ITSD-03

UNCLASSIFIED
Directive
for the
Control of COMSEC Material
in the
Government of Canada
ITSD-03
October 2011

UNCLASSIFIED
Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
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October 2011

UNCLASSIFIED
Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
Foreword
The Directive for the Control of COMSEC Material in the Government of Canada is an
unclassified publication issued under the authority of the Chief, Communications Security
Establishment Canada (CSEC) in accordance with the Policy on Government Security.
This directive takes effect on the date of signature and supersedes the COMSEC Material
Control Manual (ITSG-10) dated July 2006.
CSEC will issue appropriate direction, as required, to notify users of changes to this directive.
General inquiries and suggestions for amendments must be forwarded through departmental
COMSEC channels to COMSEC Client Services at CSEC by e-mail at
comsecclientservices@cse-cst.gc.ca or call (613) 991-8495.
____________________________________________________
Toni Moffa
Deputy Chief, Information Technology Security
October 31, 2011
______________________________
Date
© Government of Canada, Communications Security Establishment Canada, 2011
It is permissible to reproduce or make extracts from this publication provided it is used for
Government of Canada departmental use. Reproduction of multiple copies of this publication for
the purpose of commercial redistribution is prohibited except with written permission from the
Government of Canada’s copyright administrator, Public Works and Government Services
Canada.
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Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
Record of Amendments
Amendment No. Date Authority
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Table of Contents
Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
Foreword ......................................................................................................................... i
Record of Amendments ............................................................................................... iii
List of Tables ............................................................................................................... xv
List of Figures ............................................................................................................. xv
List of Abbreviations and Acronyms ....................................................................... xvii
1 Introduction ........................................................................................................... 1
1.1 Purpose ....................................................................................................... 1
1.2 Authority ..................................................................................................... 1
1.3 Scope ........................................................................................................... 1
1.4 Definitions ................................................................................................... 1
1.5 Application .................................................................................................. 2
1.6 Compliance ................................................................................................. 2
1.7 Expected Results ........................................................................................ 3
1.8 Consequence .............................................................................................. 3
1.9 Requests for Exceptions ........................................................................... 3
1.10 Points of Contact ........................................................................................ 3
1.11 COMSEC User Portal .................................................................................. 4
1.12 Communications Security Establishment Canada – Web Site ............... 4
2 National COMSEC Material Control System ....................................................... 5
2.1 Structure and Organization Overview ...................................................... 5
2.2 National Central Office of Record ............................................................. 6
2.2.1 Overview ............................................................................................ 6
2.2.2 Registration Authority ........................................................................ 6
2.2.3 COMSEC Account Manager .............................................................. 6
2.2.4 Key Processor Privilege Certificate Manager ..................................... 7
2.3 Central Office of Record ............................................................................ 7
2.4 National Distribution Authority ................................................................. 7
2.5 COMSEC Accounts .................................................................................... 8
2.6 COMSEC Sub-Accounts ............................................................................ 8
2.7 Local Elements ........................................................................................... 9
3 Personnel ............................................................................................................. 11
3.1 Roles and Responsibilities ...................................................................... 11
3.1.1 Deputy Head .................................................................................... 11
3.1.2 Departmental Security Officer .......................................................... 11
3.1.3 Departmental COMSEC Authority ................................................... 11
3.1.4 COMSEC Custodian ........................................................................ 12
3.1.5 Alternate COMSEC Custodian ......................................................... 12
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3.1.6 COMSEC Sub-Account Custodian .................................................. 12
3.1.7 Alternate COMSEC Sub-Account Custodian ................................... 12
3.1.8 Local Element .................................................................................. 12
3.1.9 Controlling Authority ........................................................................ 13
3.1.10 Other Authorized Users ................................................................... 13
3.1.11 Key Ordering Personnel ................................................................... 13
3.1.12 Witness ............................................................................................ 14
3.2 Personnel Selection and Training ........................................................... 14
3.2.1 Selection of COMSEC Custodians/Alternate COMSEC
Custodians, COMSEC Sub-Account Custodians/Alternate
COMSEC Sub-Account Custodians ................................................. 14
3.2.2 COMSEC Training ........................................................................... 14
4 Management of COMSEC Accounts .................................................................. 17
4.1 Establish COMSEC Account .................................................................... 17
4.1.1 Request Establishment of COMSEC Account ................................. 17
4.1.2 Approve Establishment of COMSEC Account ................................. 17
4.1.3 Establish COMSEC Sub-Accounts .................................................. 18
4.1.4 Register Local Elements .................................................................. 18
4.2 Establish COMSEC Account Files and Records .................................... 18
4.2.1 Administrative Files .......................................................................... 18
4.2.2 Accounting Files .............................................................................. 19
4.2.3 Communications Security Establishment Canada-Approved
Accounting Sub-Systems ................................................................. 19
4.2.4 Retention/Disposition of Records and Files ..................................... 19
4.2.5 Classification of Records and Files .................................................. 19
4.2.6 Access to Records and Files ........................................................... 20
4.3 Changes to COMSEC Accounts .............................................................. 20
4.3.1 Changes to COMSEC Account Registration Information ................. 20
4.3.2 Changes to the COMSEC Signing Authority Form
(CSEC/CSTC-599) .......................................................................... 20
4.3.3 Change of Personnel ....................................................................... 20
4.3.4 Scheduling the COMSEC Custodian Changeover ........................... 20
4.3.5 Conversion of a COMSEC Sub-Account to a COMSEC Account .... 21
4.3.6 Change of Classification Level of a COMSEC Account ................... 21
4.3.7 Absence of COMSEC Custodial Staff .............................................. 21
4.4 Closing a COMSEC Account ................................................................... 22
4.5 Closing a COMSEC Sub-Account ........................................................... 22
4.6 Suspension of a COMSEC Account ........................................................ 23
4.6.1 General ............................................................................................ 23
4.6.2 Suspension ...................................................................................... 23
4.6.3 Lifting Suspension ........................................................................... 23
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5 Identification of COMSEC Material .................................................................... 25
5.1 Long Title .................................................................................................. 25
5.2 Short Title .................................................................................................. 25
5.3 Edition ....................................................................................................... 25
5.4 Accounting Number ................................................................................. 25
5.4.1 Assignment of Accounting Number .................................................. 25
5.4.2 Local Accounting Identifier ............................................................... 25
5.4.3 Unique Accounting Numbers for Electronic Key .............................. 26
5.5 Accounting Legend Code ........................................................................ 26
5.5.1 Description ....................................................................................... 26
5.5.2 Entry of COMSEC Material into National COMSEC Material
Control System ................................................................................ 26
5.5.3 Accounting Legend Code 1 COMSEC Material ............................... 26
5.5.4 Accounting Legend Code 2 COMSEC Material ............................... 27
5.5.5 Accounting Legend Code 4 COMSEC Material ............................... 27
5.5.6 Accounting Legend Code 6 COMSEC Material ............................... 27
5.5.7 Accounting Legend Code 7 COMSEC Material ............................... 28
5.6 Types of COMSEC Material...................................................................... 28
5.6.1 Key Material ..................................................................................... 28
5.6.2 COMSEC Equipment ....................................................................... 28
5.6.3 COMSEC Publications ..................................................................... 28
5.7 CRYPTO Marking ...................................................................................... 29
5.8 Controlled Cryptographic Item Marking ................................................. 29
5.9 Classification or Protected Marking ....................................................... 29
6 Accounting Forms, Reports and Notices .......................................................... 31
6.1 COMSEC Material Report ......................................................................... 31
6.2 Local Accounting Records and Logs ..................................................... 31
6.2.1 Handling Instructions/Disposition Record Card ................................ 31
6.2.2 Local Accounting Logs ..................................................................... 31
6.3 COMSEC Material Reports ....................................................................... 32
6.3.1 Preparation and Distribution of COMSEC Material Reports ............. 32
6.3.2 Transfer Report ................................................................................ 32
6.3.3 Hand Receipt ................................................................................... 33
6.3.4 Possession Report ........................................................................... 35
6.3.5 Key Generation Report .................................................................... 36
6.3.6 Conversion Report ........................................................................... 37
6.3.7 Relief from Accountability Report ..................................................... 37
6.3.8 Destruction Report ........................................................................... 38
6.3.9 Consolidated Destruction Report ..................................................... 38
6.3.10 Inventory Report .............................................................................. 40
6.4 Accounting Notices .................................................................................. 41
6.4.1 Tracer Notice – Transfers ................................................................ 41
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6.4.2 Tracer Action by the COMSEC Custodian ....................................... 41
6.4.3 Tracer Action by National Central Office of Record/Central Office
of Record ......................................................................................... 42
7 Special Accounting Requirements .................................................................... 43
7.1 Drop Accounting of North Atlantic Treaty Organization and
International COMSEC Material .............................................................. 43
7.1.1 General Requirement ...................................................................... 43
7.1.2 North Atlantic Treaty Organization Funded Units ............................. 43
7.1.3 North Atlantic Treaty Organization COMSEC Material Requiring
Two-Person-Integrity Control ........................................................... 43
7.2 Canadian Controlled COMSEC Material Outside of the National
COMSEC Material Control System .......................................................... 43
7.3 Criteria for Release of COMSEC Material to the Private Sector ........... 44
7.4 Government Furnished Equipment ......................................................... 44
7.4.1 Government Furnished Equipment for Canadian Industry ............... 44
7.4.2 Government Furnished Equipment for Allied Contractors ................ 45
7.5 COMSEC Material under Contract ........................................................... 45
8 Access to COMSEC Material .............................................................................. 47
8.1 Prerequisite for Access to COMSEC Material ........................................ 47
8.1.1 Access by Government of Canada Employees and Contractors ..... 47
8.1.2 Access by Foreign Nationals ........................................................... 47
8.2 COMSEC Briefing and COMSEC Briefing Certificate ............................ 47
8.2.1 Requirements .................................................................................. 47
8.2.2 Retention of COMSEC Briefing Certificates ..................................... 48
8.2.3 COMSEC Debriefings/Updates ........................................................ 48
8.3 Two Person Integrity ................................................................................ 48
8.4 No Lone Zone ............................................................................................ 48
9 Physical Security ................................................................................................. 49
9.1 COMSEC Facilities ................................................................................... 49
9.1.1 Requirement .................................................................................... 49
9.1.2 Planning and Establishing a COMSEC Facility ................................ 49
9.1.3 Access Controls and Restrictions .................................................... 49
9.1.4 COMSEC Facility Approval .............................................................. 50
9.2 Secure Storage ......................................................................................... 51
9.2.1 Security Containers ......................................................................... 51
9.2.2 Segregation of COMSEC Material in Storage .................................. 51
9.2.3 Opening of Security Containers in Emergency Situations ................ 51
9.2.4 Incidents Involving Security Containers ........................................... 52
9.2.5 Protecting Lock Combinations and Lock Keys ................................. 52
9.3 Storage of Physical Key Material ............................................................ 54
9.3.1 Storage Requirements ..................................................................... 54
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9.3.2 Key Material Held in Reserve .......................................................... 54
9.4 Storage of Electronic Key Material ......................................................... 56
9.5 Storage of COMSEC Equipment .............................................................. 56
9.5.1 General Requirement ...................................................................... 56
9.5.2 Preparation for Storage ................................................................... 56
9.5.3 Spare or Standby Equipment ........................................................... 56
9.6 Storage of COMSEC Publications ........................................................... 56
10 Distribution and Receipt of COMSEC Material ................................................. 57
10.1 Distributing COMSEC Material ................................................................ 57
10.2 Distributing Electronic Key on Magnetic or Optical Media ................... 58
10.3 Tracking the Shipment of COMSEC Material ......................................... 59
10.4 Packaging Physical COMSEC Material ................................................... 59
10.4.1 Overview .......................................................................................... 59
10.4.2 Inner Wrapping ................................................................................ 59
10.4.3 Outer Wrapping ............................................................................... 60
10.4.4 Types of Packaging ......................................................................... 60
10.4.5 Wooden Crates or Transit Cases ..................................................... 61
10.5 Authorized Modes of Transportation ...................................................... 61
10.5.1 Overview .......................................................................................... 61
10.5.2 North Atlantic Treaty Organization and Foreign COMSEC Material 62
10.6 Authorized Couriers of COMSEC Material ............................................. 64
10.6.1 Canadian Government Diplomatic Courier Service ......................... 64
10.6.2 Authorized Departmental Couriers ................................................... 64
10.6.3 Contractor’s Authorized Couriers ..................................................... 65
10.6.4 Commercial Carriers ........................................................................ 65
10.7 Receiving COMSEC Material ................................................................... 66
10.7.1 Preparation before Receiving COMSEC Material ............................ 66
10.7.2 Inspection of Packages .................................................................... 67
10.7.3 Validation of Content ....................................................................... 67
11 Handling and Use ................................................................................................ 69
11.1 Accountable Key Material ........................................................................ 69
11.1.1 Purpose and Use ............................................................................. 69
11.1.2 Labels .............................................................................................. 69
11.1.3 Protective Packaging ....................................................................... 69
11.1.4 Key Tape in Canisters...................................................................... 69
11.1.5 Electronic Key Material on Magnetic or Optical Media ..................... 70
11.1.6 Electronic Key on a Key Storage Device ......................................... 70
11.1.7 Copies of Key .................................................................................. 70
11.1.8 Two Person Integrity Controls .......................................................... 71
11.2 Accountable COMSEC Equipment .......................................................... 71
11.2.1 Sight Verification .............................................................................. 71
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11.2.2 Equipment Labels ............................................................................ 71
11.2.3 Modification ...................................................................................... 72
11.2.4 Equipment Installed for Operational Use ......................................... 72
11.2.5 Key Storage/Fill Equipment Containing Key Material....................... 72
11.2.6 Equipment Audit Trails ..................................................................... 72
11.3 Accountable COMSEC Publications ....................................................... 73
11.3.1 Reproduction ................................................................................... 73
11.3.2 Frequency of Page Checks .............................................................. 73
11.3.3 Conducting Page Checks ................................................................ 74
11.3.4 Amendments to Accountable COMSEC Publications ...................... 74
11.4 Local Tracking of Other Associated Material ......................................... 76
11.4.1 Local Tracking System..................................................................... 76
11.4.2 Control and Protection of Crypto Ignition Keys ................................ 76
11.4.3 Record of Personal Identification Numbers and Passwords ............ 76
11.4.4 Change of Personal Identification Numbers and Passwords ........... 77
11.4.5 Storage of Personal Identification Numbers and Passwords ........... 77
11.4.6 Configuration Disks .......................................................................... 77
11.4.7 Software Upgrades .......................................................................... 77
12 Destruction/Disposal of Accountable COMSEC Material ................................ 79
12.1 General Requirement ............................................................................... 79
12.2 Destruction of Key Material ..................................................................... 79
12.2.1 Scheduling Destruction of Key Material ........................................... 79
12.2.2 Unavailability of Destruction Devices ............................................... 79
12.2.3 Conditions Affecting Destruction of Key Material ............................. 79
12.2.4 Key Material Issued for Use ............................................................. 79
12.2.5 Sealed Key Material ......................................................................... 80
12.2.6 Emergency Supersession ................................................................ 80
12.2.7 Defective Key Material ..................................................................... 80
12.3 Destruction/Disposal of COMSEC Equipment ....................................... 81
12.4 Destruction of COMSEC Publications .................................................... 81
12.5 Performing Routine Destruction ............................................................. 81
12.5.1 Personnel ......................................................................................... 81
12.5.2 Training ............................................................................................ 82
12.5.3 Performing Physical Destruction ...................................................... 82
12.6 Routine Destruction Methods .................................................................. 83
12.6.1 Paper COMSEC Material ................................................................. 83
12.6.2 Non-Paper COMSEC Material ......................................................... 84
12.7 Approved Routine Destruction Devices ................................................. 85
12.8 Emergency Destruction Priorities ........................................................... 85
12.8.1 Priorities within Categories .............................................................. 85
12.8.2 Priorities for Combined Categories .................................................. 87
12.9 Emergency Destruction Methods ............................................................ 87
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12.10 Reporting Emergency Destruction ......................................................... 87
13 COMSEC Account Inventory .............................................................................. 89
13.1 Reasons for Inventory .............................................................................. 89
13.2 Types of Inventory .................................................................................... 89
13.2.1 Annual Inventory .............................................................................. 89
13.2.2 Change of COMSEC Custodian Inventory ....................................... 89
13.2.3 Special Inventory ............................................................................. 90
13.3 Inventory Reports ..................................................................................... 90
13.3.1 National Central Office of Record/Central Office of Record-
Initiated Inventory Report ................................................................. 90
13.3.2 COMSEC Account Inventory Report ................................................ 90
13.3.3 Amendment to Inventory Report ...................................................... 91
13.4 Inventory Process .................................................................................... 91
13.4.1 Scheduling the Sight Inventory ........................................................ 91
13.4.2 Conducting the Sight Inventory ........................................................ 92
13.4.3 Reconciling the COMSEC Account Inventory Report ...................... 92
14 COMSEC Emergency Plan .................................................................................. 95
14.1 Preparing the COMSEC Emergency Plan ............................................... 95
14.1.1 Requirement .................................................................................... 95
14.1.2 Development of the Plan .................................................................. 95
14.1.3 Maintaining and Testing the Plan ..................................................... 95
14.1.4 Emergency Destruction Plan ........................................................... 95
14.2 Planning for Emergency Events .............................................................. 96
14.2.1 Best Practices .................................................................................. 96
14.2.2 Natural Disasters and Accidental Emergencies ............................... 96
14.2.3 Hostile Activity ................................................................................. 97
15 COMSEC Account Audit ..................................................................................... 99
15.1 Planning the Audit .................................................................................... 99
15.1.1 Delegation of Authority..................................................................... 99
15.1.2 Purpose of an Audit ......................................................................... 99
15.1.3 Frequency of Audits ......................................................................... 99
15.1.4 Scheduling the Audit ........................................................................ 99
15.2 Conducting the Audit ............................................................................. 100
15.2.1 Access to COMSEC Account Holdings .......................................... 100
15.2.2 Scope of the Audit ......................................................................... 100
15.2.3 Exit Interview ................................................................................. 100
15.3 Audit Reporting ...................................................................................... 101
15.3.1 COMSEC Account Audit Report .................................................... 101
15.3.2 Statement of Action Form .............................................................. 101
15.3.3 Failure to Return a Statement of Action Form ................................ 101
15.4 COMSEC Sub-Account Audits .............................................................. 101
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15.4.1 Requirement .................................................................................. 101
15.4.2 Communications Security Establishment Canada Participation ..... 101
16 COMSEC Incidents ............................................................................................ 103
16.1 General .................................................................................................... 103
16.2 Classes of COMSEC Incidents .............................................................. 103
16.2.1 Compromising Incidents ................................................................ 103
16.2.2 Practices Dangerous to Security .................................................... 103
16.3 Categories of COMSEC Incidents ......................................................... 104
16.3.1 Cryptographic Incidents ................................................................. 104
16.3.2 Personnel Incidents ....................................................................... 105
16.3.3 Physical Incidents .......................................................................... 106
16.4 Handling of Incidents ............................................................................. 107
16.4.1 Departmental Procedures .............................................................. 107
16.4.2 COMSEC Custodian Responsibility ............................................... 107
16.4.3 Departmental COMSEC Authority Responsibility .......................... 107
16.4.4 Reporting COMSEC Incidents ....................................................... 108
16.5 Recovery of COMSEC Material .............................................................. 109
16.6 Post-Incident Evaluation ........................................................................ 109
16.7 COMSEC Incidents Involving North Atlantic Treaty Organization
COMSEC Material ................................................................................... 110
16.8 COMSEC Incidents Involving In-Process COMSEC Material .............. 110
16.9 Disciplinary Action ................................................................................. 110
Glossary ..................................................................................................................... 111
Bibliography .............................................................................................................. 125
Annex A – Control of In-Process COMSEC Material .............................................. 127
A.1 Introduction ............................................................................................ 127
A.1.1 Purpose ......................................................................................... 127
A.1.2 Scope............................................................................................. 127
A.1.3 Content of Annex ........................................................................... 127
A.2 In-Process Plan ....................................................................................... 128
A.2.1 Content of the In-Process Plan ...................................................... 128
A.2.2 Approval of an In-Process Plan ..................................................... 129
A.2.3 Approving Authority ....................................................................... 129
A.2.4 Changes to an In-Process Plan ..................................................... 129
A.3 Accounting for In-Process COMSEC Material...................................... 131
A.3.1 Automated In-Process Accounting System .................................... 131
A.3.2 In-Process Accounting Records ..................................................... 131
A.3.3 Reconciliation of In-Process Accounting Records ......................... 132
A.3.4 In-Process Accounting Reports ..................................................... 132
A.3.5 Retention and Disposition of In-Process Records and Reports ..... 135
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A.3.6 Audit of In-Process COMSEC Accounts ........................................ 135
A.4 Control of In-Process COMSEC Equipment ......................................... 135
A.4.1 Integrated Circuits .......................................................................... 135
A.4.2 Controlled Cryptographic Items ..................................................... 136
A.4.3 Breakage, Waste and Scrap In-Process COMSEC Material .......... 139
A.4.4 Loss of In-Process COMSEC Material ........................................... 140
A.5 COMSEC Equipment under Repair and Maintenance Contract .......... 140
A.5.1 Transfer to/from the Contractor ...................................................... 140
A.5.2 Accountability within the Repair and Maintenance In-Process
Facility ............................................................................................ 140
A.5.3 Sources of Spare COMSEC Parts, Components and Assemblies . 140
A.5.4 Non-Serviceable In-Process Parts, Components and Assemblies 141
A.5.5 Non-repairable COMSEC Equipment ............................................ 142
A.6 Accountable COMSEC Publications under Development ................... 142
A.6.1 In-Process Manuscripts ................................................................. 142
A.6.2 Working Papers ............................................................................. 142
A.6.3 Release of In-Process Manuscripts before Government of
Canada Acceptance ...................................................................... 142
A.6.4 Government of Canada Acceptance of a Final Manuscript ............ 144
A.6.5 Destruction of In-Process Manuscripts .......................................... 144
A.7 Accountable COMSEC Publications under Reproduction or
Translation Contract .............................................................................. 145
A.7.1 In-Process Manuscripts ................................................................. 145
A.7.2 COMSEC Publications Controlled within the National COMSEC
Material Control System................................................................. 145
A.7.3 Destruction of In-Process Material Surplus to Contract
Requirement .................................................................................. 145
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List of Tables
Table 1 – Contact Information ......................................................................................... 3
Table 2 – Key Material Held in Reserve ........................................................................ 54
Table 3 – Storage of Physical Key Material ................................................................... 55
Table 4 – Authorized Modes of Transportation for COMSEC Material .......................... 63
Table 5 – Approval of IP Plans .................................................................................... 129
Table 6 – Labelling CCI ............................................................................................... 139
List of Figures
Figure 1 – National COMSEC Material Control System (NCMCS).................................. 5
Figure 2 – Example of Magnetic or Optical Media Label ............................................... 59
Figure 3 – IP Hand Receipt Required Information ....................................................... 134
Figure 4 – Return of Issued IP COMSEC Material ...................................................... 134
Figure 5 – IP COMSEC Material Label ........................................................................ 144
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List of Figures

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List of Figures

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List of Abbreviations and Acronyms
ACM
ACMCA
ALC
CA
CARDS
CCD
CCF
CCI
CD
CFCSU
CICA
CIK
CKL
CMAC
COMSEC
COR
CSC
CSEC
CSO
CUP
DCA
DDSM
DIAS
DND
DSC
DSO
DVD
EKMS
FAA
FOUO
FSC
FSU
GC
GFE
HI/DR
IC
ICMCM
ID
Accountable COMSEC Material
Accountable COMSEC Material Control Agreement
Accounting Legend Code
Controlling Authority
COMSEC Accounting, Reporting and Distribution System
Canadian Cryptographic Doctrine
Canadian Central Facility
Controlled Cryptographic Item
Compact Disk
Canadian Forces COMSEC Support Unit
CSEC Industrial COMSEC Account
Crypto-Ignition Key
Compromise Key List
Crypto Material Assistance Centre
Communications Security
Central Office of Record
COMSEC Safeguarding Capability
Communications Security Establishment Canada
Company Security Officer
COMSEC User Portal
Departmental COMSEC Authority
Directive on Department Security Management
Distributed INFOSEC Accounting System
Department of National Defence
Document Safeguarding Capability
Departmental Security Officer
Digital Versatile Disk
Electronic Key Management System
Financial Administration Act
For Official Use Only
Facility Security Clearance
Field Software Upgrade
Government of Canada
Government Furnished Equipment
Handling Instructions/Disposition Record
Integrated Circuit
Industrial COMSEC Material Control Manual
Identifier
List of Abbreviations and October 2011 xvii
Acronyms

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Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
IP
INFOSEC
ISDN
IT
ITS AFU
ITSA
ITSB
ITSD
ITSLC
KEK
KMID
KMSP
KP
MOA
MOU
NATO
NCER
NCIO
NCMCS
NCOR
NDA
NLZ
NSA
ORR
PDS
PGS
PIN
PSTN
PWA
PWGSC
R&M
SCIP
SDNS
SKCR
SPIRS
T3MD
TBS
TEK
TPI
TRA
In-Process
Information Security
Integrated Services Digital Network
Information Technology
Information Technology Security Approvals for Use
Information Technology Security Alert
Information Technology Security Bulletin
Information Technology Security Directive
Information Technology Security Learning Centre
Key Encryption Key
Key Material Identifier
Key Material Support Plan
Key Processor
Memorandum of Agreement
Memorandum of Understanding
North Atlantic Treaty Organization
National Cryptographic Equipment Reserve
National COMSEC Incidents Office
National COMSEC Material Control System
National Central Office of Record
National Distribution Authority
No Lone Zone
National Security Agency
Operational Rekey Report
Practices Dangerous to Security
Policy on Government Security
Personal Identification Number
Public Switched Telephone Network
Printed Wiring Assembly
Public Works and Government Services Canada
Repair and Maintenance
Secure Communications Interoperability Protocol
Secure Data Network System
Seed Key Conversion Report
SDNS PSTN-ISDN Rekey Subsystem
Tier 3 Management Device
Treasury Board of Canada Secretariat
Traffic Encryption Key
Two-Person Integrity
Threat and Risk Assessment
xviii October 2011 List of Abbreviations and
Acronyms

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U//FOUO
U.K.
