Purpose
The purpose of Policy Notification (PN)-106R1 is to notify all Acquisitions Program (AP) procurement officers of key policy changes to the Contract Security Program that affect the procurement process.
Effective date
This PN-106R1 is effective May 2, 2022.
Overview
This PN replaces PN-106 in its entirety.
Organization Security Screenings
To increase its performance and improve the delivery of its services, the Contract Security Program (CSP) is refocusing its security screening activities on active participants in a procurement process. These changes are necessary to better integrate contract security requirements in the procurement life-cycle and to prioritize security screening activities when they are actually required.
Previously, Government of Canada approved sources could sponsor any private sector organization to be registered and screened through the CSP without participation in a solicitation process. Due to the large volume of such broad sponsorship requests, the CSP faced delays in conducting organization and personnel security screenings. In order to increase the efficiency of CSP’s program delivery, going forward all requests for security screenings will need to be associated with a CSP signed and approved SRCL form. This will allow the CSP to allocate its resources on security screening activities that are required as part of active procurement processes.
In the case of contracts awarded through a competitive process, government departments will no longer be required to fill out the Request for Private Sector Organization Screening (PSOS) form (PWGSC-TPSGC 186) to sponsor suppliers for registration into the CSP. Instead, for solicitations with security screening requirements posted on or after May 2, 2022, contracting officers must include the CSP Application for Registration (AFR) form (PWGSC-TPSGC 471)
with bid solicitation documents. Suppliers wishing to bid on a solicitation will be required to complete and submit the AFR form with their bid. If suppliers do not provide all the required information at bid closing, they will be given the opportunity to complete any missing information within a period set by the contracting officer. Suppliers already registered in the CSP that are bidding on a new procurement with security requirements must also complete the AFR form even if they already hold the necessary organization security clearance. The new process also applies to new Requests for Standing Offers and Requests for Supply Arrangements posted on or after May 2, 2022.
Once completed bid packages have been received, contracting officers must submit the following information to the CSP for processing at tpsgc.ssiinscription-issregistration.pwgsc@tpsgc-pwgsc.gc.ca:
- A bid submission cover sheet (PWGSC-TPSGC 470);
- A CSP-approved Security Requirements Check List (SRCL) for the solicitation/contract; and
- Application for Registration (AFR) forms (PWGSC-TPSGC 471) completed by each bidder.
Foreign bidders should complete the Initial International Security Screening (IISS) form, instead of an AFR. Otherwise the process for foreign suppliers is the same as for domestic suppliers.
In the case of sole source procurements, contracting officers must collect the AFR from the proposed supplier and submit it and a CSP-approved SRCL to the CSP.
The CSP will keep procurement officers informed of the progress of the screening process by copying them on their emails exchange with the suppliers. Once the screening process is complete, the CSP will inform the contracting officer of the results of the screening in advance of contract award.
In cases where supplier personnel need security clearance to access sensitive information or assets for the purpose of preparing bids, on request, the CSP may grant a provisional security clearance to eligible bidders and their respective bid preparation teams. Once granted, these provisional security clearances will be valid for the duration of the bid solicitation stage only.
At its discretion, the CSP may make exceptions to the new process for sponsorships to support ministerial mandate and budget commitments. Currently, this includes sponsorship requests for Indigenous businesses and suppliers interested in participating in social procurement opportunities. In such cases, contracting officers will be required to submit a Private Sector Organization Screening (PSOS) request form along with a director level approved valid justification to the CSP at tpsgc.ssiinscription-issregistration.pwgsc@tpsgc-pwgsc.gc.ca.
Finally, as an interim measure, for suppliers already part of existing Standing Offers or Supply Arrangements (SOSAs) with security requirements, the CSP will continue to process PSOS request forms submitted on their behalf on an as-needed basis. This means that there will be no changes at this time to the security clearance process for suppliers participating in existing SOSAs. Further guidance on how the new CSP security clearance process will be applied to SOSAs in the future will be distributed to contracting officers at a later date.
The Contract Security Program and Contract Security Manual
On November 12, 2020, the CSP published the first version of the Contract Security Manual (CSM). The legacy Industrial Security Manual (ISM) was re-written into the CSM to ensure that private sector organizations could better understand security and related requirements in government contracting.
In the Supply Manual and the Standard Acquisition Clauses and Conditions (SACC) Manual, all previous references to the ISM have been changed to the CSM and all prior references to the Canadian Industrial Security Directorate (CISD) have been changed to the Contract Security Program (CSP).
Foreign Ownership, Control or Influence
This PN also contains updates to the policy requirements regarding Foreign Ownership, Control or Influence (FOCI). A FOCI evaluation must be completed in all situations where a third-party individual, firm, or government is assumed to possess dominance of, or authority over, a Canadian facility to such a degree that a third-party individual, firm or government may gain unauthorized access to extremely sensitive information or assets. A FOCI evaluation is an administrative determination of the nature and extent of foreign dominance over the contractor’s management and/or operations. Espionage of industrial and commercial secrets is a serious threat to Canada’s economic, defence and political interests and those of its allies.
Revisions to the Supply Manual
The Supply Manual has been revised to reflect this PN. For more details, refer to the Affected Supply Manual sections listed below.
Revisions to the Standards Acquisitions Clauses and Conditions (SACC) Manual
The SACC Manual has been revised to reflect this PN. For more details, refer to the Affected SACC Manual sections listed below.
Revisions to the Standard Procurement Templates
The Standard Procurement Templates have been revised on GCPedia.
Contact Information
For general inquiries regarding the changes to the contract security screening process, please refer to CSP’s Q&A document. If your questions are not addressed in the Q&A document, you may contact the Contract Security Program’s Client Service Centre for assistance.
Questions regarding to the Supply Manual can be sent by email to:
tpsgc.paspspublications-apspspublications.pwgsc@tpsgc-pwgsc.gc.ca.
Questions regarding the SACC Manual and Standard Procurement Templates may be sent to:
tpsgc.outilsdapprovisionnement-procurementtools.pwgsc@tpsgc-pwgsc.gc.ca.