Cyber Background Check

Cyber Background Check

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Cyber Background Check

Unidentified Registered Entity (URE) self-reported a violation of CIP-004-1 R2, R3 and R4. WECC determined URE had not established a training program for personnel with authorized access to Critical Cyber Assets and consequently did not maintain a corresponding training record in violation of R2. URE also did not have a personnel risk assessment program and did not conduct appropriate background checks per R3. In addition, URE did not have procedures and records concerning physical access to its Critical Cyber Assets per R4. Finding: The violations of R2 and R3 posed a moderate threat to the reliability of the bulk power system (BPS) because, even though URE is a small entity and did have a cyber security policy and a list of critical facilities in place, it did not have a training program for personnel with authorized access to the Critical Cyber Assets and did not have a compliant personnel risk assessment program that included background checks for personnel that had access to Critical Cyber Assets. Issue: Southwestern Power Administration (SPA) self-reported that during an internal review it discovered that two employees on its authorized unescorted access list did not receive physical security training within 90 days of obtaining authorization in violation of R2.1; two employees were authorized unescorted physical access to the Critical Cyber Assets (CCA) area without a criminal background check being performed within the past seven years in violation of R3.2; and two contractors were improperly included in the list of personnel with authorized, unescorted physical access to the CCA area in violation of R4. Issue: The NERC Registered Entity conducted background checks of its employees at the time of employment, however, it failed to update each personnel risk assessment at least every seven years after the initial personnel risk assessments were conducted for personnel with authorized cyber or authorized unescorted physical access rights to Critical Cyber Assets.

Issue: In September 2008, a Registered Entity self-reported that it provided three employees (who were granted unescorted physical access to the Critical Cyber Assets) with physical cardkey access to its Physical Security Perimeter, even though it had not conducted backgrounds checks on those employees within the seven-year time frame as required. In addition, MRO and SPP determined the violation of R4 did not pose a serious or substantial threat to the reliability of the bulk power system because most of the employees that were mistakenly not on the Critical Cyber Assets access lists had received cyber security training and background checks to ensure they would not abuse access rights to the Critical Cyber Assets. Finding: It was determined by SERC that the violation did not pose a serious or substantial risk to the reliability of the bulk power system because URE trained and performed background checks on all employees with cyber and unescorted physical access and kept records of the access granted to employees, contractors and service providers (these records were not made part of the master list, leading to the violation).

In regards to the first violation of R3, only one long-term employee (representing less than 1% of employees who had access rights to the Critical Cyber Assets) was missing his Personnel Risk Assessment and the Registered Entity performed the background check as soon as it discovered that it was missing. Finding: Upon review, FRCC determined there was no violation of R1 and dismissed the violations of R2 and R3. The violation of R4 did not pose a serious or substantial threat to reliability of the bulk power system because the contractor had conducted pre-employment background checks, had activities in place to protect customer system information, and had training related to cyber security. Finding: The NERC Registered Entity mitigated the violation by conducting background and identity verification checks on all employees with authorized cyber or authorized unescorted physical access to Critical Cyber Assets and preparing employee release forms to execute the seven-year background checks.

Complete the document entitled NERC Cyber Security Standards” and include it with your Proposal - Attachment - NERC A. If awarded a contract, as a result of this RFP, you will be required to perform the required background checks and training, for all employees who will be performing this work or have access to protected documents.

https://scholar.harvard.edu/jsinger/blog/hud-guidance-discriminatory-refusals-rent-tenants-criminal-records

https://repository.law.umich.edu/cgi/viewcontent.cgi?article=1080&context=mjrl

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