U.S.
Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
Unclassified//For Official Use Only
United Kingdom
United States
List of Abbreviations and October 2011 xix
Acronyms

UNCLASSIFIED
1 Introduction
1.1 Purpose
Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
This directive provides the minimum security requirements for the control of accountable
Communications Security (COMSEC) material in the Government of Canada (GC).
1.2 Authority
This directive is promulgated pursuant to the Policy on Government Security (PGS), which
delegates Communications Security Establishment Canada (CSEC) as the lead security agency
and national authority for the development, approval and promulgation of COMSEC policy
instruments and for the development of guidelines and tools related to Information
Technology (IT) Security.
1.3 Scope
The methods for the control of COMSEC material vary and are determined by the nature of the
material itself. The scope of this directive includes:
COMSEC material, which requires control and accountability within the National
COMSEC Material Control System (NCMCS);
COMSEC material under development, which requires local accounting and control
within an In-Process (IP) accounting system as detailed in Annex A; and
COMSEC material (other than above), which requires control and local tracking by the
COMSEC Custodian through a manual or electronic tracking system outside of the
NCMCS.
1.4 Definitions
COMSEC – The application of cryptographic security, transmission and emission
security, physical security measures, operational practices and controls to deny
unauthorized access to information derived from telecommunications and that ensure the
authenticity of such telecommunications.
COMSEC Material – Material designed to secure or authenticate telecommunications
information. COMSEC material includes, but is not limited to, key, equipment, modules,
devices, documents, hardware, firmware or software that embodies or describes
cryptographic logic and other items that perform COMSEC functions.
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Accountable COMSEC Material (ACM) – COMSEC material that requires control and
accountability within the National COMSEC Material Control System (NCMCS) in
accordance with its accounting legend code and for which transfer or disclosure could be
detrimental to the national security of Canada.
NCMCS – A CSEC-approved, central logistic system through which COMSEC material,
including COMSEC material marked “CRYPTO” is distributed, controlled and
safeguarded.
Refer to the Glossary for additional definitions of terms used in this directive.
1.5 Application
This directive applies to:
GC departments within the meaning of Schedules I, I.1, II, IV and V of the Financial
Administration Act (FAA), unless excluded by specific acts, regulations or Orders in
Council;
GC departments not listed in the above mentioned FAA Schedules, but that have entered
into a written agreement with the Treasury Board of Canada Secretariat (TBS) to adopt
the requirements of the PGS. A copy of the agreement must be maintained in the CSEC
National Central Office of Record (NCOR) chronological files; and
Private Sector companies and organizations managing COMSEC material under the
direction of the Industrial COMSEC Material Control Manual (ICMCM). If a situation
arises that is not covered by the ICMCM, or a discrepancy arises between it and the
content of this directive, ITSD-03 takes precedence.
NOTE: For the purpose of this directive, the term ‘GC departments’ includes all federal
institutions (e.g. departments, agencies, organizations) subject to the FAA and PGS.
1.6 Compliance
All GC departments identified in Article 1.5 must comply with the baseline security
requirements of the Directives for the Application of Communications Security in the
Government of Canada (ITSD-01) and this directive. While compliance with these minimum
security requirements is the responsibility of each GC department, this does not preclude
individual departments from applying more stringent security measures. Departmental directives
that exceed the minimum security requirements of ITSD-03 take precedence within that
department.
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1.7 Expected Results
Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
This directive describes courses of action which CSEC has determined are required to achieve a
minimum level of control, safeguard and accounting for COMSEC material in departmental
communications operations.
1.8 Consequence
Failure to comply with this directive may result in escalated administrative controls being placed
on a COMSEC Account. In extreme circumstances, a COMSEC Account will be suspended until
an external audit is conducted and the Departmental Security Officer (DSO) or DSO-delegated
Departmental COMSEC Authority (DCA) has rectified any shortcomings.
1.9 Requests for Exceptions
Requests for exceptions or waivers to any of the direction contained herein must be submitted to
COMSEC Client Services at CSEC. Requests must be submitted in writing and include
justification. CSEC approval is required before implementing any exception or waiver.
NOTE: Exceptions or waivers are designed to be remedial and of limited duration.
1.10 Points of Contact
The CSEC points of contact for topics covered by this directive are listed in Table 1 below.
Table 1 – Contact Information
Office Phone Number E-mail Address
COMSEC Client Services 613-991-8495 comsecclientservices@cse-cst.gc.ca
Crypto Material Assistance Centre
(CMAC)
and
National Central Office of Record
(NCOR)
National COMSEC Incidents
Office (NCIO)
613-991-8600 cmac-camc@cse-cst.gc.ca
613-991-8175 ncio@cse-cst.gc.ca
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1.11 COMSEC User Portal
Authorized users may access the CSEC COMSEC User Portal (CUP) at http://comsecportal.csecst.gc.ca.
The CSEC CUP provides COMSEC-related information and Field Software Upgrades
(FSUs), up to PROTECTED A, associated with high assurance products, systems and services.
For information on becoming an authorized user of the CSEC CUP, contact the CMAC at CSEC.
1.12 Communications Security Establishment Canada – Web Site
Other COMSEC directives and information (UNCLASSIFIED only) associated with high
assurance products, systems and services are available at http://www.cse-cst.gc.ca/itssti/publications/index-eng.html.
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2 National COMSEC Material Control System
2.1 Structure and Organization Overview
The NCMCS is a CSEC-approved logistics system which includes the personnel and procedures
that enable GC departments to effectively handle and control COMSEC material. The NCMCS
provides for the control of COMSEC material through:
National Central Office of Record (NCOR)
Central Office of Record (COR)
National Distribution Authority (NDA)
COMSEC Accounts
COMSEC Sub-Accounts, and
Local Elements (formerly referred to as Loan Holders or Authorized Users).
National Central
Office of
Record (NCOR)
National Distribution
Authority (NDA)
GC Department
COMSEC Accounts
CSEC Industrial
COMSEC Account
(CICA)
Department of National
Defence (DND)
Central Office of Record
(COR)
Local
Elements
COMSEC
Sub-accounts
COMSEC
Sub-accounts
DND
COMSEC Accounts
Local
Elements
COMSEC
Sub-accounts
Local
Elements
Local
Elements
Figure 1 – National COMSEC Material Control System (NCMCS)
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2.2 National Central Office of Record
2.2.1 Overview
NCOR is the entity at CSEC which is responsible for overseeing the management and
accounting of COMSEC material produced in, or entrusted to Canada. NCOR is not a COMSEC
Account and never holds COMSEC material. NCOR responsibilities include the three distinct
roles of Registration Authority, COMSEC Account Manager and Key Processor (KP) Privilege
Certificate Manager. These roles are administered by the CMAC.
2.2.2 Registration Authority
As the national Registration Authority for GC COMSEC Accounts, NCOR personnel:
manage the block of Electronic Key Management System (EKMS) Identifiers (IDs)
(i.e. COMSEC Account numbers) used in Canada;
register NCOR with allied COMSEC material control systems;
participate in the opening and closing of COMSEC Accounts for the GC;
temporarily deactivate COMSEC Accounts for GC departments;
confirm the appointment or termination of appointment of the DCA, COMSEC Custodian
and Alternate COMSEC Custodian(s);
assign a unique EKMS ID to each COMSEC Account;
collect and maintain account registration data in the EKMS Directory Service;
provide registration data to COMSEC Accounts that do not have access to the EKMS
Directory Service; and
register COMSEC Accounts with allied COMSEC material control systems when those
accounts are authorized to exchange COMSEC material with allied countries.
2.2.3 COMSEC Account Manager
As COMSEC Account Manager, NCOR personnel:
maintain a master inventory of all centrally accountable COMSEC material for those
COMSEC Accounts under their purview;
process COMSEC Material Reports, including validation of signature(s) against signature
specimens;
perform annual inventory reconciliations with COMSEC Accounts under his or her
purview;
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monitor the effective dates of key material to ensure key material is destroyed and
reported as destroyed in a timely manner;
support the evaluation and recovery from compromise or potential compromise of
COMSEC material; and
liaise with COMSEC Account personnel and provide guidance and assistance on all
COMSEC accounting matters.
2.2.4 Key Processor Privilege Certificate Manager
As the KP Privilege Certificate Manager, NCOR personnel:
accept and validate requests for KP Privilege Certificates;
create, sign and distribute KP Privilege Certificates; and
maintain configuration control of KP Privilege Certificates.
2.3 Central Office of Record
A COR is an entity within a GC department, which is responsible for overseeing the
management and accounting of COMSEC material held by COMSEC Accounts subject to its
oversight. NCOR will establish a COR in a GC department upon approval from COMSEC Client
Services at CSEC that sufficient justification for a COR exists. A COR can only be established
by receiving delegated authorities from the NCOR to administer the regulatory processes of this
directive within its own department.
NOTE: CSEC has established the Department of National Defence (DND) Canadian Forces
COMSEC Support Unit (CFCSU) as a COR. Throughout this directive, the combined
term NCOR/COR will mean NCOR (or COR if applicable).
2.4 National Distribution Authority
The NDA is the entity at CSEC responsible for the movement (receipt and distribution) of ACM
in and out of the country. It is also responsible for:
storing a limited amount of ACM for eventual distribution;
storing contingency key material, in the event of system failure;
holding the National Cryptographic Equipment Reserve (NCER);
receiving ACM for disposal or out-of-country repair or transfer;
receiving and redistributing allied ACM;
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receiving damaged or defective ACM being returned to CSEC for technical evaluation;
and
generating and distributing electronic key, as required.
2.5 COMSEC Accounts
GC departments must establish a COMSEC Account before receiving COMSEC material.
Normally, only one COMSEC Account is established at each GC department. However, if
sufficient justification exists, COMSEC Client Services at CSEC may approve the establishment
of additional COMSEC Account(s) within a GC department. COMSEC Accounts may establish
COMSEC Sub-Accounts and may register Local Elements. Each COMSEC Account is assigned
by NCOR/COR a unique EKMS ID.
The minimum COMSEC Account personnel requirements include:
a DCA
a COMSEC Custodian, and
at least one Alternate COMSEC Custodian.
NOTE 1: For COMSEC Accounts requiring Two-Person Integrity (TPI) or No Lone Zone
(NLZ) controls, more than one Alternate COMSEC Custodian is recommended.
NOTE 2: Refer to Chapter 3 for requirements applicable to personnel roles and responsibilities
and Chapter 4 for information on establishing COMSEC Accounts.
2.6 COMSEC Sub-Accounts
GC departments may establish COMSEC Sub-Accounts to assist with the control of COMSEC
material. The COMSEC Sub-Account:
will be assigned a unique EKMS ID by the parent COMSEC Account Custodian;
must have a COMSEC Sub-Account Custodian and at least one Alternate COMSEC
Sub-Account Custodian;
must exchange COMSEC material and accounting transactions only with its own GC
parent COMSEC Account;
must not hold COMSEC material to which the parent COMSEC Account cannot have
access;
must register Local Elements; and
must not establish transactions with other COMSEC Sub-Accounts.
NOTE: CSEC is responsible for establishing COMSEC Sub-Accounts within the private
sector.
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2.7 Local Elements
Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
Local Elements are individuals who are authorized to hold and use COMSEC material. Local
Elements do not have their own EKMS ID. They share the EKMS ID of the COMSEC Account
or COMSEC Sub-Account at which they are registered. Local Elements are authorized to
exchange COMSEC material only with the COMSEC Account or COMSEC Sub-Account at
which they are registered. Local Elements are not authorized to re-loan COMSEC material to
other Local Elements except through their own COMSEC Account Custodian or COMSEC Sub-
Account Custodian.
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3 Personnel
Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
3.1 Roles and Responsibilities
All COMSEC Account personnel and other personnel requiring access to COMSEC material
must be Canadian citizens (including dual nationality) (see Article 3.2.1, Article 6.3.3.4 and
Chapter 8 for additional detail). Except for private sector COMSEC Sub-Accounts, COMSEC
Account personnel must be an employee of the GC department registered to the COMSEC
Account.
3.1.1 Deputy Head
Deputy Heads of GC departments are responsible for implementing this directive.
3.1.2 Departmental Security Officer
The DSO is appointed by the department Deputy Head. Among other duties, as listed in the PGS,
the DSO is responsible to manage the departmental security program. For more detail on the
roles and responsibilities of the DSO, consult the Directive on Department Security Management
(DDSM).
3.1.3 Departmental COMSEC Authority
A DCA may be appointed by the DSO to act in his/her stead to manage the departmental
COMSEC program. The DCA is responsible for developing, implementing, maintaining,
coordinating and monitoring a departmental COMSEC program that is consistent with the PGS
and its operational standards. Additionally, the DCA is responsible for the overall control of
COMSEC material that has been charged to the departmental COMSEC Account. Refer to the
DCA Quick Reference Guide for an overview of the DCA responsibilities associated with the
control of COMSEC material.
NOTE: In departments where a DCA is not appointed, the DSO must assume the role and
responsibilities of the DCA.
3.1.3.1 Separation of Duties
The DCA, or any other individual within the GC department fulfilling the role of the DCA, may
not be appointed as a COMSEC Custodian, Alternate COMSEC Custodian, COMSEC Sub-
Account Custodian or Alternate COMSEC Sub-Account Custodian.
COMSEC Custodian personnel must not be designated to more than one COMSEC Account or
COMSEC Sub-Account at the same time.
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3.1.4 COMSEC Custodian
COMSEC Custodians are responsible for the generation, receipt, custody, distribution,
disposition or destruction, and accounting of COMSEC material entrusted to their COMSEC
Account or Sub-Account in accordance with this directive. COMSEC Custodians are also
responsible for providing their departmental users with COMSEC equipment troubleshooting
support and guidance on the use of key material. Refer to the COMSEC Custodian Quick
Reference Guide for an overview of the COMSEC Custodian responsibilities.
3.1.5 Alternate COMSEC Custodian
The Alternate COMSEC Custodian assists the COMSEC Custodian in the day-to-day activities
of the COMSEC Account or Sub-Account and performs the duties of the COMSEC Custodian in
the temporary absence of the COMSEC Custodian. Refer also to the same COMSEC Custodian
Quick Reference Guide mentioned in Article 3.1.4.
3.1.6 COMSEC Sub-Account Custodian
COMSEC Sub-Account Custodians are responsible for the generation, receipt, custody,
distribution, disposition or destruction, and accounting of COMSEC material entrusted to their
COMSEC Sub-Account in accordance with this directive. COMSEC Sub-Account Custodians
are also responsible for providing their authorized users with COMSEC equipment
troubleshooting support and guidance on the use of key material. Refer also to the same
COMSEC Custodian Quick Reference Guide mentioned in Article 3.1.4.
3.1.7 Alternate COMSEC Sub-Account Custodian
The Alternate COMSEC Sub-Account Custodian assists the COMSEC Sub-Account Custodian
in the day-to-day activities of the COMSEC Sub-Account and performs the duties of the
COMSEC Sub-Account Custodian in the temporary absence of the COMSEC Sub-Account
Custodian. Refer also to the same COMSEC Custodian Quick Reference Guide mentioned in
Article 3.1.4.
3.1.8 Local Element
A Local Element is an individual who is authorized to hold and use COMSEC material. A Local
Element is personally responsible for the control, safeguarding and disposition of COMSEC
material entrusted to he or she, in accordance with the control and handling instructions provided
by their COMSEC Account or Sub-Account Custodian.
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3.1.9 Controlling Authority
Controlling Authorities (CAs) must be appointed by the DCA to establish and maintain order,
supervise cryptographic logistics and respond to security issues affecting a cryptographic
network (cryptonet) that has been established to protect the electronic communication of
classified and PROTECTED C information.
All cryptonets require an appointed CA to manage the operational use of the key material
assigned to the cryptonet and to develop a Key Material Support Plan (KMSP) before it can be
given authority to operate. Refer to the Directive for the Use of CSEC-Approved COMSEC
Equipment and Key on a Telecommunications Network (ITSD-04) for complete detail on the
responsibilities of the CA and how to prepare a KMSP.
3.1.10 Other Authorized Users
In certain instances, individuals such as shift workers and technicians may require short term
(immediate) access to COMSEC material. Before allowing this access, the individual who is
personally responsible for the COMSEC material must confirm with the DCA, COMSEC
Custodian or COMSEC Sub-Account Custodian that the user requiring access:
is a Canadian citizen (including dual nationality);
has a need-to-know, has been COMSEC briefed and possesses the required security
clearance or reliability status;
signs for and maintains constant personal surveillance of the COMSEC material until it is
returned (refer to Article 6.2);
does not store the COMSEC material and returns it for lock-up when not under positive
personal possession;
does not transport the COMSEC material to another work area or building without
consent; and
understands what constitutes a COMSEC incident or potential COMSEC incident.
3.1.11 Key Ordering Personnel
The DCA is responsible to appoint key ordering personnel and establish their privileges to
submit orders for key material. In addition to their regular responsibilities, COMSEC custodial
staff can also be appointed to handle key ordering responsibilities.
NOTE: Refer to the Cryptographic Key Ordering Manual (ITSG-13) for key ordering
requirements.
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3.1.12 Witness
Sight inventory of COMSEC material and most types of destruction (see Article 12.5.1.3) must
be witnessed. The witness would normally be an Alternate COMSEC Custodian; however,
another appropriately cleared and COMSEC briefed individual may act as a witness when an
Alternate COMSEC Custodian is not available. The COMSEC Custodian (or other personnel)
who asks an individual to serve as a witness must ensure that the individual is fully conversant
with the responsibilities of being a witness. The witness must not sign any documentation
without having personally sighted the COMSEC material being inventoried or destroyed.
3.2 Personnel Selection and Training
3.2.1 Selection of COMSEC Custodians/Alternate COMSEC Custodians,
COMSEC Sub-Account Custodians/Alternate COMSEC Sub-Account
Custodians
The DCA must carefully screen individuals who have been selected to become a COMSEC
Custodian, Alternate COMSEC Custodian, COMSEC Sub-Account Custodian or Alternate
COMSEC Sub-Account Custodian to ensure that each proposed individual:
is a Canadian citizen (including dual nationality);
possesses a security clearance at least equal to the highest sensitivity of the COMSEC
material held in the COMSEC Account;
is a responsible individual who is qualified to assume the duties and responsibilities of
COMSEC Custodian, Alternate COMSEC Custodian, COMSEC Sub-Account Custodian
or Alternate COMSEC Sub-Account Custodian;
is in a position or level of authority which would permit the individual to exercise proper
jurisdiction in fulfilling the responsibilities of the position;
has not previously been relieved of COMSEC Custodian, Alternate COMSEC Custodian,
COMSEC Sub-Account Custodian or Alternate COMSEC Sub-Account Custodian duties
for reasons of negligence or non-performance of duties; and
will not be assigned duties that would interfere or conflict with the duties as COMSEC
Custodian, Alternate COMSEC Custodian, COMSEC Sub-Account Custodian or
Alternate COMSEC Sub-Account Custodian.
3.2.2 COMSEC Training
3.2.2.1 General
Appointments of COMSEC Account personnel in Article 3.2.1 require that each appointee have
completed CSEC-approved training before starting the role or as soon as possible (next available
course) following the appointment.
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NOTE: Training can be delayed only in extenuating circumstances (e.g. no formal course
available prior to appointment). If training has to be delayed, COMSEC Client
Services should be contacted for additional instruction.
3.2.2.2 Schedules and Registration
Course schedules and registration information are available from the IT Security Learning
Centre (ITSLC), at CSEC.
NOTE 1: Personnel attending courses requiring access to ACM will be COMSEC briefed by
ITSLC staff at the outset of the course.
NOTE 2: Due to technological, procedural and standards advances, former COMSEC staffs,
who have not performed COMSEC related duties for more than two years, must
attend formal COMSEC training.
