity of the report must be confirmed before any further action is taken.

The CSO should record any reported changes of circumstances in a register or on personal files. 

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4 Identifiable changes in circumstances

The following changes in circumstances must be reported.

  • Entering into, or ceasing, a close personal relationship

A close personal relationship is any relationship where the degree of sexual, emotional or financial intimacy might lead to the clearance holder becoming vulnerable to pressure or influence, for example, to protect close relatives or the relationship itself. In particular, a close personal relationship with a foreign citizen may result in a conflict of loyalty arising where the individual has to choose between the relationship and their loyalty to New Zealand.

  • Residence in, or visits to, foreign countries

Countries of security significance will vary depending on the clearance holder’s role, his or her agency’s responsibilities and the level of clearance held. By reporting all visits to foreign countries, CSOs, acting on advice from the NZSIS, can determine the significance.

  • Relatives residing in foreign countries of security significance

Any changes to the country of residence of the clearance holder’s close relatives’ (for example, immediate family or relatives the clearance holder has regular contact with) are significant as they may introduce conflicts of loyalty and/or issues of foreign influence or preference may arise.

  • Changes in citizenship or nationality

There must be no doubts about a national security clearance holder’s allegiance to New Zealand and his or her willingness to protect protectively marked information relating to New Zealand’s national security. Any changes in citizenship or residence must be reported.

  • Non-routine communications with employees of any foreign government

This type of contact must be reported to the clearance holder’s CSO through the Contact Reporting System administered by the NZSIS. If a clearance holder is concerned about the propriety of any questions asked or information requested by a foreign official then he or she must report the contact.

Also refer to Contact Reporting.

  • Changes in financial circumstances

This includes the receipt of large amounts of money, significant increases in debt, new financial associations and financial hardship such as bankruptcy or entering into a No Asset Procedure.

  • Changes in health or medical circumstances

Some medical conditions may make it easier for adversaries to gain information from a clearance holder. The use of some prescription drugs may have adverse effects on a clearance holder’s judgement and ability to determine when not to disclose information. Additionally, serious medical conditions may lead to financial difficulties.

  • Involvement in criminal activity

Deliberate involvement can indicate questionable judgement and a lack of integrity. Accidental involvement can also put a clearance holder at risk of adverse influence from criminal organisations. National security clearance holders must report any arrests, criminal charges or serious traffic offences to their CSO.

  • Involvement with any individual, group, society or organisation that may be of security concern

This may include extreme political groups, other extremist organisations or special interest or issue-motivated groups relating to projects currently being undertaken by the clearance holder or their agency. The groups of concern may vary depending on the roles of the clearance holder and his or her agency.

  • Disciplinary procedures

If a clearance holder is subject to disciplinary procedures he or she may lack the necessary qualities of reliability and good judgement.

  • Security incidents

Significant breaches or violations or a history of minor incidents may bring into question a clearance holder’s commitment to the security of the agency’s assets and reliability.

Also refer to Reporting Incidents and Conducting Security Investigations.

  • Any other changes in circumstance that may be of concern to the agency

Some agencies will have specific areas of concern, these must be advised to a clearance holder at the time he or she is employed or granted a clearance.

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5 Consequences of reporting a change in circumstance

Early recognition of a change in circumstance will usually allow the issue to be dealt with before it becomes a security concern, reducing the risk to both the clearance holder and the employing agency.

When a significant change in circumstance is identified or reported, the agency must conduct a risk assessment based on the continuation of the individual holding a clearance.

If there is doubt, the agency should suspend or cancel the national security clearance until the risk is mitigated or assessed as void.

The agency’s CSO must assess the situation and if necessary, escalate the matter to the NZSIS. Not all changes in personal circumstances will require this action.

Where the change is considered significant or is likely to present a risk to national security, the NZSIS must be informed.

If the NZSIS considers it necessary, the agency may be asked to submit a new vetting request.

If the NZSIS is satisfied that the clearance holder remains suitable to retain a clearance at the particular level, then a positive recommendation will be made. The risk management advice may include specific measures to be taken.

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5.1 Adverse findings

If the NZSIS is not satisfied that access to protectively marked material should continue at the current level, then the clearance holder and their agency head will be advised.

The clearance holder must be advised of his or her statutory right to make a complaint to the Inspector General of Intelligence and Security if he or she considers that they have been adversely affected by any act, omission, practice, policy or procedure of the NZSIS.

Complaints must be in writing and addressed to:

Inspector General of the High Court of New Zealand

DX SX 11199


More information is available at www.igis.govt.nz.

Also refer to the Personnel Security Management Protocol.

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A security clearance recommendation from the NZSIS is based on a wide range of information about a candidate, including their personal circumstances and a "whole of life" assessment.  If and when a candidate's personal circumstances change, the initial recommendation for a security clearance may need to be reassessed by the agency and/or the NZSIS.  This is particularly significant for holders of high level clearances.

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Last modified: 18 December 2014

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