Human Capital or Human Resources on board employees into the organization. This has been a practice for years and works very well. Part of onboarding should include verification of eligibility to work as well as execution of a background check.
With cleared defense contractors, FSOs should be incorporated into the onboarding process. The FSO role is to either grant access to already cleared personnel, initiate background investigations for those not already cleared, and prepare employees to execute on classified contracts.
In many organizations, HR and FSOs might be the same person or share the same office. In this case, the onboarding process for cleared employees may not be an issue as the employees are either the same or shared.
In larger organizations, the FSO and HR may be separated by distance, offices or other circumstances. However, they should be working together from onboarding to termination of cleared employees. Here are some important things to consider:
- If HR only uses I9 for employment eligibility, which does not determine citizenship, just eligibility to work.
- FSOs must ensure U.S. citizenship, which requires passport, birth certificate and or citizenship documents such as naturalization forms, therefore should be part of the on boarding process. Where I9 requires driver’s license or SSN, be sure to check citizenship
- FSOs must ensure cleared employees remain eligible. This may require involving HR in policymaking and documentation of employee non-compliance
- FSOs must debrief employees when access is no longer required, therefore should be part of the off boarding process
As your company grows, consider ensuring your FSO is part of the growth and has the opportunity to execute their requirements to demonstrate NISPOM compliance.