3.2.2.3 Formal COMSEC Custodian Course
COMSEC Custodians require formal training. The DCA must ensure that each new COMSEC
Custodian and Alternate COMSEC Custodian attends the formal COMSEC Custodian course
before or as soon as possible following the appointment. Other departmental personnel who use
or are responsible for the control of COMSEC material may also attend this course.
3.2.2.4 Interim COMSEC Custodian Training
Where formal training is unavailable prior to appointment or when a new COMSEC Custodian
or Alternate COMSEC Custodian is unable to attend, due to extenuating circumstances, the
formal COMSEC Custodian training course before the appointment, the DCA or the COMSEC
Custodian, as applicable, must provide interim training. If interim training cannot be provided,
contact NCOR to arrange for interim training assistance.
3.2.2.5 COMSEC Accounting System Training
Before installing CSEC-approved accounting software packages, COMSEC Custodians and
Alternate COMSEC Custodians must attend formal training. Other COMSEC Account personnel
may also attend this course.
3.2.2.6 COMSEC Equipment Training
Before using COMSEC equipment and to the extent possible, COMSEC Custodians and
Alternate COMSEC Custodians should attend formal COMSEC equipment training courses.
Local Elements may also attend these courses.
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3.2.2.7 Other Training Courses
CSEC offers additional training courses that will assist COMSEC Account personnel in the use
and protection of COMSEC material or increase their knowledge on the basic concepts of
IT security and cryptography.
3.2.2.8 COMSEC Sub-Account and Local Element Training
COMSEC Custodians are normally responsible for training their COMSEC Sub-Account
personnel and Local Elements. However, COMSEC Sub-Account personnel and Local Elements
may attend the formal COMSEC Custodian training course provided by CSEC.
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4 Management of COMSEC Accounts
4.1 Establish COMSEC Account
4.1.1 Request Establishment of COMSEC Account
GC departments requiring COMSEC material must submit a request to COMSEC Client
Services at CSEC for the establishment of a COMSEC Account. The request must include:
a letter containing –
o justification for the requirement to hold COMSEC material
o interoperability (beyond department) requirements
o highest security classification of the COMSEC material, and
o statement that the minimum physical security standards of this directive can be met
for the highest level of sensitivity of COMSEC material to be held; and
the following forms –
o Account Registration, to identify the department, location and COMSEC custodial
staff being appointed
o Appointment Certificate, for each individual to be appointed to the COMSEC
Account, including the DCA, the COMSEC Custodian and at least one Alternate
COMSEC Custodian, and
o COMSEC Signing Authority Form, also called the COMSEC Courier Certificate, to
provide records of COMSEC Account personnel or any additional departmental staff
who are authorized to receive and sign for COMSEC material. Only COMSEC
Custodial staff members are authorized to open parcels and sign COMSEC material
reports.
4.1.2 Approve Establishment of COMSEC Account
Before validating a request to open a COMSEC Account, a CSEC representative(s) will visit the
GC department to verify that the physical security requirements of this directive (refer to
Chapter 9) can be met and that COMSEC Account personnel have been COMSEC briefed.
Following validation of the request, NCOR/COR will provide written approval for the request
including:
the assigned EKMS ID
confirmation of the name of the DCA
verification of the appointment of the COMSEC Custodian and the Alternate COMSEC
Custodian(s), and
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a list of publications required to effectively manage the COMSEC Account.
4.1.3 Establish COMSEC Sub-Accounts
The DCA may establish COMSEC Sub-Accounts to assist with the control of COMSEC material
within the department. The DCA must implement procedures for opening a departmental
COMSEC Sub-Account based upon the direction contained herein.
4.1.4 Register Local Elements
COMSEC Custodians and COMSEC Sub-Account Custodians must register Local Elements
before authorizing their access to or use of COMSEC material (refer to Article 6.3.3.4). The
registration of Local Elements must include at a minimum a record of the full name, title or
designator, location and phone number.
4.2 Establish COMSEC Account Files and Records
4.2.1 Administrative Files
The COMSEC Custodian must establish and maintain administrative files containing
documentation related to the COMSEC Account, including:
courier, mail and package receipts
correspondence
IT Security Alerts (ITSA)
IT Security Bulletins (ITSB)
IT Security Approvals for Use (ITS AFU)
Account Registration Forms
Appointment Certificates
Security Screening Certificates
COMSEC Briefing Certificates
COMSEC Signing Authority Forms
COMSEC Incident Initial Reports
COMSEC Account Audit Reports
related files for each COMSEC Sub-Account (if applicable), and
other relevant documentation.
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4.2.2 Accounting Files
The COMSEC Custodian must establish and maintain accounting files (paper or electronic as is
appropriate for the authorized accounting system being employed) that include:
a copy of all accounting reports (see Chapter 6), records, registers and logs with
appropriate physical or digital signatures;
a copy of all inventory reports (see Chapter 13); and
IP accounting records (if applicable).
4.2.3 Communications Security Establishment Canada-Approved Accounting
Sub-Systems
CSEC has approved the use of several automated accounting/management systems to
accommodate the minimum security requirements of the NCMCS. These systems employ
terminology and procedures that are quite distinct from each other. Each department is
responsible for ensuring that its custodial personnel are trained in the use of its CSEC-approved
automated system and are familiar with the terms used by the respective software to describe the
NCMCS activities detailed in this directive. Manual inventory systems (e.g. CSEC 417 cards)
must not be the sole mechanism used by COMSEC Accounts for managing COMSEC Account
inventories. Contact COMSEC Client Services at CSEC for list of approved systems or for
requests for approval of new systems.
The NCMCS and supporting sub-systems must be classified minimally to PROTECTED A with
additional appropriate classification to meet special inventory requirements (see Article 4.2.5)
and any other classified information stored on the system.
4.2.4 Retention/Disposition of Records and Files
All inactive or archived COMSEC Account records and files must be retained for a period of no
less than five years by the COMSEC Custodian (or responsible DCA), after which they may be
destroyed or forwarded to NCOR/COR for disposal.
4.2.5 Classification of Records and Files
COMSEC Account records and files must be marked “PROTECTED A” unless they contain:
classified information (e.g. effective dates, classified long titles or remarks), in which case
it must be marked in accordance with the sensitivity of the content; or
a list containing COMSEC material that was provided by a United Kingdom (U.K.)
source, in which case the list must be classified at least to the minimum standard that the
U.K. is handling the material.
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NOTE:
Contact NCOR/COR if assistance is required in properly classifying these
records, files and reports.
4.2.6 Access to Records and Files
The COMSEC Custodian must limit access to COMSEC Account records and files to individuals
who have a need-to-know and possess the appropriate security clearance or reliability status.
Access to COMSEC Account records and files by individuals other than the COMSEC
Custodian or Alternate COMSEC Custodian must be closely monitored.
4.3 Changes to COMSEC Accounts
4.3.1 Changes to COMSEC Account Registration Information
COMSEC Custodians must promptly post changes to COMSEC Account registration
information (e.g. mailing and shipping addresses, phone numbers) to the Directory Server or
submit them to NCOR/COR. The Account Registration form is to be used to submit these
changes.
4.3.2 Changes to the COMSEC Signing Authority Form (CSEC/CSTC-599)
The COMSEC Custodian must submit a new COMSEC Signing Authority Form to NCOR/COR
annually and whenever there is a change of personnel or other information. The COMSEC
Signing Authority Form contains the names, telephone numbers and signatures of COMSEC
Account personnel and any additional departmental staff who are authorized to sign for
shipments containing COMSEC material.
4.3.3 Change of Personnel
Before the departure of currently appointed COMSEC Account personnel, the DCA must
provide NCOR/COR with an Appointment Certificate, including:
the new COMSEC Account personnel information completed; and
the “Termination of Appointment” section completed for the individual being replaced.
The DCA or COMSEC Custodian, as applicable, must ensure the new appointee receives a
COMSEC briefing.
4.3.4 Scheduling the COMSEC Custodian Changeover
The changeover of COMSEC Custodians should be scheduled at least 40 calendar days in
advance of the COMSEC Custodian’s departure date. The current COMSEC Custodian and the
individual being appointed as the new COMSEC Custodian must conduct an inventory of the
COMSEC material held in the COMSEC Account as detailed in Chapter 13 of this directive.
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The departing COMSEC Custodian is not relieved of responsibility for COMSEC material
involved in any unresolved discrepancy until all discrepancies are resolved.
4.3.5 Conversion of a COMSEC Sub-Account to a COMSEC Account
The DCA must submit a letter to COMSEC Client Services at CSEC requesting the
establishment of new COMSEC Account in accordance with Article 4.1.1. The letter must
contain justification for the conversion of the COMSEC Sub-Account to a COMSEC Account.
Upon approval of the conversion, NCOR/COR will provide accounting instructions.
4.3.6 Change of Classification Level of a COMSEC Account
The DCA must submit a written request to COMSEC Client Services at CSEC requesting a
change in the level of classification for the COMSEC Account. The request must include a
justification for the requirement and indicate the new level of classification requested.
When requesting a lower level of classification, COMSEC Client Services will provide written
approval once NCOR/COR has confirmed that the COMSEC Account holds COMSEC material
at, or lower than, the requested classification.
When requesting to upgrade the classification level of a COMSEC Account, COMSEC Client
Services will provide written approval once a CSEC representative has visited the COMSEC
Account to verify that the physical security requirements of this directive can be met. The
COMSEC Account must not receive COMSEC material at the higher level until approval of the
change of classification level has been granted.
4.3.7 Absence of COMSEC Custodial Staff
4.3.7.1 Temporary Absence of COMSEC Custodian
In the absence of the COMSEC Custodian for a period of 60 calendar days or less, the DCA
must ensure the Alternate COMSEC Custodian assumes the responsibilities and duties of the
COMSEC Custodian.
4.3.7.2 Temporary Absence of Alternate COMSEC Custodian
In the absence of the Alternate COMSEC Custodian for a period of 60 calendar days or less, the
DCA must ensure the second Alternate COMSEC Custodian assumes the responsibilities and
duties. Where no second Alternate COMSEC Custodian has been appointed, the DCA must
appoint one.
4.3.7.3 Absence Longer then 60 Calendar Days
An absence of more than 60 calendar days must be treated as a permanent absence, and the DCA
must appoint a new COMSEC Custodian or Alternate COMSEC Custodian, as applicable.
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4.3.7.4 Unexplainable Departure of COMSEC Custodian or Alternate COMSEC
Custodian
In the case of an unexplainable (does not include death, serious illness, short notice personnel
transfer) sudden, indefinite or permanent departure of the COMSEC Custodian or Alternate
COMSEC Custodian, the DCA must take the following steps:
a. Immediately report the circumstances of any departure in accordance with Chapter 16 of
this directive.
b. Appoint a new COMSEC Custodian or Alternate COMSEC Custodian as required.
c. Ensure the combinations and the keys of containers and vaults are changed.
d. Ensure the new COMSEC Custodian or Alternate COMSEC Custodian immediately
conducts an inventory (see Chapter 13) with an appropriately cleared witness,.
e. Ensure the COMSEC Account audit is conducted by the appropriate authority.
4.4 Closing a COMSEC Account
When a COMSEC Account no longer has a requirement to hold COMSEC material, the DCA
must provide COMSEC Client Services at CSEC with a written request to close the COMSEC
Account and must include Termination Certificates for all COMSEC Account personnel.
The COMSEC Custodian will transfer all ACM currently held in the COMSEC Account to
another COMSEC Account, or destroy it (if authorized), and forward all accounting reports as
well as a signed “zero balance” inventory to NCOR/COR.
Once NCOR/COR has confirmed receipt of the Termination Certificates, confirmed that the
COMSEC Account no longer holds any COMSEC material and has updated the COMSEC
Account status in the EKMS Directory Server to “closed”, COMSEC Client Services at CSEC
will issue a letter to the DCA, officially closing the COMSEC Account.
The DSO will ensure that all COMSEC Account files are retained for a period of five years and
then dispose of them in accordance with the direction at Article 4.2.4.
4.5 Closing a COMSEC Sub-Account
When it is determined that the requirement for a COMSEC Sub-Account no longer exists, the
DCA must take the following steps:
a. Direct the COMSEC Sub-Account Custodian to return to the parent COMSEC Account, or
destroy (if authorized), all COMSEC material held by the COMSEC Sub-Account and
submit a signed “zero balance” Inventory Report (refer to Chapter 13).
b. Provide the parent COMSEC Account with a Termination Certificate for all COMSEC
Sub-Account personnel.
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4.6 Suspension of a COMSEC Account
4.6.1 General
COMSEC Accounts are audited at least once every 18 months (refer to Article 15.4.1). In rare
cases, due to the severity of account infraction(s) or the effect that poor account management
could have on other government departments or allies, NCOR/COR, in consultation with the
DSO, may authorize the DCA to temporarily suspend a COMSEC Account. NCOR/COR may also
initiate an account suspension. A COMSEC Account may be suspended if:
the DCA fails to take action to correct serious deficiencies reported in the COMSEC
Account Audit Report or fails to submit a Statement of Action form showing that
corrective action is underway; or
the number of security violations or reporting and management practices at the account
demonstrates a continued disregard for COMSEC policy and procedures.
NOTE: Any suspension, regardless of how temporary, may severely impact the COMSEC
Account activities.
4.6.2 Suspension
A COMSEC Account whose status is “suspended” will cease to have COMSEC material
transferred in or transferred out. The custodial staff will remain in place to conduct all other
normal activities within the account, including the corrective action that would lead to the lifting
of the suspension.
NOTE: NCOR/COR will inform the DSO, the DCA and the Departmental COMSEC
Custodian that, transfers to and from the account will be suspended. The notification
will include a list of the discrepancies that caused the suspension, the corrective action
needed to allow the lifting of the suspension and a target completion date.
4.6.3 Lifting Suspension
Upon receipt of the Statement of Action form, which certifies that corrective action has been
completed (or is underway), CSEC may lift the suspension. Before lifting the suspension, CSEC
will conduct another audit of the account to ensure that conditions have been rectified.
Upon lifting the suspension, NCOR/COR will notify other affiliated or affected organizations or
accounts, and transfers of COMSEC material to and from the account will resume.
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5 Identification of COMSEC Material
5.1 Long Title
The long title provides a general description of the COMSEC material. In some cases, long titles
may be classified.
5.2 Short Title
A short title must be assigned to COMSEC material at its point of origin for accounting
purposes. The short title is an identifying combination of letters or digits that consists of a
maximum of 24 alphanumeric characters. For some CSEC-approved accounting/management
systems (see Article 4.2.3), special characters (e.g. /, -, * or #) are not allowed. For these
systems, the special characters that may appear on ACM short titles, COMSEC equipment
nameplates and COMSEC publications are replaced with a space. The individual short titles of
COMSEC material are UNCLASSIFIED. For further details on short titles, refer to the Short
Title Nomenclature in Canada (ITSG-09) 1 .
5.3 Edition
COMSEC material may be identified by a unique alphabetic or numeric designator. COMSEC
material may be time sensitive and is superseded when the next edition becomes effective. Refer
to ITSG-13 for more information on editions.
5.4 Accounting Number
5.4.1 Assignment of Accounting Number
COMSEC material may be assigned a unique accounting serial or register number at the point of
origin to facilitate accounting (see Article 5.5 for a description of the relationship between
accounting numbers and the ALC). Serial numbers are used with CCI and COMSEC equipment,
while register numbers are used for any other material requiring an accounting number.
5.4.2 Local Accounting Identifier
The COMSEC Custodian may assign a local accounting identifier to COMSEC material that is
accounted for by quantity. This local accounting identifier must not be used as an accounting
number on a COMSEC Material Report. It may be entered in the remarks column of the
COMSEC Material Report.
1 ITSG-09 is available upon request through COMSEC Client Services at CSEC.
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5.4.3 Unique Accounting Numbers for Electronic Key
Unique accounting numbers for electronic key are not required when:
all copies of the key within a particular short title and edition are the same;
each copy can be individually controlled without the use of a unique accounting number;
or
the CA for the short title has determined that the key does not need to be copy-controlled
through the use of unique accounting numbers.
5.5 Accounting Legend Code
5.5.1 Description
The ALC is a numeric code assigned by the originator of the COMSEC material to indicate its
accounting and reporting requirements. The ALC is recorded on all COMSEC Material Reports
but does not normally appear on the COMSEC material itself. The ALC assigned by the
originator must not be changed without authorization from COMSEC Client Services at CSEC.
Authorized changes to ALCs must be managed through NCOR/COR, as noted in Chapter 6.
NOTE 1: If the accountability of the COMSEC material is in question, contact NCOR/COR.
NOTE 2: ALC 3 and ALC 5 are no longer used.
5.5.2 Entry of COMSEC Material into National COMSEC Material Control System
Whenever COMSEC material is assigned an ALC, it must be entered into the NCMCS. This
COMSEC material must be controlled in the NCMCS until it is authorized for destruction or
other disposition, or the appropriate authority removes the accountability requirement. A
COMSEC Material Report is used to enter COMSEC material into the NCMCS in circumstances
described at Article 6.3.4.
5.5.3 Accounting Legend Code 1 COMSEC Material
ALC 1 is assigned to physical COMSEC material that is subject to continuous accountability to
NCOR/COR by short title and accounting number. ALC 1 COMSEC material will include:
some unclassified and all classified physical key material marked CRYPTO;
all cryptographic equipment approved for classified processing;
CCI;
classified cryptographic software and firmware that are the functional equivalents of, or
emulate, COMSEC equipment operations and cryptography; and
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Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
classified full maintenance manuals and depot maintenance manuals (and their printed
amendments), which contain crypto-information.
5.5.4 Accounting Legend Code 2 COMSEC Material
ALC 2 is assigned to physical COMSEC material that is subject to continuous accountability to
NCOR/COR by short title and quantity. ALC 2 COMSEC material may include:
classified and CCI components (e.g. modular assemblies, printed wiring
assemblies [PWA], integrated circuits [IC], microcircuits, microchips, permuters)
intended for installation (but not installed) in COMSEC equipment;
specific COMSEC devices; and
COMSEC publications.
5.5.5 Accounting Legend Code 4 COMSEC Material
ALC 4 is assigned to physical COMSEC material that, following initial receipt to the distributing
COMSEC Account, is locally accountable by the receiving COMSEC Account by short title and
quantity, or by short title and accounting number. ALC 4 COMSEC material may include:
unclassified or classified COMSEC publications dealing with a cryptographic subject
(e.g. classified maintenance manuals);
protected and unclassified key material (e.g. test, maintenance and training key); and
other unclassified or classified COMSEC material which, due to the nature of the
COMSEC information it contains, requires accountability within the NCMCS.
5.5.6 Accounting Legend Code 6 COMSEC Material
ALC 6 is assigned to electronic key tracked by the GC EKMS and is subject to continuous
accountability to NCOR/COR, as determined by the controlling authority for the key and by the
doctrine specific to the equipment, where applicable. ALC 6 may be assigned to electronic key:
intended to protect information having long-term intelligence value (e.g. TOP SECRET);
used to protect other keys (e.g. key encryption key [KEK]);
used for joint or combined interoperability;
marked “CRYPTO”;
used to generate other electronic keys (e.g. key production key); and
generated from ALC 1 physical key material.
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5.5.7 Accounting Legend Code 7 COMSEC Material
ALC 7 is assigned to electronic key tracked by the GC EKMS that is locally accountable to the
generating COMSEC Account until final disposition.
5.6 Types of COMSEC Material
5.6.1 Key Material
The term key material applies to both physical and electronic formats of key. Refer to ITSG-13
for additional information on key material.
5.6.2 COMSEC Equipment
COMSEC equipment is normally identified and accounted for by one short or long title, rather
than by individual components or sub-assemblies. Whenever a component or sub-assembly that
has been assigned an ALC is removed from its host equipment, it requires accountability within
the NCMCS and it must be identified separately by its individual short title. Refer to the
Canadian Cryptographic Doctrine (CCD) series for further information on specific COMSEC
equipment.
5.6.3 COMSEC Publications
COMSEC publications may include:
crypto-maintenance manuals
sensitive pages of a crypto-maintenance manual
cryptographic operating instructions
classified full maintenance manuals
classified depot maintenance manuals
cryptographic logic descriptions
drawings of cryptographic logics
specifications describing a cryptographic logic
other classified cryptographic and non-cryptographic operational publications
replacement pages to the above and like publications, and
extracts, supplements and addenda from accountable COMSEC publications.
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Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
5.7 CRYPTO Marking
The CRYPTO caveat is used to indicate the unique sensitivity of the COMSEC material on
which it appears (or is otherwise identified). Items so marked must always be accounted for
within the NCMCS. The CRYPTO marking will appear in bold letters on classified printed
circuit boards, on the covers of printed key material, on disks, on individual key variables, and
(as required) on equipment and tags or labels affixed to physical storage device (e.g. KSD-64)
containing electronic key.
5.8 Controlled Cryptographic Item Marking
The CCI marking indicates a type of COMSEC equipment that must always be accounted for
and controlled within the NCMCS or within a foreign nation’s formal COMSEC channels. The
CCI category applies to specific unclassified, secure communications and information handling
equipment, as well as associated cryptographic components and assemblies.
In many cases, COMSEC material in the CCI category will not be assigned a short title, but will
instead bear the manufacturer’s commercial designator. This equipment will be marked
“Controlled Cryptographic Item” or “CCI”, and will bear a government serial number label.
Since CCI and associated cryptographic components employ a classified cryptographic logic, it
is only the hardware or firmware embodiment of that logic that is UNCLASSIFIED. The
associated cryptographic engineering drawings, logic descriptions, theory of operation, computer
programs, and related cryptographic information remain classified.
5.9 Classification or Protected Marking
COMSEC material may be marked or otherwise identified with a classification or protected level
at the time it is created to indicate its storage and handling requirements. Operational key
material is classified or protected at the sensitivity level of the information that it is intended to
protect.
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6 Accounting Forms, Reports and Notices
6.1 COMSEC Material Report
The primary accounting form used for the control of COMSEC material is the multipurpose
COMSEC Material Report (commonly referred to as the GC-223 form). This form is used to:
report the change in the status of COMSEC material (e.g. transfer, issue, possession,
generation, conversion, relief from accountability or destruction);
report the inventory holdings of a COMSEC Account (i.e. Inventory Report); and
provide notice of an action associated with COMSEC material (e.g. Tracer Notice).
6.2 Local Accounting Records and Logs
6.2.1 Handling Instructions/Disposition Record Card
The HI/DR card is used to record the issue and destruction of individual segments of an edition
of key tape. The HI/DR card is to be stored with its associated canister until all segments have
been issued and destroyed. Before issuing a canister of key tape, the COMSEC Custodian must
enter the short title and its attributes on the HI/DR card. The HI/DR card is UNCLASSIFIED,
but becomes CONFIDENTIAL once an entry is made. The individual and witness who perform
the destruction of key tape segments must both initial or sign the HI/DR card beside the entry
corresponding to the segment that was destroyed. The COMSEC Custodian must review each
HI/DR card to confirm the destruction of each key tape segment before using the record to
prepare a Consolidated Destruction Report.
6.2.2 Local Accounting Logs
When the distribution or re-distribution of COMSEC material or other material specified in
equipment doctrine can not be automatically tracked, the COMSEC Custodian must establish a
manual accounting system to locally control and account for this material. The Crypto-Ignition
Key (CIK) CIK Local Accounting Log is used to record the creation and distribution of locally
accountable CIKs. The COMSEC Material Local Accounting Register may be used for local
tracking of redistributed material. See specific system or equipment CCD for additional detail.
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6.3 COMSEC Material Reports
6.3.1 Preparation and Distribution of COMSEC Material Reports
General instructions for the preparation of COMSEC Material Reports can be found with the
GC-223 form. The following articles list the specific requirements applicable to the preparation
and distribution of each type of report. Refer to the Glossary for definitions of each type of
COMSEC Material Reports.
6.3.2 Transfer Report
6.3.2.1 General
The distribution of COMSEC material between two COMSEC Accounts is called a transfer.
COMSEC material being transferred must be prepared and receipted for as detailed in
Chapter 10. The COMSEC Custodian who originates the transfer of COMSEC material remains
accountable for the material until the signed receipt is returned to the originating COMSEC
Account.
Approval from the appropriate CA must be granted before COMSEC material is transferred.
Whenever the transfer of COMSEC material is required for operational or contingency purposes,
appropriate authorities will notify the affected COMSEC Custodians.
COMSEC Client Services at CSEC are required to approve all transfers of COMSEC material by
methods not pre-authorized in accordance with Article 10.5 and Table 4.
6.3.2.2 Distribution
The following applies to the distribution of Transfer Reports:
Along with the original, prepare sufficient copies of the Transfer Report to ensure
effective accountability –
o Enclose the original with physical shipment.
o If the report lists centrally-accountable COMSEC material, send a copy to
NCOR/COR of the receiving COMSEC Account (COMSEC Accounts using an
automated CSEC-approved accounting system will send an electronically-signed
copy to NCOR/COR).
o Retain a copy of the original on file until it can be replaced with a receipt signed by
the recipient COMSEC Custodian.
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When a receipt for a Transfer Report cannot be provided, the Transfer Report must be
cancelled. For example, if a removable data storage device (e.g. floppy disk, compact
disk, flash drive) containing the transaction was destroyed in-transit, or if physical
COMSEC material being transferred is destroyed in-transit, or if a Transfer Report was
prepared and circumstances cancelled the need for the COMSEC material to be
distributed, the destination COMSEC Account Custodian would not return a receipt for
the material. The Transfer Report may be cancelled by –
o preparing a Cancel Distribution Transaction, and forwarding a copy to the intended
recipient COMSEC Account and NCOR/COR; or
o marking the Transfer Report as cancelled and forwarding a copy to the intended
recipient COMSEC Account and NCOR/COR.
6.3.2.3 Receipt
To relieve the shipping COMSEC Account from accountability for the transferred material, the
receiving COMSEC Custodian must sign the Transfer Report, make copies and distribute them
according to the following:
Return the signed original to the shipping COMSEC Custodian.
If the report lists centrally-accountable COMSEC material, send a copy to NCOR/COR
(COMSEC Accounts using an automated CSEC-approved accounting system will send
an electronically-signed copy to NCOR/COR).
Retain a signed copy of the original receipt on file.
6.3.3 Hand Receipt
6.3.3.1 General
The distribution of COMSEC material to a COMSEC Sub-Account or Local Element is called an
issue. COMSEC material being issued may be packaged as a shipment or it may be hand
delivered directly to an authorized recipient. Packages wrapped for shipment must be prepared in
accordance with the direction in Chapter 10.
6.3.3.2 Distribution
The issuance of COMSEC material is recorded on a Hand Receipt. When distributing COMSEC
material to a COMSEC Sub-Account or a Local Element, the COMSEC Custodian must use a
Hand Receipt.
Recipients must sign the Hand Receipt to certify their acceptance of the listed material, as well
as an understanding of the handling requirements for the COMSEC material entrusted to them.
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Before signing the Hand Receipt, the recipient must inspect the COMSEC material to verify the
accuracy of the document and to establish the condition of the material. See Chapter 10.
Control and tracking responsibilities for issued material remains within the COMSEC Account;
therefore, Hand Receipts are not sent to NCOR/COR.
NOTE: Hand Receipts for COMSEC material must be reviewed annually by the COMSEC
Custodian to ensure their accuracy and to verify the continued requirement for ACM
by authorized end-users.
6.3.3.3 Accountability
Accountability for issued COMSEC material includes the issuing COMSEC Account, the
COMSEC Sub-Account (if applicable) and the Local Element. Upon signing the Hand Receipt,
the recipient assumes responsibility for the care and control of all material listed on the
document; however, the recipient’s signature on a Hand Receipt does not relieve the issuing
COMSEC Custodian from accountability for the issued material.
6.3.3.4 Confirmation before Issue
Before issuing COMSEC material to a COMSEC Sub-Account or a Local Element, the
COMSEC Custodian must ensure the recipient:
has a need-to-know for COMSEC material listed on the Hand Receipt;
is a Canadian citizen (including dual nationality);
is cleared to the security level of the COMSEC material listed on the Hand Receipt;
has been COMSEC briefed and has signed a COMSEC Briefing Certificate;
has the appropriate storage facilities for the material listed on the Hand Receipt;
has been trained on the handling, storage, use and destruction (where authorized) of the
COMSEC material listed on the Hand Receipt;
is aware of what constitutes a COMSEC incident;
where necessary, has established a local accounting system that maintains strict control
of each item of the COMSEC material listed on the Hand Receipt whenever it –
o must be accounted for during shift work operations; or
o is temporarily loaned to another authorized user.
signs the Hand Receipt acknowledging the receipt of the material and understanding of
the responsibilities associated with handling the COMSEC material listed on the Hand
Receipt.
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6.3.3.5 Returning COMSEC Material
COMSEC Sub-Accounts and Local Elements must return COMSEC material to the COMSEC
Custodian if it is no longer required and is not authorized for destruction.
COMSEC material issued to a COMSEC Sub-Account must be returned to the parent account
that issued the material. The COMSEC Sub-Account Custodian must prepare a COMSEC
Material Report (annotate the “OTHER” box with “Hand Receipt”) addressed to the parent
account.
Upon receipt and verification of the material, the COMSEC Custodian at the parent account must
sign the COMSEC Material Report and return it to the COMSEC Sub-Account, thereby relieving
the COMSEC Sub-Account from accountability for the returned material.
COMSEC material issued to a Local Element must be returned to the COMSEC Account or
COMSEC Sub-Account that issued the material. The COMSEC Custodian must prepare a Hand
Receipt for material being returned from the Local Element. The COMSEC Custodian must
ensure that the Hand Receipt, which lists the material being returned from the Local Element, is
addressed to the COMSEC Account. The COMSEC Custodian’s signature on the Hand Receipt
relieves the Local Element from accountability for the returned COMSEC material. Local
Elements are not authorized to re-loan COMSEC material to any other Local Elements.
6.3.4 Possession Report
6.3.4.1 General
Occasionally, extraordinary circumstances dictate that COMSEC material, for which a current
record of accountability within the NCMCS does not exist, be taken on charge at a COMSEC
Account.
A Possession Report is used to document the entry of COMSEC material into the NCMCS in the
following circumstances when:
COMSEC material under development or manufacture has been accepted by the GC
(refer to Annex A);
COMSEC material received from a foreign government or international organization
requires accountability within the NCMCS;
COMSEC material previously declared lost and removed from accountability is
subsequently found;
a COMSEC publication requiring control within the NCMCS is reproduced in whole or
in part;
magnetic or optical media is used to transfer or issue electronic key material;
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Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
a non-automated COMSEC Account converts its inventory to an automated CSECapproved
accounting system; and
COMSEC material is in the possession of a COMSEC Account and is not listed on any
other COMSEC Account inventory.
6.3.4.2 Preparation and Distribution
Authorization from NCOR/COR, is required before submitting a Possession Report. A
Possession Report may not be created by a COMSEC Sub-Account. The Sub-Account Custodian
must report the requirement to the parent COMSEC Account.
The following applies to the preparation and distribution of Possession Reports:
A brief description of why the item is being possessed must be included in either the
Remarks column or after the “NOTHING FOLLOWS” line.
If the report lists centrally-accountable COMSEC material, a copy must be sent to
NCOR/COR within five working days following the creation of the report. Possession
reports listing only ALC 4 or ALC 7 COMSEC material must be retained locally.
6.3.5 Key Generation Report
6.3.5.1 Privileges
Some automated COMSEC Accounts are granted the privilege of generating electronic keys or
importing physical key material and converting it to electronic form. These privileges are
granted by the Privilege Certificate Manager at NCOR/COR. Whenever an electronic key is
generated at an account, a Generation Report must be raised.
6.3.5.2 Preparation and Distribution
The following applies to the preparation and distribution of Generation Reports:
COMSEC Custodians must submit Generation Reports to NCOR/COR whenever ALC 6
key material is generated. Imported ALC 1 physical key when converted to electronic
form must be reported as ALC 6 key.
COMSEC Custodians must retain copies of Generation Reports on file whenever ALC 7
key material is generated. Imported ALC 4 physical key when converted to electronic
form must be reported as ALC 7 key.
COMSEC Sub-Account Custodians must submit Generation Reports to their parent
COMSEC Account whenever ALC 6 or ALC 7 key material is generated, or when ALC 1
or 4 physical key is imported.
A signed copy of all Generation Reports must be retained on file.
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6.3.6 Conversion Report
6.3.6.1 General
Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
When it becomes necessary to change or correct a short title, an equipment modification number,
or the ALC of ACM, a Conversion Report must be raised. Conversion Reports may be initiated
by a COMSEC Custodian or by NCOR/COR. COMSEC Custodians must not initiate conversion
activities without receiving explicit instructions from NCOR/COR.
A Conversion Report may not be created at a COMSEC Sub-Account. The COMSEC Sub-
Account Custodian must report the requirement to the parent COMSEC Account.
If the automated accounting system in use at the COMSEC Account does not have the capability
to generate a Conversion Report, contact NCOR/COR for instructions.
6.3.6.2 Preparation and Distribution
In the preparation and distribution of Conversion Reports, the COMSEC Custodian:
may raise a Conversion Report only if the material being converted is on-hand at the
COMSEC Account;
must send a copy to NCOR/COR if the Conversion Report lists centrally-accountable
COMSEC material;
must send a copy of the Conversion Report to all COMSEC Sub-Accounts that hold
COMSEC material to be converted; and
must retain a signed copy of the Conversion Report on file.
6.3.7 Relief from Accountability Report
6.3.7.1 General
COMSEC Custodians may seek relief from accountability for COMSEC material that has been
irretrievably lost. Normally, an investigation will be conducted by the DCA to determine the
injury caused by the loss and the NCIO will issue a report on the results of the investigation.
A Relief from Accountability Report is used to document the removal of COMSEC material from
a COMSEC Account inventory. Authorization from the NCIO is required before preparing a
Relief from Accountability Report.
If the automated accounting system in use at the COMSEC Account does not have the capability
to generate a Relief from Accountability Report, contact NCOR/COR for instructions.
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6.3.7.2 Preparation and Distribution
The following rules apply to the preparation and distribution of Relief from Accountability
Reports:
Reference to the authority under which the COMSEC material was removed from
accountability must be included in either the remarks column or after the NOTHING
FOLLOWS line.
If the report lists centrally-accountable COMSEC material, a copy must be sent to
NCOR/COR.
A signed copy of all Relief from Accountability Reports must be retained on file.
6.3.8 Destruction Report
6.3.8.1 General
Cryptographic material must be destroyed after it is superseded. Other COMSEC material may
be authorized for destruction after it has served its intended purpose. A Destruction Report is
used to document the physical destruction or electronic zeroization of COMSEC material,
whether by authorized means or by accident, and serves to report the items’ removal from
accountability (see Chapter 12 for complete destruction instructions).
6.3.8.2 Preparation and Distribution
The following applies to the preparation and distribution of Destruction Reports:
List, in alphanumerical order, all material that is scheduled for destruction.
Enter the reason for the destruction (e.g. zeroized, superseded, filled in equipment
[include the short title and serial number of the equipment], obsolete) in either the
Remarks column or after the “NOTHING FOLLOWS” line.
If the Destruction Report lists centrally-accountable COMSEC material, send a signed
copy to NCOR/COR.
A signed copy of all Destruction Reports must be retained on file.
6.3.9 Consolidated Destruction Report
6.3.9.1 General
Occasionally, COMSEC material (e.g. superseded key) is authorized for destruction by
personnel other than the COMSEC Custodian. Except in tactical situations (operational theatres),
such destructions must be performed in the same secure environment using the same security
procedures required of the COMSEC Custodian.
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Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
In such cases, the appropriate destruction documents, duly signed and witnessed, must be
forwarded to the COMSEC Custodian. The COMSEC Custodian must compile the documents
(e.g. HI/DR card) into a single Consolidated Destruction Report for forwarding to NCOR/COR.
6.3.9.2 Preparation and Distribution
The following applies to the preparation and distribution of Consolidated Destruction Reports:
a. Review local destruction records (e.g. HI/DR card) for accuracy, appropriate
authorizations and required signatures.
b. List the COMSEC material that was destroyed (and reported as destroyed on local
accounting records) during the month.
c. Annotate the report with “Consolidated Destruction Report”.
d. If the report contains centrally-accountable COMSEC material, submit the report to
NCOR/COR no later than the 16 th of the month following destruction of the key material.
e. Retain a copy of all Consolidated Destruction Reports on file.
6.3.9.3 Seed Key Conversion Report
The Canadian Central Facility (CCF) generates a monthly Seed Key Conversion Report (SKCR)
for Secure Communications Interoperability Protocol (SCIP) equipment that lists the Key
Material Identifier (KMID) number of the key that has been converted from seed key to
operational key. When a user initiates a secure call from authorized SCIP equipment to the
Secure Data Network System (SDNS) Public Switched Telephone Network (PSTN)-(Integrated
Services Digital Network (ISDN) Rekey Subsystem (SPIRS), operational key is sent to that
user’s SCIP equipment. Once the operation is completed, the user can use their equipment to
place secure calls to other SCIP users. A copy of the SKCR will be sent to the COMSEC
Account Custodian on a monthly basis or upon request. The COMSEC Custodian must use the
SKCR to verify that a Destruction Report has been completed for all KMIDs listed on the report.
6.3.9.4 Operational Rekey Report
The CCF generates a monthly Operational Rekey Report (ORR) that lists the KMID of keys for
SCIP equipment that were used to place a secure call to the SPIRS. Upon initiation of a secure
call to the SPIRS, a new operational key is downloaded to the SCIP equipment along with a
Compromised Key List (CKL). A copy of the ORR will be sent to the COMSEC Account
Custodian on a monthly basis or upon request. This report must be used to verify that end users
conduct quarterly rekey calls to the SPIRS and ensure that they have the latest CKL. The
COMSEC Custodian must use the ORR to verify that a Destruction Report has been completed
for all KMIDs listed on the report.
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Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
6.3.10 Inventory Report
6.3.10.1 General
COMSEC Custodians are responsible for conducting inventories. During the inventory process,
the COMSEC material held at the COMSEC Account is physically sighted and the actual
holdings are compared to the accounting records. The inventory process is very important as it is
sometimes the only means of discovering the loss of COMSEC material. For a complete
description of inventories, see Chapter 13.
A list of COMSEC Account’s holdings is recorded on an Inventory Report.
6.3.10.2 Preparation and Distribution
The following rules apply to the preparation and distribution of Inventory Reports:
NCOR/COR will prepare, for distribution to each COMSEC Account, a list of all ALC 1,
ALC 2 and ALC 6 COMSEC material held by a COMSEC Account. This list is called an
Inventory Report and contains all the material that the COMSEC Account has reported to
NCOR/COR via various COMSEC Material Reports (e.g. Transfers, Receipts,
Destructions and Possessions).
COMSEC Custodians must prepare an Inventory Report for each Sub-Account and Local
Element. This report must contain all ACM (i.e. ALC 1, ALC 2, ALC 4, ALC 6 and
ALC 7) issued to each element.
Each Local Element must conduct a physical sighting of COMSEC material in his or her
possession, annotate the Inventory Report as required, sign and have someone else
witness and sign the report, and then return the completed report to the COMSEC
Custodian. The COMSEC custodian must retain a copy of each signed Inventory Report
on file.
The COMSEC Custodian must verify the accuracy of each returned report, resolve
discrepancies, report COMSEC incidents (for lost items) and return the signed Inventory
Report along with all supplemental accounting transactions to NCOR/COR. Inventory
Reports returned to NCOR/COR must contain a compilation of all ALC 1, ALC 2 and
ALC 6 material held at the COMSEC Account.
A copy of all signed Inventory Reports must be retained on file.
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6.4 Accounting Notices
6.4.1 Tracer Notice – Transfers
If the signed Transfer Report (receipt) has not been received when due, tracer action must be
initiated as follows:
The initial tracer action may be accomplished via a documented phone call, e-mail, or by
using an official tracer notice.
The initiation of tracer action is dependent on the distribution method (e.g. electronic,
courier) and whether the COMSEC Account or NCOR/COR is initiating the tracer
action.
In exceptional cases, when physical COMSEC material cannot be delivered and receipted
for within the allotted time, an extension of up to 20 working days is acceptable. In such
cases, a note must be added on the transfer report.
6.4.2 Tracer Action by the COMSEC Custodian
The COMSEC Custodian must ensure that a signed receipt has been received for every transfer
initiated at the COMSEC Account as follows:
Electronic Distribution. If a signed receipt for the electronic distribution of key is not
received within five working days from the date of distribution of the COMSEC material,
the COMSEC Custodian must initiate tracer action.
If the signed receipt is not received within five working days of this initial tracer action,
the COMSEC Custodian must notify NCOR/COR. NCOR/COR will assist the COMSEC
Custodian in obtaining the receipt.
Physical Distribution. If a signed receipt for the physical shipment of COMSEC material
is not received within 10 working days from the date of shipment, the COMSEC
Custodian must initiate tracer action.
If the receipt is not received within 10 working days of this initial tracer action, the
COMSEC Custodian must notify NCOR/COR. NCOR/COR will assist the COMSEC
Custodian in obtaining the receipt.
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6.4.3 Tracer Action by National Central Office of Record/Central Office of
Record
6.4.3.1 Tracer Action for Transfer Reports
If NCOR/COR has not received a signed Transfer Report (receipt) within 20 working days of the
date on which the report was sent, NCOR/COR will send a Tracer Notice to the delinquent
account. Up to three Tracer Notices will be sent.
NCOR/COR occasionally receives signed receipts for Transfer Reports that have not been
forwarded to NCOR/COR. The receipt cannot be reconciled unless the original Transfer Report
has been processed. In such cases, NCOR/COR will immediately send a Tracer Notice for the
missing Transfer Report.
6.4.3.2 Tracer Action for Inventory Reports
Tracer Notices may also be sent with respect to the Inventory process. During an inventory,
NCOR/COR may discover that COMSEC Material Reports have not been forwarded for
processing at NCOR/COR.
Missing COMSEC Material Reports will result in an inability to reconcile a COMSEC
Account’s inventory. NCOR/COR will originate tracer action for the missing COMSEC Material
Reports.
6.4.3.3 Failure to Respond to Tracer Notices
Failure to respond to Tracer Notices could result in an immediate audit of the COMSEC
Account.
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7 Special Accounting Requirements
7.1 Drop Accounting of North Atlantic Treaty Organization and
International COMSEC Material
7.1.1 General Requirement
When GC departments are entrusted with COMSEC material by a North Atlantic Treaty
Organization (NATO) or other international authority, it must be accounted for, transported,
stored and handled in accordance with the directive contained herein for Canadian COMSEC
material of equivalent sensitivity. Similarly, Canada accepts that our allies will also account for,
transport, store, and handle Canadian COMSEC material in accordance with their own national
policy and procedures. This arrangement is known as drop accounting. There is no requirement
for GC departments to hold the policy and procedural publications of the nation or alliance that
provides the material, except as detailed in the following two articles.
7.1.2 North Atlantic Treaty Organization Funded Units
When NATO funded units such as Satellite Ground Terminals are located on Canadian territory,
the COMSEC holdings will be entirely of NATO origin and must be accounted for, transported,
stored, and handled in accordance with the current editions of Instructions for the Control and
Safeguard of NATO Cryptomaterial (SDIP 293) and NATO Crypto Distribution and Accounting
Publication (AMSG 505).
7.1.3 North Atlantic Treaty Organization COMSEC Material Requiring Two-
Person-Integrity Control
Where GC departments are issued with NATO COMSEC material that requires TPI control,
such items must be accounted for, transported, stored, and handled in accordance with the
current edition of Policy and Procedures for the Handling and Control of Two-Person-
Controlled NATO Security Material (AMSG 773). The format of NATO COMSEC material
requiring TPI control is significantly different from its national equivalent and requires different
storage and handling procedures.
7.2 Canadian Controlled COMSEC Material Outside of the National
COMSEC Material Control System
COMSEC material, including CCI, must exit the NCMCS only via the NDA at CSEC. Canadian
CCI destined for use outside of Canada must be accounted for and handled within the receiving
foreign nation’s formal COMSEC channels. Subsequent to CSEC providing case-by-case
authority with a foreign nation, the NDA will initiate formal transfer to a foreign nation’s
established COMSEC Account with appropriate notification being sent to the foreign nation’s
responsible COR.
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NOTE 1:
NOTE 2:
Where a foreign private sector company or organization is involved, the COMSEC
material, including CCI, must be transferred to an established COMSEC Account or,
in the case of CCI under development (within established IP channels), via the
appropriate foreign nation’s NDA, in coordination with the foreign NDA’s COR.
COMSEC Client Services at CSEC may authorize GC departments or private sector
companies or organizations to by-pass this channel if sufficient justification is
provided in writing before the distribution.
7.3 Criteria for Release of COMSEC Material to the Private Sector
Private sector companies or organizations (including those in Canadian industry,
universities, etc.) that require COMSEC material must have a COMSEC Sub-Account
established by the CICA. Before the establishment of a COMSEC Sub-Account at a private
sector institution or organization, the institution or organization must:
have a legal agreement with the GC (i.e. a contract or pre-contractual agreement, or be a
member of a CSEC program which requires the production or support of COMSEC
material);
have been granted a Facility Security Clearance (FSC) by CSEC. The FSC, which
includes a Document Safeguarding Capability (DSC) and COMSEC Safeguarding
Capability (CSC), must be equal to or higher than the classification or protected level of
the COMSEC material being issued or produced;
have a Company Security Officer (CSO), and a trained COMSEC Custodian and Alternate
COMSEC Custodian, all approved by CSEC; and
if receiving or producing COMSEC material items, sign an Accountable COMSEC
Material Control Agreement (ACMCA) with CSEC. A copy of the ACMCA is found in
ITSD-01.
7.4 Government Furnished Equipment
7.4.1 Government Furnished Equipment for Canadian Industry
When transferring Government Furnished Equipment (GFE) to a Canadian industry COMSEC
Sub-Account, the COMSEC Custodian must ensure that:
the COMSEC material is identified as GFE on the Transfer Report;
the contract number and Memorandum of Understanding (MOU) or Memorandum of
Agreement (MOA), which must be identified by the client GC department’s contract
authority, is included on the Transfer Report; and
an appropriate ACMCA is in place for each contract.
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Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
7.4.2 Government Furnished Equipment for Allied Contractors
Transfer of GFE to or from allied contractors is handled on a case-by-case basis. Contact
COMSEC Client Services at CSEC.
7.5 COMSEC Material under Contract
Refer to Annex A – Control of IP COMSEC Material for accounting and control direction
applicable to COMSEC material under a maintenance or repair contract and COMSEC
publications under a reproduction or translation contract.
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8 Access to COMSEC Material
8.1 Prerequisite for Access to COMSEC Material
8.1.1 Access by Government of Canada Employees and Contractors
Access to COMSEC material may be granted to Canadian citizens (including dual nationality)
who:
possess a valid GC security clearance or reliability status commensurate with the security
classification of the material and information they will access;
have a “need-to-know”;
have been given a COMSEC Briefing;
have signed a COMSEC Briefing Certificate; and
are familiar with applicable COMSEC material control procedures.
NOTE: Access by persons with Permanent Resident Status is not authorized.
8.1.2 Access by Foreign Nationals
Access to COMSEC material may be granted to foreign nationals (i.e. non-Canadian citizens)
upon approval from CSEC on a case-by-case basis. Requests for such access must be submitted
in writing to COMSEC Client Services at CSEC.
8.2 COMSEC Briefing and COMSEC Briefing Certificate
8.2.1 Requirements
The DCA and COMSEC Custodian must ensure individuals requiring access to COMSEC
material receive a COMSEC Briefing and sign a COMSEC Briefing Certificate. A COMSEC
Briefing is required for individuals (includes, but is not limited to, COMSEC Account personnel,
Local Elements, individuals attending CSEC and international COMSEC courses and COMSEC
forums; and, individuals who need “user access” or “maintainer access” during installation,
troubleshooting, repair, or physical keying of equipment) who require access to:
COMSEC material controlled within the NCMCS;
crypto-information which embodies, describes or implements a classified cryptographic
logic;
crypto-information including, but not limited to full maintenance manuals, cryptographic
computer software (must be a continuing requirement);
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classified IP COMSEC material or CCI and components at any phase during its
production or development; and
cryptographic key or logic during its production or development.
8.2.2 Retention of COMSEC Briefing Certificates
A COMSEC Briefing Certificate must be retained by the COMSEC Custodian for a minimum of
two years after an individual’s authorization to access COMSEC material has ended.
8.2.3 COMSEC Debriefings/Updates
COMSEC debriefings are not required when access to COMSEC material is no longer required.
Periodic or annual briefing updates are not required for active COMSEC Custodians, Alternate
COMSEC Custodians and Local Elements. Any individual being re-appointed at the same or at a
different COMSEC Account as a COMSEC Custodian, Alternate COMSEC Custodian or Local
Element must be given a new COMSEC Briefing and sign a new COMSEC Briefing Certificate.
8.3 Two Person Integrity
TPI is a security measure designed to prevent any one person from having access to specified
COMSEC material (e.g. TOP SECRET key material). Each individual having such access must
be capable of detecting incorrect or unauthorized security procedures with respect to the task
being performed. TPI-regulated storage and handling requires the use of security devices
protected by two approved locks, Personal Identification Numbers (PINs) or passwords, with no
one person having access to both sets of combinations, keys, PINs or passwords.
8.4 No Lone Zone
Certain areas in a COMSEC facility may be designated as a NLZ. A minimum of two authorized
individuals must be in visual contact with each other at all times within a NLZ. If the departure
of one individual would leave a single occupant, then both individuals must leave and secure the
NLZ.
The DCA will establish a NLZ for COMSEC Accounts that:
receive, store, handle, use or destroy TOP SECRET key material;
produce physical key material; or
take part in the design, development, manufacture or maintenance of crypto equipment.
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9 Physical Security
9.1 COMSEC Facilities
9.1.1 Requirement
Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
A COMSEC facility must be established wherever COMSEC material is generated, stored,
repaired, used or operations warrant (e.g. COMSEC Custodian work area, key distribution
centre, repair facility). COMSEC Custodian work areas outside of established COMSEC
facilities (e.g. temporary structures, mobile vehicles) that are not considered COMSEC facilities
must provide the maximum possible protection from theft, compromise, damage and
deterioration of COMSEC material and ensure access and accounting integrity is maintained.
9.1.2 Planning and Establishing a COMSEC Facility
When planning and establishing a COMSEC facility, the DCA should:
establish the COMSEC facility in an area which provides positive control over access
using a hierarchy of zones (refer to Article 6.2 of the TBS’ Operational Security Standard
on Physical Security);
produce a standard operating procedure (in conjunction with the COMSEC Emergency
Plan) containing provisions for securely conducting facility operations; and
ensure a Threat and Risk Assessment (TRA) is conducted before initial activation (where
practical) and periodically thereafter based on threat, physical modifications, sensitivity of
operations and COMSEC incident reports of a serious nature.
9.1.3 Access Controls and Restrictions
The COMSEC Custodian must:
establish an access list for authorized individuals who have regular duty assignments in
the COMSEC facility;
limit unescorted access to individuals who are Canadian citizens (including dual
nationality), whose duties require such access, and who meet the access requirements of
Chapter 8;
ensure all visits are recorded in a visitor log and retain the log for at least one year after
the date of the last entry. The visitor log must contain, at a minimum:
o date/time of arrival and departure
o printed name
o signature of visitor
o purpose of visit, and
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o signature, including printed name, of authorized individual admitting the visitor;
ensure visitors are continuously escorted by an individual whose name is on the access
list;
prohibit unauthorized personally owned devices and equipment capable of receiving and
recording intelligible images, sound recording devices and equipment, radio transmitting
and receiving equipment and microphones and television receivers from the COMSEC
facility;
post a sign to identify the area as a RESTRICTED ACCESS area;
establish and document a daily security check procedure to ensure COMSEC material is
properly safeguarded, and that approved physical security protection devices (e.g. door
locks, alarm system) are functioning properly; and
ensure unmanned facilities in areas posing a high risk of compromise are protected by an
approved intrusion detection system and that physical checks are conducted at least once
every 24 hours to ensure that all doors to the facility are locked and that there have been
no attempts at forceful entry.
9.1.4 COMSEC Facility Approval
9.1.4.1 Initial Inspection of Facility for COMSEC Custodian Work Area
The facility for the COMSEC Custodian work area must be approved by CSEC before the GC
department is authorized to establish a COMSEC Account and hold COMSEC material. The
approval will be based on a security inspection to determine if the facility meets the
requirements for safeguarding COMSEC material as detailed in this directive, the Operational
Security Standard on Physical Security and the applicable RCMP Physical Security Guide.
9.1.4.2 Other Departmental COMSEC Facilities
Where a departmental Threat and Risk Assessment (TRA) indicates the requirement for other
COMSEC facilities (e.g. COMSEC Sub-Account, telecommunications facility, maintenance or
repair depot), the DCA is responsible for ensuring these COMSEC facilities are established and
approved.
9.1.4.3 Re-inspection of COMSEC Facilities
CSEC representatives will re-inspect the facility for the COMSEC Custodian work area during
the audit of the COMSEC Account. The DCA must ensure other departmental COMSEC
facilities are re-inspected periodically based on threat, physical modifications, past security
performance and sensitivity of operations. These inspections must be conducted by individuals
not directly involved in the installation, operations or maintenance of the facility.
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9.1.4.4 Records of COMSEC Facility Inspections
The inspection of a COMSEC facility must be documented and records kept on file at the
COMSEC Account or CSEC, as applicable, for a minimum of five years.
9.2 Secure Storage
9.2.1 Security Containers
COMSEC material must be stored in security containers (e.g. vaults, safes, file cabinets, etc.)
that are approved for the classification or protected level of the COMSEC material and which
meet the requirements of the RCMP Security Equipment Guide (G1-001). Security containers
used for the storage of COMSEC material must be located in a security zone appropriate for the
level of the COMSEC material. Additional information can be found at RCMP’s Physical
Security Guides and Reports web page.
NOTE: Brief cases are not considered storage containers and must not be used as such.
9.2.2 Segregation of COMSEC Material in Storage
The rules for the minimum segregation of COMSEC material in physical storage are:
Effective editions, reserve editions and superseded key material awaiting destruction must
be stored separately from each other in approved security containers.
Key material or CIKs must not be stored in the same security container as the equipment
with which they may be used.
NOTE: In situations where space is at a premium, segregation may be accomplished using a
locked strongbox housed within a single security container.
9.2.3 Opening of Security Containers in Emergency Situations
When the COMSEC Custodian and Alternate COMSEC Custodian(s) are not available to open a
security container in an emergency, the DCA (or other designated authority) may direct the
opening of the security container, under the following conditions:
At least two individuals must be present to gain access to the combination and to open the
security container.
The individuals who opened the security container must prepare a written report
(containing an inventory of the contents and the circumstances surrounding the access
requirement) to the individual(s) in charge of the security container, after the emergency
opening.
The individual(s) responsible for the security container must conduct a full inventory of
the COMSEC material and change the combination(s), immediately upon their return.
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In the event of an emergency where access is required to COMSEC material that has been
previously issued to a Local Element who is not available, the individual requiring immediate
access must contact either the COMSEC Custodian or Alternate COMSEC Custodian.
9.2.4 Incidents Involving Security Containers
In the event of a security incident (e.g. if a container or vault is found open after normal working
hours), the individual discovering the incident must notify the COMSEC Custodian or Alternate
COMSEC Custodian. If the COMSEC Custodian or Alternate COMSEC Custodian cannot be
located, one of the other individuals on the list of individuals having knowledge of the
combinations to the container must be contacted. The COMSEC Custodian and Alternate
COMSEC Custodian must conduct a full inventory of its contents and immediately change the
combination.
In the event of an incident in which COMSEC material has been issued to a Local Element, the
individual discovering the incident must contact either the COMSEC Custodian or Alternate
COMSEC Custodian.
9.2.5 Protecting Lock Combinations and Lock Keys
9.2.5.1 Security Measure
Any sign of tampering with or suspicion of compromise of a lock or its associated combinations
(or keys) must be immediately reported to the DCA.
9.2.5.2 Change of Combinations
The COMSEC Custodian must ensure that combinations for locks used for the secure storage of
COMSEC material are changed when:
the lock is first put into use by the COMSEC Custodian (i.e. the manufacturer’s preset
combination) must not be used;
an individual knowing the combination ceases to have authorized access to the storage
facility or the security container;
an unauthorized individual has had access to the written record of the combination;
the combination is known or suspected to have been compromised;
the lock has been repaired, serviced or inspected by a person not having authorized access
to storage facility or the security container;
the combination has not been changed in the last 12 months; or
the lock is temporarily or permanently taken out of use.
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9.2.5.3 Selection of Combinations
Each lock must have a combination composed of randomly selected numbers based on the
manufacturer’s specifications. The combination must not be a duplicate of another lock
combination within the facility.
9.2.5.4 Change of Key Operated Locks
The COMSEC Custodian must ensure that key-operated locks used to secure COMSEC material
are replaced and not re-used to secure COMSEC material when:
an individual ceases to have authorized access to the security container;
an unauthorized individual has had access to a key;
the key or lock is known or suspected to have been compromised;
the lock has been repaired, serviced or inspected by a person not having authorized access
to the security container; or
the lock has not been changed in the last 12 months.
9.2.5.5 Protective Packaging of Combinations or Spare Keys
When a combination (or key operated lock) is changed by the individual responsible for the
security container, the COMSEC Custodian must ensure that the responsible individual has:
a. sealed the combination numbers (or spare keys) in an opaque envelope in such a manner
that tampering with the envelope is evident;
b. marked the envelope with the highest classification or protected level of the material that
the combinations (or keys) protect and listed the name and phone number of the
individual(s) authorized access to the combinations (or keys); and
c. given the envelope to the DCA (or other authorized individual) for secure storage in a
storage container that meets or exceeds the classification or protected level of the material
being protected by the combinations (or keys).
9.2.5.6 Record of Combinations and Keys
The COMSEC Custodian must keep a record of the name and telephone number of individuals
having knowledge of the combinations (or hold keys) to containers in which COMSEC material
is stored. Normally, the containers will be under the direct control of the COMSEC Custodian
and the Alternate COMSEC Custodian(s).
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9.2.5.7 Access to and Knowledge of Combinations or Keys
The COMSEC Custodian must ensure that only appropriately cleared and authorized personnel
have access to, or knowledge of, combinations (or keys) that protect the COMSEC material for
which they are accountable. Personnel with knowledge of combinations must not record and
carry the combinations or store the records of such combinations in electronic form. Keys must
not be stored in key presses that are accessible to any personnel other than the COMSEC
Custodian or his/her staff.
9.2.5.8 Combinations for Two-Person Integrity Containers and No Lone Zone
The COMSEC Custodian must ensure that no one person may change both combinations or will
be allowed access to or have knowledge of both combinations to a security container used to
store COMSEC material requiring TPI control or to an area used as a NLZ.
NOTE: Lock combinations must be classified and safeguarded at the highest classification of
the material they protect.
9.3 Storage of Physical Key Material
9.3.1 Storage Requirements
Key material not under the direct continuous control of a cleared and authorized individual (or
individuals where applicable) must be stored in a locked, approved security container, in an area
protected by security guards or by an intrusion-detection system (i.e. Security Zone, High
Security Zone). Refer to Table 3 for specific requirements for the storage of key material.
9.3.2 Key Material Held in Reserve
The amount of key material to be held in reserve varies with the supersession rate of the key
material. Table 2 provides a guide to the amount that should normally be held in reserve.
Table 2 – Key Material Held in Reserve
Supersession Rate
Material superseded daily, ten times monthly,
semi-monthly and monthly.
Material superseded every two months or
quarterly.
Material superseded semi-annually, annually
and irregularly.
SDNS seed key (five year retention factor).
Held in Reserve
Editions effective during the current month, plus
three months reserve.
Effective edition plus two editions reserve.
Effective edition plus one edition reserve.
One seed key may be held in reserve.
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Table 3 – Storage of Physical Key Material
Key Material
TOP SECRET Key
Material and other Key
Material Requiring TPI
Control
SECRET,
CONFIDENTIAL and
PROTECTED C Key
Material
PROTECTED A and
PROTECTED B Key
Material
UNCLASSIFIED Key
Material
Foreign Key Material
Storage Requirements
TOP SECRET key material must be stored under TPI controls in
containers meeting the RCMP Security Equipment Guide (G1-001)
standards.
TOP SECRET key material that is held within a work area for
intermittent use throughout the day may be kept under one lock in a
NLZ. Knowledge of the combination or access to the key used to
secure the lock must be restricted to the supervisor on duty.
TOP SECRET key material in tactical environments, may be:
stored in a standard, approved field safe;
stored in a similar container secured by a combination lock meeting
the RCMP Security Equipment Guide (G1-001) standards; or
kept under personal custody if adequate storage facilities are not
available.
SECRET, CONFIDENTIAL and PROTECTED C key material must
be stored :
in any manner approved for TOP SECRET key material; or
in a container approved for SECRET, CONFIDENTIAL or
PROTECTED C material, as applicable, with an approved
combination lock.
PROTECTED A and PROTECTED B key material must be stored in
any manner approved for classified key material.
UNCLASSIFIED key material must be stored by the most secure
means available to the authorized user provided that it will reasonably
preclude theft, sabotage, tampering or use by unauthorized individuals.
Foreign key material must be stored in accordance with the
instructions for Canadian COMSEC material of equivalent sensitivity.
UNCLASSIFIED, RESTRICTED and UNCLASSIFIED/For Official
Use Only (U//FOUO) foreign key material marked “CRYPTO” must
be stored as PROTECTED A (or higher) COMSEC material.
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9.4 Storage of Electronic Key Material
Electronic key material must be stored in accordance with the applicable system or equipment
doctrine.
9.5 Storage of COMSEC Equipment
9.5.1 General Requirement
All COMSEC equipment must be stored in a manner consistent with its classification or
protected level and security markings (e.g. CRYPTO, CCI) when not under the direct and
continuous control of appropriately cleared and authorized personnel. COMSEC equipment may
require special storage procedures or storage facilities. Refer to the applicable equipment
doctrine.
NOTE: UNCLASSIFIED COMSEC equipment and unkeyed CCI require storage that must
provide reasonable protection from compromise, theft, tampering and damage.
9.5.2 Preparation for Storage
COMSEC equipment must never be stored in a keyed state, unless:
operational requirements mandate it and no practical alternative exists; or
keyed equipment cannot be zeroized due to malfunction or damage.
When COMSEC equipment is stored in a keyed state, it must be stored in accordance with the
highest classification of key loaded in the equipment.
NOTE 1: CCI that utilize a CIK are considered keyed whenever the CIK is inserted and
unkeyed with the CIK removed and not accessible for use by unauthorized persons.
NOTE 2: CCI that utilize a PIN to unlock the secure mode are considered keyed whenever the
PIN is entered.
9.5.3 Spare or Standby Equipment
Spare or standby COMSEC equipment that is located within a secure work area may be
considered installed for operation. The storage requirements in the previous articles are not
applicable to such equipment.
9.6 Storage of COMSEC Publications
COMSEC publications must be stored in accordance with their security classification and any
caveat(s) or other security markings.
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10 Distribution and Receipt of COMSEC Material
10.1 Distributing COMSEC Material
To meet secure communications requirements, COMSEC Custodians may be directed to
distribute COMSEC material to other NCMCS elements. It is a COMSEC Custodian’s
responsibility to ensure that individual shipments of COMSEC material are kept to the minimum
required to support operational requirements (including contingency operations).
When preparing COMSEC material for distribution, the COMSEC Custodian must:
verify the receiving COMSEC Account, COMSEC Sub-Account or Local Element is
authorized to hold the COMSEC material;
verify the security classification of the receiving COMSEC Account, COMSEC Sub-
Account or Local Element;
perform page checks, equipment checks and inspection of protective packaging
immediately (no earlier than 48 hours) before packaging;
zeroize or remove CIKs from all CCI before transportation (or, when circumstances
warrant, keyed devices may be hand-carried by authorized GC couriers or contractor
couriers);
package operational and seed key material separately from its associated COMSEC
equipment (including CCI) and transport in different vehicles on different days, unless –
o the application or design of the equipment is such that the corresponding key material
cannot be physically separated from it;
o the key material is an UNCLASSIFIED maintenance key (which may be shipped in
the same container as its associated COMSEC equipment); or
o there are no other means available to effect delivery to support an immediate
operational requirement;
NOTE: When COMSEC equipment must be shipped in a keyed state or with its
associated key material, ship the package in accordance with the
classification of the key material or the COMSEC equipment, whichever is
higher.
dispatch the list of effective dates of editions of key material separately, and on different
days, from the key material;
package each Traffic Encryption Key (TEK) separately from its associated KEK;
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package components which, as a whole, comprise a cryptographic system (i.e. the
cryptographic equipment, ancillaries, associated documentation and key variables)
separately and transport in different shipments;
apply TPI controls to the TOP SECRET key material during its transit unless it is
enclosed in protective packaging and is double-wrapped, in which case only one courier is
required;
ensure that electronic key material is transmitted in accordance with the applicable system
or equipment doctrine; and
prepare a COMSEC Material Report in accordance with Chapter 6 of this directive.
10.2 Distributing Electronic Key on Magnetic or Optical Media
In addition to the criteria at Article 10.1, when electronic key is distributed (i.e. transferred or
issued) on magnetic or optical media, the selected media must be controlled as a separate
COMSEC item within NCMCS as ALC 1. The COMSEC Custodian must affix a label to the
media similar to the example label depicted at Figure 2. The accounting number is taken from a
“next in sequence” number log maintained by the COMSEC Custodian to record the sequential
serial numbers of the media. The originating COMSEC Custodian must prepare and process a
Possession Report in accordance with Chapter 6 to enter the new COMSEC material into the
NCMCS before distributing the media (and the electronic key material).
Two GC-223 Transfer Reports must be generated: one to account for the physical transport
media; and, the second to account for the transfer of the electronic key that is being transported
by the media. Both reports are signed and returned to the originating COMSEC Account.
If unencrypted key is being transported by magnetic or optical media, the label must also display
the CRYPTO marking and highest classification of key being transported (minimum SECRET).
NOTE: Magnetic or optical media used for distribution of electronic key is not authorized for
re-use. The electronic key being transported by the media must be processed and
reconciled, and along with the transporting medium, be physically destroyed within
three working days of receipt.
Classification:
SECRET (CRYPTO if applicable)
Accounting Legend Code: ALC 4
Short Title:
CAKAE 4005 (+ EKMS ID)
Accounting Number: (Unique next in sequence number)
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Figure 2 – Example of Magnetic or Optical Media Label
10.3 Tracking the Shipment of COMSEC Material
Following the shipment of COMSEC material, the COMSEC Custodian must:
notify the recipient, within 24 hours of shipment, of the details of the shipment and the
estimated time of delivery;
ensure the telephone numbers of both the shipping and the receiving COMSEC Accounts
are listed on the waybill when COMSEC material is shipped by commercial carrier or
Canada Post Priority Courier;
keep a local record of the shipment; and
follow-up to ensure the COMSEC material is delivered to the authorized recipient
according to schedule and –
o if a shipment is not received within 48 hours of expected delivery, initiate shipment
tracer action with the carrier to determine the last known location of the shipment;
and
o if the location is not determined and the shipment is not recovered within 24 hours of
the shipment tracer initiation, assume that the shipment is lost in transit and
immediately report the loss as a COMSEC incident as detailed in Chapter 16.
10.4 Packaging Physical COMSEC Material
10.4.1 Overview
Packaging used for the distribution of physical COMSEC material will depend upon the
material’s size, weight, shape and intended method of transport. All COMSEC material must be
double-wrapped or otherwise encased in two opaque containers, and securely sealed (including
seams) before its transportation.
10.4.2 Inner Wrapping
The inner wrapping for package(s) must be secure enough to detect tampering, guard against
damage and be marked as follows:
full addresses of both the shipping and receiving COMSEC Accounts
highest classification or protected level of the contents
caveat “CRYPTO” if any of the contents are so marked, and
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notation “TO BE OPENED ONLY BY THE COMSEC CUSTODIAL STAFF”.
The sealed envelope containing the copies of the COMSEC Material Report may be enclosed
inside the package or affixed to the external surface of the inner wrapping of the package. When
more than one package is required, the envelope may be enclosed or affixed to the first package
of the series.
10.4.3 Outer Wrapping
The outer wrapping must:
be secure enough to prevent damage to the contents or inadvertent or accidental
unwrapping;
not bear any indication that the package contains classified or protected COMSEC
material;
be marked with the –
o full addresses of both the shipping COMSEC Account and the receiving COMSEC
Account
o shipment number or authorized courier number, and
o package number, followed by a forward slash (“/”), followed by the total number of
the packages in the shipment (e.g. 1/3, 2/3, 3/3); and
have all required customs documentation clearly identified and affixed to it.
10.4.4 Types of Packaging
10.4.4.1 Envelopes
Double official envelopes may be used for the shipment of COMSEC material by mail or by
courier. If the inner envelope contains cryptographic material (of any classification) or
COMSEC material classified SECRET or above, both the inner and outer envelope flap must be
sealed with reinforced or tamper-evident tape in addition to the envelope gum seal.
If the inner envelope contains COMSEC material classified CONFIDENTIAL or below, both the
inner and outer envelopes require gum sealing only. However, envelopes should be sealed with
reinforced or tamper-evident tape if, in the opinion of the COMSEC Custodian, the envelopes
may tear during transportation.
10.4.4.2 Parcels
Good quality brown wrapping paper and fibre-reinforced paper tape should be used when
preparing COMSEC parcels. Such parcels must be packaged and bound as follows:
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All seams of the inner wrapping must be bound with fibre-reinforced paper tape.
Sharp corners must be reinforced or bound with cardboard to prevent damage to the inner
wrapping while in transit.
Outer wrapping must consist of paper and fibre-reinforced tape heavy enough to ensure a
suitably sturdy parcel.
10.4.4.3 Cartons
Cartons may be used as the inner or outer container for a shipment. Used cartons must be in good
condition, with all previous markings obliterated. Additional packing must be used within the
carton to prevent movement of the contents. Fibre-reinforced paper tape must be used to seal all
seams and to reinforce edges and corners.
10.4.5 Wooden Crates or Transit Cases
Wooden crates or transit cases should normally be used only as outer wrapping for shipments,
except when specially designed and authorized to be used as inner wraps. The outer crate or case
must be strapped with a minimum of one strap lengthwise and one width-wise, both centred. The
clamp securing the strap running lengthwise must be positioned above the strap running widthwise.
10.4.5.1 Canvas Bags
A canvas bag may be used as the outer wrapping of a parcel. The bag must be sealed with a lever
lock and a plik. The identification number on each plik is a tamper evident security control that
must be used to detect unauthorized access to the bag. The user must take note of the plik’s
unique ID/serial number when the plik is used to seal the bag. Later, when the bag is to be
opened, the user must verify that the ID number of the plik on the bag has not changed. This
verification of the ID number confirms that the bag has not been opened by someone else and
then re-sealed using a different plik. The seams of the bag must be on the inside. Damaged or
repaired bags must not be used.
10.4.5.2 Briefcases
Within Canada, a briefcase with a GC-approved lock is an appropriate outer wrapper for
COMSEC material carried by authorized departmental couriers. See the RCMP Security
Equipment Guide (G1-001) for details.
10.5 Authorized Modes of Transportation
10.5.1 Overview
The approved modes of transportation for Canadian COMSEC material are listed in Table 4.
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10.5.2 North Atlantic Treaty Organization and Foreign COMSEC Material
10.5.2.1 Classified COMSEC Material and UNCLASSIFIED Key Material Marked
CRYPTO
The approved modes of transportation listed in this chapter do not apply to NATO or foreign
classified COMSEC material or unclassified key material marked CRYPTO. This COMSEC
material must be transported in accordance with NATO and foreign national manuals, such as:
Communications Security and Cryptography (IS-4) – Part 1: Management of
Cryptographic Systems, U.K.
Communications Security and Cryptography (IS-4) – Part 2: Forms and Instructions,
U.K.
Instructions for the Control and Safeguarding of NATO Cryptomaterial (SDIP 293).
NATO Crypto Distribution and Accounting Publication (AMSG 505).
Control of Communications Security (COMSEC) Material (NSA/CSS Policy Manual
No. 3-16), United States (U.S.).
NOTE: Contact COMSEC Client Services at CSEC for information regarding these
publications.
10.5.2.2 UNCLASSIFIED, RESTRICTED and U/FOUO COMSEC Material
(other than Key Material marked CRYPTO)
UNCLASSIFIED, RESTRICTED and U/FOUO foreign and NATO COMSEC material (other
than key material marked CRYPTO) must be shipped by the modes listed in Table 4 as approved
for PROTECTED “A” COMSEC material of the same type. CCI, whether of foreign or national
origin, must always be shipped by approved modes listed in Table 4.
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Table 4 – Authorized Modes of Transportation for COMSEC Material
Destination
Classification or Protected Level of COMSEC Material
(see COMSEC Material Legend)
1, 2 3, 4, 5 6, 7 8 9
Within Canada
A, B, C
(Notes I, II, IV)
A, B, C, D
(Notes I, II, IV)
A, B, C, D, E, F
(Notes I, II, IV)
A, B, D, E, F
A, B, C, D, E, F
(Notes I, II)
Between Canadian Addressees
Outside of Canada (see Note V)
A, B, C
(Notes I, II, IV)
A, B, C, D
(Notes I, II, IV)
A, B, C, D
(Notes I, II, IV)
A, B, D, E, F
A, B, C, D, E, F
(Notes I, II)
To or From Non-Canadian
Addressees (see Note VI)
A, B, C
(Notes I, II, IV)
A, B, C, D
(Notes I, II, III, IV)
A, B, C, D
(Notes I, II, III, IV)
A, B, D, E
A, B, C, D
(Notes I, II, III)
UNCLASSIFIED COMSEC material may be shipped by any means intended to assure safe arrival at its destination.
UNCLASSIFIED COMSEC material marked with “CRYPTO” caveat must be shipped as per PROTECTED A (Note IV).
COMSEC Material Legend:
Authorized Mode Legend:
1 All TOP SECRET and PROTECTED C COMSEC material
A Canadian Government Diplomatic Courier Service
2 All Crypto Keying Material not in Protective Packaging B Authorized Departmental Couriers
3 Classified Crypto-Information (not TOP SECRET)
C
Electronic Transfer
4 Classified Crypto Equipment D Contractor’s Authorized Couriers
5 SECRET Crypto Keying Material in Protective Packaging
6
7
PROTECTED B, CONFIDENTIAL and SECRET COMSEC
Information
CONFIDENTIAL and PROTECTED B Crypto Keying Material in
Protective Packaging
8 UNCLASSIFIED CCI and UNCLASSIFIED CRYPTO Material
9 PROTECTED A COMSEC Material
Notes:
E
F
Authorized Commercial Carriers
Canada Post Priority Courier Service
I
II
III
Systems for electronic transfer of COMSEC material are authorized by CSEC on a case-by-case basis.
Electronic transfer of keying material when authorized by CSEC and in accordance with system operational doctrine.
Departmental and Contractor’s couriers authorized by CSEC for urgent requirements only.
IV
V
NATO and foreign COMSEC material (including Crypto key) may require additional considerations (see also SDIP-293, AMSG-505,
NSA/CSS Policy Manual 3-16, IS-4, etc. for details).
Refers to those addressees outside of Canada, where mail and shipment of material, once delivered, are handled and opened by
Canadian citizens (including dual nationality), e.g. Canadian Forces Base, Canadian Embassies, consular offices.
VI Refers to any other foreign addressee not covered in Note V.
Instructions: Locate the correct classification/protected level of the COMSEC material from the COMSEC Material Legend. Find the
destination in the upper left hand column. The authorized modes of transportation are indicated by letters, which correspond to letters listed
in the Authorized Mode Legend. Refer to the notes for additional information.
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10.6 Authorized Couriers of COMSEC Material
10.6.1 Canadian Government Diplomatic Courier Service
The Canadian Diplomatic Mail Services of Foreign Affairs and International Trade Canada
provides all authorized diplomatic courier services for the GC.
10.6.2 Authorized Departmental Couriers
10.6.2.1 Requirements
Before authorizing the appointment of a departmental courier for the transport of COMSEC
material, the DCA must ensure the courier:
is a Canadian citizen (including dual nationality);
is appointed for a specific period of time;
carries an authorized COMSEC Courier Certificate;
is cleared to a security level equal to or higher than the highest classification or protected
level of the COMSEC material that is being carried;
has been appropriately briefed regarding responsibilities upon appointment; and
is provided with COMSEC Signing Authority Forms (refer to Article 4.3.2), as required.
10.6.2.2 COMSEC Courier Certificate
The COMSEC Courier Certificate attests to all concerned individuals (e.g. air carrier security
agents, customs officials) that the sealed container or package transported by the courier holds
only official matter. Presentation of the courier certificate should extend immunity from search
or examination of the official material carried or escorted by the courier. When further
verification is needed regarding the authenticity of a COMSEC Courier Certificate, the courier
will direct the concerned individual to contact the nearest Canadian Military or Diplomatic
representative, as appropriate.
10.6.2.3 Courier Instructions
The DCA must brief the courier and provide written instructions regarding his or her
responsibilities to personally safeguard the COMSEC material until the package has been
delivered to and signed for by the authorized recipient. The courier instructions must include, at
a minimum, what actions to take:
before the start of the trip (e.g. contacting airline security or customs officials to make
arrangements for clearance without inspection);
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during the pre-boarding security screening or customs inspection to ensure the COMSEC
material is not compromised or damaged (e.g. requirement to show the COMSEC Courier
Certificate when requested to do so by appropriate authorities);
for alternate storage arrangements and whom to contact in the event of emergency
situations, lengthy delays or stopovers en route; and
in the event of loss, compromise or possible compromise of COMSEC material and know
who to contact in such a case.
10.6.2.4 Customs and Pre-Boarding Inspections
In cases where customs officials request or demand to view (X-ray is authorized if
requested/demanded) the contents of a COMSEC shipment, the authorized courier, or the
COMSEC Custodian if called, will request an interview with the Chief of Customs or Air
Transport Security Authority. The courier may agree to limited inspection as a means of assuring
customs officials that the shipment contains nothing other than what is described on the
documentation. Whenever COMSEC packages are subjected to increased scrutiny, the
authorized courier will request that the inspection:
take place in a private location;
be conducted by duly authorized individuals in the presence of the authorized courier;
and
be restricted only to the external viewing of the COMSEC material.
The courier may be obliged to discontinue the courier run and return to the point of departure
with the COMSEC material if an arrangement regarding the extent of customs clearance
examination required cannot be reached.
10.6.3 Contractor’s Authorized Couriers
Appropriately cleared contractor personnel who have been appointed by CSEC may be
employed as couriers. Contact CICA for details on the requirements that must be met by
personnel appointed as contractor couriers. A COMSEC Courier Certificate is required.
10.6.4 Commercial Carriers
A commercial carrier service (including Canada Post Priority Courier Service) may be used as a
courier service for COMSEC material (at the levels specified in Table 4) provided the carrier can
ensure a continuous chain of accountability and custody for the material while in transit. The
courier must offer speed of service (e.g. overnight delivery), physical protection and track-andtrace
capabilities.
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A commercial carrier (non-military contracted aircraft) may be used to transport CCI providing
the carrier warrants in writing that the carrier:
provides door-to-door service and guarantees delivery within a reasonable number of
days based on the distance to be travelled;
possesses a means of tracking individual packages within its system (i.e. manual or
electronic) to the extent that should a package become lost, the carrier can, within
24 hours following notification, provide information regarding the last known location of
the package(s);
guarantees the integrity of the transporters’ contents at all times;
guarantees the integrity of package contents, including protection against damage,
tampering and theft;
has the capability to store in-transit COMSEC packages in a securely locked facility
(e.g. security cage) that is accessible solely to authorized carrier personnel, should it
become necessary for the carrier to make a prolonged stop at a carrier terminal (during
overnight stopovers);
obtains manual or electronic signatures, whenever a shipment changes hands within the
carrier company; and
obtains date-timed signatures upon pickup and delivery.
10.7 Receiving COMSEC Material
10.7.1 Preparation before Receiving COMSEC Material
Before receipt of any COMSEC material, the COMSEC Custodian must:
notify the departmental mailroom or shipping area of –
o the name of the departmental COMSEC Account that has been established
o the name and internal address of the COMSEC Custodian, and
o the requirement to deliver mail and packages addressed to the COMSEC Account to
the COMSEC Custodian unopened;
provide the departmental mailroom or shipping area with up-to-date copies of the
COMSEC Signing Authority Form; and
ensure other individuals who are authorized to sign for packages can provide appropriate
secure storage for the received package(s) (when the COMSEC Custodian or Alternate
COMSEC Custodian is not available).
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10.7.2 Inspection of Packages
On receipt of a shipment, the COMSEC Custodian must:
a. carefully inspect the outer wrapping and inner wrapping of the shipment for signs of
damage or tampering before removing each wrapping;
b. check the addresses on both outer and inner wrapping to confirm the shipment has been
sent to the intended recipient;
c. immediately report any evidence of possible tampering with either the inner or outer
wrappings or unauthorized access to the contents as a possible COMSEC incident in
accordance with Chapter 16 and –
o pending investigation of a possible compromise, discontinue unwrapping the package
and quarantine the package; and
o notify the shipping COMSEC Custodian to annotate all COMSEC material involved
as “Pending Investigation”.
10.7.3 Validation of Content
When satisfied that the packaging has not been tampered with, the COMSEC Custodian must:
a. open the package (with TPI control in place if the shipment contains TOP SECRET key
material or other key material requiring TPI control);
b. unpack the contents and confirm that the items listed on the enclosed COMSEC Material
Report match the items shipped by confirming the –
o short title, edition and quantities of all items, and
o accounting numbers, where applicable;
c. report any discrepancies to the shipping COMSEC Custodian and, if required, contact
NCOR/COR for assistance with reconciliation of the discrepancy;
d. inspect the protective packaging on each item of COMSEC material, where applicable;
NOTE: Certain items of COMSEC material are protectively packaged at the time of
production and must not be opened until they are to be issued to the authorized
user.
e. check key tape canisters and confirm that the first segment shown displays the proper short
title, register number and segment number;
f. page check all copies of accountable COMSEC publications;
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g. if applicable, process and reconcile electronic key received on magnetic or optical media
and destroy the media within three working days of receipt; and
h. if no discrepancies are found, sign the three copies of the COMSEC Material Report and
distribute in accordance with instructions found at Article 6.3.2.3.
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11 Handling and Use
Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
11.1 Accountable Key Material
11.1.1 Purpose and Use
Key material may be used only for its intended purpose and only in the equipment for which it
was produced, unless otherwise directed by the CA for the key. Refer to the ITSG-13 for more
information on the purpose and use of key material.
11.1.2 Labels
Except for the labels affixed to protective packaging at a production facility and the CSEC
authorized barcode labels approved for the COMSEC Accounting, Reporting and Distribution
System (CARDS), no other labels may be affixed to the protective packaging of any key
material.
11.1.3 Protective Packaging
Certain items of COMSEC material are protectively packaged at the time of production and will
not, in most cases, be opened until issued to an authorized user. The protective packaging must
be inspected for signs of tampering upon initial receipt, during inventory, before transfer or issue
and before destruction of sealed key material. Protective packaging applied to individual items of
TOP SECRET key must be removed under TPI controls.
11.1.4 Key Tape in Canisters
11.1.4.1 Sealed Key Tape
Key material in its original canister is considered to be protectively packaged and sealed. The
following applies to key tape in canisters:
Do not segment check punched key tape in sealed plastic canisters.
Issue the entire canister to the Local Element and annotate the HI/DR card with the short
title, edition, register number and classification of the key material. However, when
warranted and approved by the CA, before the effective date of use, individual segments
may be issued using the HI/DR card. Remove the label containing the short title, edition
and registration number from the outside of the canister before distribution.
Seal individual segments which were authorized for pre-exposure in an envelope, along
with a copy of the CA approval, and stored in the plastic bag containing the associated
key tape canister.
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Do not remove more segments than required for current use and, as each segment is
removed, appropriately initial and date the HI/DR card.
11.1.4.2 Unauthorized Removal of Key Tape
When a segment(s) of key tape is unintentionally removed from its protective packaging before
its effective period, the removal of the segment must be reported to the CA for disposition
instructions. Disposition instructions may include destruction of the pre-exposed segment or
resealing the segment. The documentation of unintentional removal must include:
a statement that the segment was unintentionally removed
identity of segment(s) actually removed
date of removal
signature(s) of the individual(s) who removed the segment, and
reference to CA approval.
Key discovered removed from its protective packaging before its effective date, with no
documentation validating that the removal was unintentional, must be reported as a COMSEC
incident in accordance with Chapter 16.
11.1.5 Electronic Key Material on Magnetic or Optical Media
The COMSEC Custodian must ensure that protective packaging on magnetic or optical medium
used for the distribution of electronic key material is not opened until required for use.
11.1.6 Electronic Key on a Key Storage Device
The COMSEC Custodian must ensure that protective packaging for electronic seed or
operational key material received on a key storage device is not opened before operational use.
The key storage device will normally be attached to a label bearing the identification information
for the electronic key and will be sealed in a plastic bag or in thermoplastic film.
11.1.7 Copies of Key
11.1.7.1 Operational Symmetric Key
Operational key may be copied, in whole or in part, as authorized by the CA for the key and in
accordance with equipment doctrine (see also Article 11.1.7.3). The following rules apply:
Retain the short title of the key being copied.
Safeguard the copies according to their classification and CRYPTO caveat (if
applicable).
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Do not retain the copies beyond the destruction date for the key from which they were
copied (they may be destroyed before this date).
Destroy the copies before destroying the original key from which the copies were made.
Locally account for the copies using a manual tracking system when equipment or system
audit trails are not available.
11.1.7.2 Test Symmetric Key
Test key may be copied and locally accounted for within a COMSEC Account. If the test key is
transferred to another COMSEC Account, all copies must be destroyed.
11.1.7.3 Asymmetric Key
Copying of any asymmetric key is absolutely forbidden.
11.1.8 Two Person Integrity Controls
TPI controls must be applied to unencrypted TOP SECRET key material and other specified key
material from the time of production to destruction unless:
the TOP SECRET key is resident in the crypto-equipment that is built to preclude access
by an individual to the TOP SECRET key; or
the key material has been issued for use in tactical situations.
11.2 Accountable COMSEC Equipment
11.2.1 Sight Verification
The COMSEC Custodian must verify the completeness of COMSEC equipment upon initial
receipt, during inventory, and before transfer or issue.
11.2.2 Equipment Labels
Manufacturing labels (includes the equipment nomenclature plate, the CCI label, anti-tamper
labels, and any other labels attached by the manufacturer that identify the equipment for
accounting purposes) must not be removed or covered, unless specifically authorized to do so by
CSEC. Unauthorized labels inhibit scrutiny of equipment for evidence of tampering; therefore,
except for the labels affixed to protective packaging at a production facility and the CSEC
authorized barcode labels approved for CARDS, no other labels are to be placed on COMSEC
equipment unless specifically authorized by CSEC. Contact COMSEC Client Services at CSEC
for additional detail. Visible signs of tampering of labels must be reported as detailed in
Chapter 16.
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11.2.3 Modification
Modification of any kind (includes unauthorized labelling) to COMSEC equipment may only be
made upon before approval of COMSEC Client Services at CSEC. Approved modifications to
COMSEC equipment must be done by authorized and qualified personnel.
11.2.4 Equipment Installed for Operational Use
The COMSEC Custodian must ensure that:
equipment installed for operational use is protected based on the classification of the
equipment or the key material, whichever is higher; and
authorized procedures have been put in place to prevent unauthorized use of the
equipment or extraction of its key.
11.2.5 Key Storage/Fill Equipment Containing Key Material
11.2.5.1 Common Fill Devices Containing Unencrypted Key
Common Fill Devices (e.g. KYK-13) that store key in unencrypted form and provide no record
of transactions must not be used for long term storage of key. Key may be held in this device no
longer than 12 hours after the end of the applicable cryptoperiod. This type of device must be
marked to show the highest classification of the key contained and must be kept under TPI
controls whenever it holds TOP SECRET key.
11.2.5.2 Tier 3 Management Devices Containing Encrypted Key
Tier 3 Management Devices (T3MD) that store key in encrypted form must be used in
accordance with the applicable equipment doctrine.
11.2.5.3 Magnetic or Optical Media Containing Key
Magnetic or optical media containing unencrypted electronic key must be returned to secure
storage after the key or associated data has been loaded into the end equipment. Removable
magnetic or optical storage media holding key material must be marked to show the highest
classification of the key held and where applicable display the CRYPTO marking.
11.2.6 Equipment Audit Trails
11.2.6.1 Responsibility for Reviewing
The audit trails for COMSEC equipment must be reviewed as specified in equipment doctrine.
11.2.6.2 Reviewing Audit Trails
The individual authorized to monitor the audit trail data must:
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not be the primary COMSEC equipment user;
be a Canadian citizen (including dual nationality), be COMSEC briefed and hold a valid
GC security clearance equal to the classification level of the audit trail data being
reviewed;
have sufficient knowledge concerning the authorized use of the applicable COMSEC
equipment and the key material stored or filled in the COMSEC equipment;
confirm only authorized copies of key material are made;
be able to detect any anomalies in the audit trail data; and
send a record of the conduct of the audit trail review to the COMSEC Custodian.
11.2.6.3 Retention of Audit Logs
Audit logs must be retained as detailed in Article 4.2.4, or as detailed in the applicable
equipment doctrine if different from this directive.
11.2.6.4 Retention of Records of Audit Trail Reviews
The COMSEC Custodian must retain a record of the completion of audit trail reviews until the
COMSEC Account receives an Annual Inventory Reconciliation Notification letter attesting that
the account inventory has been reconciled. Any previous audit trail data can then be destroyed.
11.3 Accountable COMSEC Publications
11.3.1 Reproduction
Accountable COMSEC publications may be reproduced upon specific written authorization from
the originator. Instructions for reproduction of extracts will be contained in the publication’s
handling instructions. Publications that are authorized for reproduction must be reproduced by
the COMSEC Custodian unless they are authorized for reproduction under a Private Sector
contract. Refer to Annex A of this directive for information on the reproduction of accountable
COMSEC publications under a Private Sector contract.
11.3.2 Frequency of Page Checks
Unsealed key material (i.e. not protectively packaged), accountable COMSEC publications and
amendments to accountable COMSEC publications must be page checked:
during each COMSEC Account inventory
upon receipt
before transfer and issue
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before routine destruction, and
after posting any amendment (includes removal of pages and/or replacement of pages).
11.3.3 Conducting Page Checks
11.3.3.1 Requirement
The COMSEC Custodian (or other authorized individual) must conduct a page check of unsealed
COMSEC material to ensure the presence of all required pages. To conduct the page check, the
presence of each page must be verified against the “List of Effective Pages” or the “Handling
Instructions”, as appropriate.
11.3.3.2 No Missing Pages
If there are no missing pages, the “Record of Page Checks” page must be signed and dated. If the
COMSEC material has no “Record of Page Checks” page, the notation must be placed on the
cover.
11.3.3.3 Missing Pages
If any pages are missing, the “Record of Page Checks” page must be annotated accordingly and a
COMSEC Incident Report must be submitted in accordance with Chapter 16. When pages are
missing upon initial receipt of COMSEC material from a production facility, the COMSEC
Custodian must notify the issuing authority and request disposition instructions (e.g. transfer
back for replacement, destroy, use with missing page).
11.3.3.4 Duplicate Pages
In the case of duplicate pages, the COMSEC Custodian must prepare a Possession Report in
accordance with Chapter 6 and notify NCOR/COR for disposition instructions of the duplicate
page(s). The Possession Report must list the page number as part of the short title
(e.g. AMSG 600, page 3) and list the accounting number assigned to the COMSEC material. A
notation of the duplicate page(s), and the resultant disposition of the duplicate page(s), must be
entered on the “Record of Page Checks” page.
11.3.4 Amendments to Accountable COMSEC Publications
11.3.4.1 Printed Amendments
The COMSEC Custodian must account for the printed amendment as an accountable COMSEC
publication in accordance with its respective ALC until the printed amendment has been posted
and its residue destroyed. Care should be taken when preparing the Destruction Report to ensure
that the short title, edition, and accounting number of the amendment are reported (rather than
that of the publication). Printed amendments must be entered in sequence. If one is received and
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the previous amendment(s) have not been entered they must be entered (or acquired and entered)
before processing the latest amendment.
11.3.4.2 Message Amendments
A message amendment is used to announce information that must be immediately entered into an
accountable COMSEC publication. Post the amendment and note the entry on the “Record of
Amendments” page, then file the message amendment according to its security classification or
protected level and ALC. Message amendments must be entered in sequence. If one is received
and the previous amendment(s) have not been entered they must be entered (or acquired and
entered) before processing the latest amendment.
11.3.4.3 Posting Amendments
The following applies to the posting of amendments:
The COMSEC Custodian (or other authorized individual) must post the amendment as
soon as possible after its receipt (or effective date).
Personnel who is authorized to post amendments must be appropriately trained.
Specific instructions contained in the letter of promulgation or handling instructions must
be read and understood before posting amendments.
Entire amendments must be posted at one time, and not extended over a period of time.
If replacement pages are included in an amendment, page checks of both the publication
and the residue of the amendment must be made before destruction of the residue.
Inadvertent destruction of the effective portions of publications along with the residue
from amendments must be reported as a COMSEC incident in accordance with
Chapter 16.
Personnel posting amendments must annotate the posting of the amendment on the
“Record of Amendments”. If pages were added to or removed from the publication, date
and sign the “Record of Page Checks” page.
Personnel, other than the COMSEC Custodian, posting amendments must return all
residue of the amendment (including any pages removed from the publication) to the
COMSEC Custodian for destruction.
Amendment residue must be placed in a sealed envelope marked with the short title,
accounting number, and the classification of the amendment.
Amendment residue must be destroyed within five working days after entry of the
amendment.
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11.4 Local Tracking of Other Associated Material
11.4.1 Local Tracking System
Certain material (e.g. CIKs, PINs, configuration disks) associated with COMSEC equipment,
which cannot be controlled within NCMCS, must be controlled by the COMSEC Custodian
through a local tracking and control system. It is the responsibility of the originating authority to
identify this material. Control and handling of this material will be according to this directive,
unless otherwise specified by the applicable equipment doctrine or the originator.
11.4.2 Control and Protection of Crypto Ignition Keys
The COMSEC Custodian must locally track CIKs using departmental procedures that will
minimize any potential for compromise associated with their use. Local tracking procedures for
CIKs will include:
maintaining a record of each CIK created, including the serial number of the CIK (if
possible), the serial number of the associated equipment, location of the equipment, date
equipment was keyed, and name of each authorized user;
ensuring each CIK is signed for and held by the authorized user to whom it has been
issued and verifying, at least annually, that all authorized users still hold their CIK;
shipping CIKs (separately from their associated equipment) in a COMSEC channel
approved by CSEC;
providing adequate storage for a CIK when it is not held under the personal control of the
authorized user;
zeroizing or destroying CIKs that are no longer required; and
developing procedures for detecting potential compromises.
11.4.3 Record of Personal Identification Numbers and Passwords
When a written record of PINs or passwords is required, the COMSEC Custodian must ensure:
the record contains of the name and telephone number of individual(s) having knowledge
of the PIN or password, the serial number of the associated equipment, location of the
equipment, and the date the PIN or password was changed;
the record of PINs or passwords is safeguarded as directed by its classification or the
classification of the associated equipment, whichever is higher;
access to individual PINs or passwords is restricted to the individual to whom it is
assigned, unless an emergency situation dictates otherwise; and
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the record of PINs and passwords or individual PINs and passwords are distributed via
COMSEC channels or via approved methods for classified material.
11.4.4 Change of Personal Identification Numbers and Passwords
The COMSEC Custodian must ensure that PINs and passwords for COMSEC equipment are
changed as detailed in the specific equipment doctrine. Where direction is not otherwise
provided, the PIN or password must be changed when:
the equipment is first put into use by the COMSEC Custodian;
an individual knowing the PIN or password ceases to have authorized access to the
equipment;
an unauthorized individual has had access to the written record of the PIN or password;
the PIN or password is known or suspected to have been compromised; and
the PIN or password has not been changed in the last six months.
11.4.5 Storage of Personal Identification Numbers and Passwords
When records of PINs or passwords, or a list of PINs and passwords need to be maintained, they
must be safeguarded and managed by an appropriate DCA or COMSEC Custodian who must
mark and protect the record in accordance with the minimum classification level of the highest
classification of the material being protected by the PIN or password.
11.4.6 Configuration Disks
The COMSEC Custodian must ensure the label on the equipment configuration disk identifies
the equipment to which it belongs, the date it was created, and its classification. Local tracking
includes recording the information on the label, the name of the individual responsible for the
control of the disk and the location of the associated equipment.
11.4.7 Software Upgrades
All software upgrades must be approved by COMSEC Client Services at CSEC. The COMSEC
Custodian must control the equipment software upgrade process to ensure that all operational
COMSEC equipment, and those held in reserve, are compatible. All mandatory software
upgrades must be completed by the date authorized by CSEC.
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12 Destruction/Disposal of Accountable COMSEC Material
12.1 General Requirement
COMSEC material must never be destroyed without specific authorization, unless the risk of
compromise in a hazardous situation or in an emergency is greater than the security in place to
prevent the compromise. It is imperative that routine destruction of COMSEC material be
performed promptly, in order to keep to a minimum the amount of COMSEC material that would
require destruction in an emergency.
12.2 Destruction of Key Material
12.2.1 Scheduling Destruction of Key Material
Superseded key is normally authorized for destruction when the next edition becomes effective,
unless directed otherwise by the CA for the key material.
12.2.2 Unavailability of Destruction Devices
COMSEC material that can not be zeroized or destroyed at the COMSEC Account must be
transferred to the NDA at CSEC for destruction.
12.2.3 Conditions Affecting Destruction of Key Material
Destruction requirements for key material will vary depending on whether the key:
is marked CRYPTO
has been issued for use
remains sealed in secure storage
is involved in an emergency supersession, or
is defective.
12.2.4 Key Material Issued for Use
Superseded key material, whether regularly or irregularly superseded, must always be destroyed
within 12 hours of supersession except in the following circumstances:
In the case of an extended holiday period or when special circumstances prevent
compliance with the 12-hour rule (e.g. destruction facility not operational), key material
must be destroyed as soon as possible and should not be held longer than 72 hours
following supersession.
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Where authorized destruction devices are not available, superseded key must be
destroyed as soon as practicable upon completion of operations.
Magnetic or optical media which contained electronic key must be destroyed within three
working days of receipt.
The destruction of KEK must be accomplished as soon as it is filled into the COMSEC
equipment unless specific equipment or systems doctrine allows retention.
Key material involved in compromised situations must be destroyed within 72 hours after
disposition instructions are received and the Destruction Report sent to NCOR/COR
immediately following destruction.
12.2.5 Sealed Key Material
Superseded segments of sealed key material (whether issued or unissued) need not be destroyed
until the entire edition is superseded or the segment is unsealed – whichever occurs first. When
retained until the entire edition is superseded, destroy:
key marked CRYPTO no later than five working days after supersession; and
other key no later than five working days after the first of the month in which the
supersession occurs.
“Sealed” key material is key that either remains unopened in its original protective packaging or
which has been resealed in accordance with Article 11.1.4. Canister packaged key material is
considered sealed even if one or more segments have been removed for use provided the
removed individual segments have been resealed and stored in accordance with Article 11.1.4.1.
12.2.6 Emergency Supersession
Key material involved in an emergency supersession must be destroyed in accordance with the
CA instructions.
12.2.7 Defective Key Material
Damaged or defective key material must not be destroyed at the COMSEC Account. The
COMSEC Custodian must immediately report the matter to the appropriate CA for instructions.
Defective key material must be transferred to the NDA at CSEC for evaluation and destruction
as authorized (i.e. physical destruction, zeroization or making the key useless).
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12.3 Destruction/Disposal of COMSEC Equipment
COMSEC equipment, including CCI, must not be destroyed, dismantled or cannibalized without
specific authorization from COMSEC Client Services at CSEC. Requests for destruction of
COMSEC equipment will be evaluated on a case-by-case basis. Refer to the Canadian
Cryptographic Doctrine for the Disposal of Accountable COMSEC Equipment (CCD-49) for
information on the disposal of surplus, obsolete or unserviceable COMSEC equipment.
12.4 Destruction of COMSEC Publications
COMSEC publications must be destroyed within 15 working days following the date of
supersession or the authorized date of destruction. COMSEC publications must be page checked
no more than 48 hours before their destruction.
12.5 Performing Routine Destruction
12.5.1 Personnel
12.5.1.1 COMSEC Custodian and Alternate COMSEC Custodian
The COMSEC Custodian and the Alternate COMSEC Custodian will normally perform routine
destruction of COMSEC material. However, granting the authority to destroy superseded
COMSEC material to other appropriately cleared and COMSEC briefed individuals (who then
verify the destruction to the COMSEC Custodian) is preferable to delaying destruction, even for
a short time.
12.5.1.2 Local Element
A Local Element may be granted the authority to destroy key material in the presence of an
appropriately cleared and COMSEC briefed witness, if an approved destruction device is
available. If an approved destruction device is not available, the key material must be returned to
the COMSEC Custodian for destruction.
12.5.1.3 Witness
The destruction of all physical material and electronic key on physical media must be witnessed.
Two authorized individuals must personally witness the complete destruction or zeroization of
the COMSEC material. The zeroization (i.e. destruction) of electronic key may or may not
require a witness depending on whether the system records an audit trail. Refer to the specific
equipment doctrine for direction.
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12.5.2 Training
The COMSEC Custodian must ensure that the individuals whom they authorize to destroy
COMSEC material are:
cleared to the highest classification of the COMSEC material being destroyed;
briefed on the correct procedures and methods of destruction; and
trained in the use of authorized destruction devices.
12.5.3 Performing Physical Destruction
The following steps must be carried out by the two individuals performing the destruction:
a. Verify that the material to be destroyed is authorized for destruction before listing the
material on the Destruction Report.
b. Perform equipment verification and page checking before destruction (normally, no earlier
than 48 hours before the scheduled destruction).
c. List all material to be destroyed on the Destruction Report in accordance with Article
6.3.8. Use the (unsigned) Destruction Report (or HI/DR card or other local destruction log)
as a “check list” during the destruction process to ensure that the correct COMSEC
material will be destroyed.
d. If sufficient destruction facilities are not available and the individuals carrying out the
destruction have been authorized to transport the COMSEC material –
i Place the material listed for destruction in burn bags or other destruction containers.
ii Seal and mark the containers in accordance with the appropriate classification or
protected level (if there is more than one container they must be individually
numbered (e.g. 1 of 2, 2 of 2, etc.).
iii Transport the material directly to the location where the destruction is to take place.
e. Immediately before destruction, verify the material being destroyed (short title, edition,
accounting number, and quantity for each item) against the Destruction Report (or HI/DR
card or other local destruction log) ensuring that all accounting information is correct.
f. Immediately destroy the material using approved destruction methods.
g. Examine the destruction device and the surrounding area to ensure that all material has
been destroyed.
h. Thoroughly inspect the residue to ensure that the destruction was complete.
i. Sign and witness the Destruction Report (or HI/DR card or other local destruction log)
unless the specific equipment doctrine specifies that a witness is not required. The
Destruction Report must not be signed until the complete destruction of the listed material
is confirmed.
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12.6 Routine Destruction Methods
12.6.1 Paper COMSEC Material
12.6.1.1 Overview
The destruction criteria listed in the following articles apply to classified COMSEC key material,
and to media which embody, contain, describe, or implement a classified cryptographic logic.
Other paper COMSEC material may be destroyed by any means approved for the destruction of
paper COMSEC material of equal classification or protected level.
NOTE:
Where possible, burning or pulverizing should be used as the preferred method for
ensuring the terminal destruction of COMSEC material.
12.6.1.2 Incineration
The burning of paper COMSEC material must be complete (so that all COMSEC material is
reduced to white ash) and contained (so that no unburned pieces escape). Ashes must be
inspected and, if necessary, broken up.
12.6.1.3 Pulverizing, Chopping or Pulping
Pulverizing, chopping or pulping devices used to destroy paper COMSEC material must reduce
the COMSEC material to bits no larger than five millimeters (1/5 inch) in any dimension.
NOTE: DO NOT PULP paper-Mylar-paper key tape or high wet strength paper (map stock)
and durable-medium paper substitute (e.g. TYVEC olefin, polyethylene fibre). These
materials will not reduce to pulp and must be destroyed by burning, pulverizing,
chopping or cross-cut shredding.
12.6.1.4 Cross-cut Shredding
In GC departments where burning or pulverizing are not feasible, approved Type II shredders
may be used as a first step in the destruction process. However, the residue from the shredders
must not be considered as a “terminal” destruction. Where cross-cut shredding is used as the first
step, the waste from the shredders must be:
retained and stored as classified waste and securely transported to a facility that is
capable of burning or pulverizing the shredded residue; or
dispersed in a method that will prevent or preclude collection of all portions of a key
segment such as –
o separating into small amounts (handfuls) and mixing with other shredded material of
the same color and texture and then transferring it to multiple and random trash
containers;
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o flushing mixed shredded residue down a toilet to prevent reconstruction; or
o dispersing (loosely) the shredded residue overboard (for ships at sea with limited
storage).
NOTE 1: Type II shredders must reduce the material to shreds not more than 1.0 mm wide and
14.3 mm long. Type II shredders must be highly maintained and free of any defect
that would output larger waste size.
NOTE 2: Because coloured material has the added vulnerability of instant recognition, it
should be held over for burning or pulverizing after shredding.
12.6.2 Non-Paper COMSEC Material
12.6.2.1 Microforms
Microfilm, microfiche, or other reduced-image photo negatives may be destroyed by burning, or
by chemical means. When destroying by chemical means, film sheets must be separated, and roll
film must be unrolled. Chemical destruction may be performed by immersing (for approximately
five minutes or more) silver film masters in household bleach and by immersing diazo
reproductions in acetone or methylene chloride.
NOTE: Health and safety requirements must be adhered to and caution must always be
exercised when using chemical methods of destruction. Read and follow all warning
and cautionary labels on chemical containers.
12.6.2.2 Magnetic and Optical Media
The method of disposal (e.g. degaussing, overwriting, zeroization or physical destruction) for
magnetic media (e.g. floppy disks, hard drives and back-up tapes) and optical media
(e.g. compact disks [CD] and digital versatile disks [DVD]) must be consistent with the
individual system and equipment doctrine, CSEC Clearing and Declassifying Electronic Data
Storage Devices (ITSG-06) and the RCMP Security Equipment Guide (G1-001). General
guidelines include:
Magnetic backup tapes, when no longer required or unserviceable, may be destroyed by
disintegration, incineration or shredding.
Magnetic cores may be destroyed by incineration or smelting.
Magnetic disks, disk packs and drums may be destroyed by incinerating or by removal of
the entire recording surface by means of an emery wheel or disc sander.
Floppy disks may be destroyed by shredding, in accordance with regulations for
shredding a floppy disk which contains classified data.
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12.6.2.3 Hardware Keying Material
Contact COMSEC Client Services at CSEC for authorization for destruction (or disposal) of
hardware key material, such as Programmable Read Only Memories, and permuting plugs and
their associated manufacturing aids.
12.6.2.4 Electronic Key Material
The destruction of electronic key is accomplished by zeroization or overwriting of the key.
For specific instructions on the destruction or zeroization of electronic key loaded in equipment
refer to the appropriate equipment doctrine.
12.6.2.5 Plastic Canisters
Empty canisters must be fractured or smashed to ensure all key segments have been removed,
and then disposed of as unclassified waste. The unauthorized retention of intact key tape
canisters is a COMSEC incident.
12.7 Approved Routine Destruction Devices
Information regarding routine destruction devices which have been tested and approved by
CSEC may be obtained from COMSEC Client Services at CSEC.
12.8 Emergency Destruction Priorities
12.8.1 Priorities within Categories
12.8.1.1 General
When sufficient personnel and destruction facilities are available, different individuals should be
made responsible for destroying the COMSEC material in each of the following three categories
(Key Material, COMSEC Publications and COMSEC Equipment).
12.8.1.2 Key Material
Emergency destruction priorities for key material are:
a. superseded key material marked CRYPTO
b. currently effective key material marked CRYPTO (to include the zeroization of key
variables stored electrically in crypto-equipment and fill devices)
c. future editions of TOP SECRET key material marked CRYPTO
d. future editions of SECRET and CONFIDENTIAL key material marked CRYPTO, and
e. training and maintenance key.
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12.8.1.3 COMSEC Publications
In deteriorating conditions, consideration must be given to destroying all full maintenance
manuals (i.e. those containing cryptographic logic information) that are not absolutely essential
to continued mission accomplishment. When there is insufficient time under emergency
conditions to completely destroy such manuals, every reasonable effort must be made to remove
and destroy their sensitive pages (i.e. those containing cryptographic logic).
Emergency destruction priorities for classified COMSEC publications and other classified
publications are:
a. COMSEC publications marked CRYPTO
b. status documents showing the effective dates for key material
c. complete crypto-equipment maintenance manuals (or the sensitive pages thereof)
d. the remaining classified pages of crypto-equipment maintenance manuals
e. classified cryptographic and general (non-cryptographic) publications
f. cryptographic operating instructions
g. the remaining classified COMSEC publications, and
h. national and departmental doctrinal guidance publications.
12.8.1.4 COMSEC Equipment
In deteriorating conditions, all reasonable efforts must be made to evacuate COMSEC
equipment. During an actual emergency, when evacuation may not be possible, the immediate
goal is to render COMSEC equipment unusable and irreparable. Consequently, when there is
warning of hostile intent, consideration must be given to discontinue secure communications to
allow for the thorough destruction of COMSEC equipment. Emergency destruction priorities for
COMSEC equipment are:
a. zeroization of equipment, if the keying element (e.g. key card, permuter plug) cannot be
physically withdrawn
b. destruction of removable classified and CCI components (e.g. printed circuit boards), and
c. destruction of remaining classified and CCI components.
The hulks (bodies or casings) of equipment, and unclassified devices not marked CCI, need not
be destroyed.
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12.8.2 Priorities for Combined Categories
When personnel or destruction facilities are limited, the three categories of COMSEC material
must be combined, in which case the destruction priorities are:
a. all key material marked CRYPTO, in the following order –
i superseded key, in descending order of classification or protected level from
TOP SECRET
ii currently effective key, in descending order of classification or protected level from
TOP SECRET, and
iii future key material, in descending order of classification level from TOP SECRET;
b. COMSEC publications marked CRYPTO and status documents showing the effective
dates for key material;
c. classified pages from classified maintenance manuals (or the entire manual if classified
pages are not separately identified);
d. classified and CCI components of classified equipment and CCI;
e. any remaining classified COMSEC material or other classified material; and
f. any other COMSEC material.
12.9 Emergency Destruction Methods
Any of the methods approved for the routine destruction of classified COMSEC material may be
used for emergency destruction. Incendiary destruction devices may be available at certain
locations outside Canada. Information concerning these devices is available from COMSEC
Client Services at CSEC. Basic hand tools (e.g. hammer, cold chisel, screwdrivers, pliers,
crowbar, fire axe, sledge hammer) should be readily available for the emergency destruction of
COMSEC equipment.
12.10 Reporting Emergency Destruction
Accurate and timely reporting of emergency destruction is essential in order to evaluate the
severity of an emergency, and is second in importance only to ensuring that the COMSEC
material is thoroughly destroyed. A report must be submitted to NCOR/COR as soon as possible.
The report must clearly indicate, for the destroyed COMSEC material, the method(s) of
destruction, and the degree of destruction. This report must also identify any items that were not
destroyed and which may be presumed compromised. In such cases, a COMSEC Incident Report
must be submitted, as detailed in Chapter 16.
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13 COMSEC Account Inventory
13.1 Reasons for Inventory
An inventory is the verification of a COMSEC Account’s holdings. NCOR/COR maintains a
database that reflects all ALC 1, ALC 2 and ALC 6 COMSEC material charged to the COMSEC
Account. The data is taken from COMSEC Material Reports (e.g. Destruction, Possession) that
COMSEC Accounts submit to NCOR/COR. COMSEC Material Reports that were processed by
the account but were not entered in NCOR/COR database will result in a discrepancy between
NCOR/COR database and the COMSEC Account records.
Inventories serve to ensure that:
COMSEC Account records are up-to-date;
NCOR/COR database is up-to-date by verifying that all COMSEC Material Reports have
been forwarded to NCOR/COR and have been processed by NCOR/COR;
COMSEC material charged to a COMSEC Account is actually on-hand and sighted by
authorized personnel; and
COMSEC material charged to a COMSEC Account is still required for use by the
account.
13.2 Types of Inventory
13.2.1 Annual Inventory
The COMSEC Custodian and the Alternate COMSEC Custodian must conduct an annual sight
inventory of all ACM in their COMSEC Account (including all Local Elements and COMSEC
Sub-Accounts).
NCOR/COR will distribute an Inventory Report annually that lists all accountable material
charged to the COMSEC Account as of the date of printing. A sight inventory must be conducted
to verify the presence of all –and only– material listed on the report. The COMSEC Custodian
must return the signed Inventory Reports to NCOR/COR no later than 10 working days after the
initial receipt of that report.
13.2.2 Change of COMSEC Custodian Inventory
In cases of sudden (indefinite or permanent) departure of the COMSEC Custodian, a newlyappointed
COMSEC Custodian must conduct a sight inventory of all COMSEC material in the
COMSEC Account before the formal COMSEC Custodian handover.
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Upon completion of the inventory, the new COMSEC Custodian must sign the Inventory Report
as the Custodian. The new COMSEC Custodian, except for discrepancies being resolved,
assumes responsibility for all ACM in the account.
13.2.3 Special Inventory
The COMSEC Custodian must complete a special inventory when directed to do so by
NCOR/COR and DCA. Special inventories may be requested for reasons such as the suspected
loss of COMSEC material or frequent deviation from accounting procedures.
The procedures used for an annual inventory must be used for a special inventory.
13.3 Inventory Reports
13.3.1 National Central Office of Record/Central Office of Record-Initiated
Inventory Report
NCOR/COR-initiated Inventory Reports are distributed to COMSEC Accounts to announce the
beginning of the inventory process. Each Inventory Report lists all ALC 1, ALC 2 and ALC 6
COMSEC material that have been recorded in the NCOR/COR database for the respective
COMSEC Account as of the date of the printing of the Inventory Report.
NOTE: CSEC has approved the use of several automated accounting/management systems
with terminology and procedures that are quite distinct from each other. Each GC
department is responsible for ensuring that its custodial personnel is trained in the use
of its automated system and are familiar with the terms used by the respective software
to describe activities during the inventory process.
13.3.2 COMSEC Account Inventory Report
Inventory Reports produced by the COMSEC Custodian at a COMSEC Account may be directed
at two different audiences:
Within the COMSEC Account, where they may be distributed for use during the physical
sighting of on-hand material.
At NCOR/COR, in order to report the complete holdings of the COMSEC Account.
13.3.2.1 Distribution within the COMSEC Account
The COMSEC Custodian prepares Inventory Reports for internal distribution to Sub-Account(s)
and Local Elements. These Inventory Reports list all ALC 1, ALC 2, ALC 4, ALC 6 and ALC 7
COMSEC material that the COMSEC Custodian has issued to elements within the COMSEC
Account and which are still out on loan. Instructions for the completion of an Inventory Report
can be found with the GC-223 form.
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13.3.2.2 Distribution to National Central Office of Record/Central Office of
Record
The COMSEC Custodian compiles the results of all Inventory Reports that were distributed
within the account and return an Inventory Report to NCOR/COR. This report contains all
ALC 1, ALC 2 and ALC 6 COMSEC material held by the COMSEC account.
13.3.3 Amendment to Inventory Report
The Amendment to Inventory Report is used to report any discrepancies between the COMSEC
Account’s inventory and NCOR/COR-initiated Inventory Report. For example, if the COMSEC
Account failed to submit a Destruction Report to NCOR/COR, all the material destroyed by the
account, which was listed on the Destruction Report, would not be recorded in NCOR/COR
database. Consequently, NCOR/COR-initiated Inventory Report would list that material as being
on-hand at the COMSEC Account. An Amendment to Inventory Report would provide the details
of the missing Destruction Report. When submitting the Amendment to Inventory Report, the
COMSEC Custodian must attach all supplemental accounting reports in order for NCOR/COR to
proceed with the inventory reconciliation.
13.4 Inventory Process
13.4.1 Scheduling the Sight Inventory
The COMSEC Custodian must ensure that a sight inventory of the entire COMSEC Account is
carried out during an inventory. Before the expected receipt of the annual NCOR/COR-initiated
Inventory Report, the COMSEC Custodian must:
Generate a COMSEC Account Inventory Report.
Conduct a sight inventory of COMSEC material that has been issued to Local Elements
or direct the Local Element to do so with an appropriate witness.
Direct each COMSEC Sub-Account Custodian to conduct a sight inventory of COMSEC
Sub-Account holdings in the same manner as described for a COMSEC Account
inventory.
Conduct a sight inventory of the COMSEC material on-hand, under the direct custody of
the COMSEC Custodian.
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13.4.2 Conducting the Sight Inventory
The COMSEC Custodian will provide an Inventory Report for personnel conducting a sight
inventory of COMSEC material. The following applies when conducting a sight inventory of
COMSEC material:
The sight inventory must be conducted by two individuals who are appropriately cleared
and who have been COMSEC briefed.
The two individuals conducting the sight inventory must verify that the COMSEC
material on-hand agrees with the COMSEC Account Inventory Report.
Unsealed COMSEC publications and key material must be page checked.
COMSEC equipment in use does not need to be opened to verify it contains all the
required subassemblies and elements.
Removable assemblies that are listed separately on an inventory report and are not listed
on the equipment’s chassis must be physically sighted unless the equipment is
undergoing tests or is in operation.
Electronic key, which is stored in equipment that has a verifiable audit trail, may be
inventoried without a witness.
COMSEC Custodians are responsible to NCOR/COR for only the original ALC 6
electronic key distributed to the account or generated by the account. Copies of electronic
key are locally accountable.
13.4.3 Reconciling the COMSEC Account Inventory Report
13.4.3.1 Local Element Inventory Reconciliation
Persons conducting Local Element inventories may mark-up the Inventory Report to indicate
that material is on-hand or, conversely, that it is lost, missing or contains extra material. They
must both sign the Inventory Report before returning it to the COMSEC Custodian.
The COMSEC Custodian must reconcile the Inventory Reports returned from all Local Elements
with the COMSEC Account Inventory Report.
13.4.3.2 COMSEC Sub-Account Inventory Reconciliation
The COMSEC Sub-Account Custodian must return their signed Inventory Reports to the
COMSEC Account Custodian for reconciliation. If discrepancies are noted in any COMSEC
Sub-Account Inventory Report, the COMSEC Custodian must direct the custodian of that
COMSEC Sub-Account to take corrective action within 48 hours of receipt of such notice,
advise the COMSEC Custodian of the action taken and submit any substantiating reports
required.
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The COMSEC Custodian must reconcile the Inventory Reports returned from all COMSEC
Sub-Accounts with the COMSEC Account Inventory Report.
13.4.3.3 COMSEC Account Inventory Reconciliation
Upon receipt of NCOR/COR-initiated Inventory Report, the COMSEC Custodian must reconcile
the COMSEC Account holdings with NCOR/COR-initiated Inventory Report. This is
accomplished by conducting a sight inventory of all COMSEC material held by all elements
within the account and returning a signed Inventory Report to NCOR/COR.
13.4.3.4 Completion and Submission of Inventory Report and Supplements
Upon completion of the COMSEC Account inventory, the COMSEC Custodian and the witness
must sign and date the Inventory Report. The number of supplemental accounting reports and
pages of amendments must be entered on the last page of the Inventory Report. The Inventory
Report and the Amendment to Inventory Report with all supplemental COMSEC Material
Reports (if required) must be sent to NCOR/COR no later than 10 working days after receipt of
NCOR/COR-initiated Inventory Report. A signed copy of the Inventory Report must be retained
on file.
13.4.3.5 National Central Office of Record/Central Office of Record
Reconciliation of COMSEC Account Inventory Report
NCOR/COR will process Inventory Reports submitted by COMSEC Accounts.
If NCOR/COR notifies the COMSEC Account of discrepancies between the COMSEC Account
Inventory Report and NCOR/COR Inventory Report, the COMSEC Custodian must attempt to
resolve the discrepancies.
If the discrepancies are the result of missing COMSEC Material Reports, the COMSEC
Custodian must prepare and submit, within 48 hours, an Amendment to Inventory Report with all
supplemental COMSEC Material Reports to update NCOR/COR database.
If the sight inventory of the COMSEC Account is correct, and there are no missing COMSEC
Material Reports, NCOR/COR will issue an Inventory Reconciliation Report, which certifies the
inventory as being correct.
If the sight inventory reveals lost or missing COMSEC material or other discrepancies, a
COMSEC incident must be reported as detailed in Chapter 16. An Inventory Reconciliation
Report will not be issued until all discrepancies have been resolved or an investigation into the
incident has been completed and disposal instructions issued.
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14 COMSEC Emergency Plan
14.1 Preparing the COMSEC Emergency Plan
14.1.1 Requirement
Every GC department that holds COMSEC material must prepare a COMSEC Emergency Plan.
Consideration must be given to incorporating this plan into the Business Continuity Plan
established for the entire GC department. Procedures must emphasize maintaining security
control over the COMSEC material until order is restored without endangering life.
14.1.2 Development of the Plan
The DCA, in coordination with the COMSEC Custodian is responsible for the preparation,
implementation and annual re-evaluation of the COMSEC Emergency Plan. Coordination with
appropriate security, fire and safety personnel will ensure that the plan is realistic, workable, and
accomplishes the goals for which it is prepared. The duties under the plan must be clearly
described and the contact information for all individuals with duties under the plan must be
documented. Refer to the COMSEC Emergency Plan template for an outline and an emergency
destruction plan.
14.1.3 Maintaining and Testing the Plan
The COMSEC Custodian must ensure that:
all individuals are aware of the existence of the plan and how alerts and warnings to an
emergency event will be communicated;
each individual who has duties assigned under the plan receives detailed instructions on
how to carry out these duties when the plan is put into effect;
all individuals are familiar with all duties, so changes in assignment can be made if
necessary;
training exercises are conducted periodically, to ensure that all personnel (especially new
personnel) can carry out their duties; and
the plan is revised based on experience gained in the training exercises (if necessary).
14.1.4 Emergency Destruction Plan
If the COMSEC Emergency Plan calls for destroying COMSEC material, an emergency
destruction plan must be included. Refer to Chapter 12 for emergency destruction priorities and
methods of destruction.
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14.2 Planning for Emergency Events
14.2.1 Best Practices
14.2.1.1 COMSEC Accounts Operating in Normal Conditions
The COMSEC Custodian will organize normal operating routines such that the number and
complexity of the activities that must be taken during an emergency are minimized. The
COMSEC Custodian must ensure that:
only the minimum amount of COMSEC material necessary for operational and
contingency requirements are held by the COMSEC Account (see Table 2 in Chapter 9);
COMSEC material is stored in a manner that will facilitate emergency evacuation or
destruction;
routine destruction is always conducted promptly upon authorization;
excess COMSEC material is promptly disposed of in accordance with any disposition
instructions; and
COMSEC material prepared for use in an emergency is distributed without delay.
14.2.1.2 COMSEC Accounts Operating in Hazardous Conditions
COMSEC Accounts operating in hazardous conditions, where the risk of loss of key material due
to accident or capture is high must hold only the minimum amount of key material deemed
necessary to support mission requirements. Plans for the prompt re-supply of such COMSEC
Accounts, in the event of an emergency supersession, must be prepared and readily implemented
whenever needed.
14.2.2 Natural Disasters and Accidental Emergencies
Planning for a natural disaster or accidental emergency (e.g. fire, flood, tornado, or earthquake)
must provide for:
safety of all personnel;
notification of emergency event during normal business hours and after hours;
assignment of on-scene responsibility for ensuring the protection of COMSEC material;
protection or removal of COMSEC material in the event that the admission of
unauthorized individuals into the secure area(s) becomes necessary;
evacuation of the area(s);
assessment and reporting of the probable exposure of COMSEC material to unauthorized
individuals during the emergency;
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post-emergency inventory of COMSEC material and reporting of the loss or unauthorized
exposure of COMSEC material to the DCA;
identification of primary and secondary recovery sites, when recovery will not be
possible at the current location;
identification of critical resources required to support the recovery;
off-site storage facilities; and
business continuity during and business resumption following the emergency event.
14.2.3 Hostile Activity
14.2.3.1 Assessment of situations
Planning for potential hostile activity (e.g. enemy attack, civil uprising, riot) must concentrate on
the activities necessary to safely evacuate or securely destroy the COMSEC material (without
endangering life). It must take into consideration all possible situations which could occur, such
as those in which:
an orderly withdrawal could be conducted over a specified period of time;
a volatile environment exists such that destruction must be performed discretely in order
to avoid triggering hostilities; or
invasion or capture is imminent.
14.2.3.2 Consideration Factors
Some important factors to be considered when planning for hostile activity:
Likelihood of the various types of hostile actions and the threats that those actions pose.
Availability and adequacy of physical security protection (e.g. perimeter controls,
strength of guard forces, physical defences at locations which hold COMSEC material).
Availability of transportation and adequate storage facilities for emergency evacuation
and an assessment of the probable risks associated with emergency evacuation.
Availability and adequacy of facilities for emergency destruction of COMSEC material,
including approved destruction devices, electrical power, location, personnel, etc.
Requirement for, and availability of, external communications during emergency
situations. Unless there is an urgent need to restore communications after relocation, key
material should be destroyed rather than evacuated.
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14.2.3.3 External Communications
External communications during an emergency situation should be limited to contact with a
single remote point. This point will act as a distribution centre for outgoing message traffic and
as a filter for incoming queries and guidance, thus relieving site personnel from multiple
activities during the emergency. When there is a warning of hostile intent and the physical
protection is inadequate to prevent overrun of the facility, secure communications should be
discontinued in time to allow for thorough destruction of all COMSEC material.
14.2.3.4 Protecting COMSEC Material
The three options for the control of COMSEC material in an emergency due to hostile activity
are:
securing COMSEC material;
removing COMSEC material from the scene of the emergency; and
destroying COMSEC material.
Planners must consider which of the above options (singly or in combination) are applicable to
particular situations, and to their facilities. The option(s) from which to choose in various
situations should be clearly stated in the plan. The following two scenarios are provided as
examples:
If it appears that a civil uprising is to be short-lived and that the COMSEC facility is to
be only temporarily abandoned, the actions to take could be as follows –
o Ensure that all superseded key material has been destroyed.
o Gather up current and future key material and take it along if adequate security
protection is available or destroy it using approved methods.
o Zeroize the key from all keyed operational or on-standby equipment.
o Remove all classified and CCI components from crypto-equipment and lock them,
along with other classified COMSEC material, in approved storage containers.
o Secure the facility door(s) and leave.
o Upon return, conduct a complete inventory.
If it appears that the facility is likely to be overrun, the emergency destruction plan should
be put into effect.
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15 COMSEC Account Audit
15.1 Planning the Audit
15.1.1 Delegation of Authority
The PGS mandates that CSEC report to the TBS on the state of COMSEC in the GC when
requested. Compliance with this mandate requires CSEC to audit COMSEC Accounts on a
regular basis. In concert with international partnership agreements, the audit is also required to
ensure continued access to foreign COMSEC material. The COMSEC Account audit will
hereafter be referred to as simply an audit.
15.1.2 Purpose of an Audit
The audit provides an independent review of a COMSEC Account’s records and activities to
ensure COMSEC material produced by or entrusted to the COMSEC Account is controlled as
detailed in this directive.
15.1.3 Frequency of Audits
A CSEC representative will audit COMSEC Accounts at least once every 18 months. Audits
may be conducted more frequently based on:
previous audit findings;
size of the COMSEC Account inventory;
volume of COMSEC Material Reports;
frequency of deviation from COMSEC directive;
abnormal number of COMSEC Custodian changes; or
type of automated accounting system in use at the COMSEC Account.
15.1.4 Scheduling the Audit
Three weeks advance notice is normally provided. However, the audit may occur on short notice
when irregularities of a serious nature have occurred. The CSEC representative conducting the
audit will:
contact the COMSEC Account Custodian (usually via a phone call or e-mail) to schedule
the audit;
confirm the date and time of the audit, in writing; and
provide an audit check list that will be used as a guide during the audit.
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15.2 Conducting the Audit
15.2.1 Access to COMSEC Account Holdings
The CSEC representative(s) is (are) authorized to have supervised access to all COMSEC
Account reports, records and files, including electronic files and databases, upon presentation of
their CSEC identification badge and copy of their COMSEC Briefing Certificate.
NOTE: The CSEC representative(s) may require supervised access to COMSEC Sub-Account
and Local Element sites. COMSEC Sub-Account and Local Element audits must be
coordinated by the COMSEC Account Custodian (see Article 15.4.2).
15.2.2 Scope of the Audit
The audit must be sufficient in scope to determine the accuracy of COMSEC accounting records
and to confirm that COMSEC material control procedures have been, and continue to be,
correctly applied. The audit includes:
verification that accounting reports, records and files are complete and accurate;
verification of compliance with packaging, marking and distribution procedures;
verification of the consistent application of procedures and processes (including physical
security) related to the control, storage and use of COMSEC material;
assessment of the adequacy of automated accounting system controls;
a detailed audit of IP accounting records, if applicable;
verification of the completion of COMSEC Sub-Account audits, if applicable; and
discussion with the COMSEC Custodian regarding any problems encountered with the
control of COMSEC material or the maintenance the COMSEC Account.
15.2.3 Exit Interview
Upon conclusion of the COMSEC Account audit, the CSEC representative(s) will hold an exit
interview with the DSO, the DCA (if designated) and the COMSEC Custodian to advise them of
any situations that require immediate corrective action(s) and to brief them on the audit findings
and recommendations.
NOTE: If neither the DSO, nor the DCA is available, the CSEC representative(s) will
reschedule the exit interview.
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15.3 Audit Reporting
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15.3.1 COMSEC Account Audit Report
The COMSEC Account Audit Report will document all observations, recommendations and
required corrective actions. CSEC will provide the DCA with a copy of the COMSEC Account
Audit Report (in both English and French) within 15 working days of completion of the audit. If
corrective actions are required, a Statement of Action form will be included with the COMSEC
Account Audit Report.
15.3.2 Statement of Action Form
The COMSEC Custodian must complete the corrective actions stated in the COMSEC Account
Audit Report and return a signed Statement of Action form to CSEC within 10 working days of
receipt of the COMSEC Account Audit Report. If due to operational requirements, the required
corrective actions cannot be completed before the due date, CSEC may grant an extension to this
period.
15.3.3 Failure to Return a Statement of Action Form
CSEC will send a tracer notice to the DCA if the signed Statement of Action form is not received
when due. If a signed Statement of Action form is not returned to CSEC at the end of an
additional 10 working days following dispatch of the initial tracer notice, a second tracer notice
will be sent. After another five working days, following the second tracer, if the signed
Statement of Action has not yet been received by CSEC, the matter will be treated as a
COMSEC incident and forwarded to the NCIO for action.
15.4 COMSEC Sub-Account Audits
15.4.1 Requirement
The COMSEC Custodian must audit COMSEC Sub-Accounts(s), at least once every 18 months,
using the same considerations, and in the same manner, as detailed in this chapter.
15.4.2 Communications Security Establishment Canada Participation
Although COMSEC Custodians are normally responsible for conducting audits of their
COMSEC Sub-Accounts, CSEC may conduct an audit of a COMSEC Sub-Account, including
Local Elements, when irregularities of a serious nature have occurred.
NOTE: COMSEC Sub-Account and Local Element irregularities notwithstanding, CSEC may
request to collaborate with the COMSEC Account Custodian during routine audits.
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16 COMSEC Incidents
16.1 General
Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
A COMSEC incident occurs whenever there is a situation or activity that jeopardizes the
confidentiality, integrity or availability of COMSEC information, material or services.
Prompt and accurate reporting of COMSEC incidents minimizes the potential for compromise of
COMSEC material and the classified information that it protects. Unless all personnel who
handle or manage COMSEC material immediately report all occurrences that are specifically
identified as COMSEC incidents, corrective action cannot be implemented in a timely manner to
mitigate or eliminate their impact.
It is vitally important that all suspected COMSEC incidents be promptly reported to the
responsible DCA.
16.2 Classes of COMSEC Incidents
16.2.1 Compromising Incidents
Compromising incidents may have serious consequences for operational security. Investigation
of compromising incidents helps to determine if sensitive records were irretrievably lost by the
rightful owners or accessed by an unauthorized individual. It is important to note that the
compromise of sensitive information or asset(s) may have implications far beyond the local
authorized user or GC department. Compromising incidents are reportable at the national level
(report to COMSEC Custodian, DCA and NCIO).
16.2.2 Practices Dangerous to Security
Practices Dangerous to Security (PDS) are incidents that are considered minor violations of
administrative requirements and do not result in the loss of control, unauthorized access or
unauthorized viewing of COMSEC material. PDS are considered administrative infractions
and are not reportable at the national level. PDS do not result in a compromise of
information, assets or functionality, but create situations where exploitation is possible unless
action is taken to correct the practice. Even minor violations may warrant an evaluation.
Therefore, PDS must be handled locally by the DCA in accordance with departmental directives.
PDS include:
premature or out-of-sequence use of keying material without the approval of the CA
(report to CA, Custodian and DCA only)
inadvertent destruction of keying material without authorization of the CA, as long as the
destruction was properly performed and documented (only report to the CA, the
COMSEC Custodian and the DCA)
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removing keying material from its protective packaging prior to issue for use, or removing
the protective packaging without authorization, as long as the removal was documented,
the exposed key material was properly protected, and there was no reason to suspect
espionage (only report to the COMSEC Custodian and the DCA)
receipt of a package with damaged outer wrapper, but an intact inner wrapper (only report
to the COMSEC Custodian and the DCA)
incidents involving unclassified, non-registered documents, unclassified equipment not
marked CCI, and unclassified keying material not marked CRYPTO (only report to the
COMSEC Custodian and the DCA)
activation of the anti-tamper mechanism or unexplained zeroization of COMSEC
equipment as long as there were no other indications of unauthorized access or penetration
(only report to the COMSEC Custodian and the DCA)
NOTE: When these events occur (without explanation) to a KP, report as a National
COMSEC incident vice a PDS.
failure to zeroize key from a common fill device or T3MD within the time limits imposed
in Article 12.2.3 (only report to the COMSEC Custodian and the DCA)
destruction of COMSEC material not performed within required time limits (only report
to the COMSEC Custodian and the DCA)
loss of audit trail data in T3MDs due to the failure to upload when the time and means are
unavailable (only report to the COMSEC Custodian and the DCA)
16.3 Categories of COMSEC Incidents
16.3.1 Cryptographic Incidents
Cryptographic incidents are directly related to the improper or unauthorized use of key material
or cryptographic equipment or systems. The following examples of cryptographic COMSEC
incidents are not all inclusive. Additional reportable COMSEC incidents, which are unique to a
given cryptosystem or to a particular application of a cryptosystem, will be listed in the specific
system or equipment doctrine.
Such incidents include:
the use of key material which is compromised, superseded, defective, previously used
(and not authorized for reuse) or incorrectly used. For example the –
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o use of key material that was produced without CSEC authorization
o unauthorized use of any key material for other than its intended purpose
o unauthorized extension of a cryptoperiod, and
o premature use of key material;
the use of COMSEC systems, equipment, software, operational practices or maintenance
practices which are not approved by CSEC. For example –
o the operational use of COMSEC equipment without the completion of a required
alarm-check test or after the failure of an alarm-check test
o the maintenance of crypto-equipment by unauthorized or unqualified individuals, and
o tampering with, or unauthorized modification of a COMSEC component, equipment
or system;
the operational use of COMSEC equipment having defective cryptographic logic circuitry
or use of an unapproved operating procedure. For example –
o plain text transmission resulting from a COMSEC equipment failure or malfunction
o any transmission during a failure, or after an uncorrected failure that may cause
improper operation of COMSEC equipment, and
o compromising emanations from a COMSEC equipment or system while processing
classified information;
discussion via non-secure communications of the details of a crypto-equipment failure or
malfunction; and
any other unauthorized use of key material or cryptographic equipment.
16.3.2 Personnel Incidents
Personnel incidents are situations involving individuals who have access to COMSEC material,
which could jeopardize the security of that COMSEC material. Such incidents include:
known or suspected defection or treason;
known or suspected espionage or sabotage;
known or suspected subversion;
theft of COMSEC material;
deliberate falsification of COMSEC records or reports;
known or deliberate failing to report a known or suspected COMSEC incident;
unauthorized disclosure, or an attempt at disclosure, of information concerning COMSEC
material; and
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accidentally or knowingly processing, storing or transmitting classified or protected
information on an inappropriate COMSEC system or equipment.
16.3.3 Physical Incidents
Physical incidents are situations that adversely affect the physical security of COMSEC material.
Such incidents include:
loss of any COMSEC material or portions thereof;
unauthorized access to COMSEC material;
discovery of COMSEC material outside of required accountability and physical control.
For example –
o material reflected on a destruction report as having been destroyed and witnessed, but
found not completely destroyed and left unattended;
o material left unsecured and unattended where unauthorized individuals could have had
access;
o failure to maintain required TPI or NLZ controls for TOP SECRET key; and
o failure to destroy a key (including zeroizing a fill device) after use or supersession
within the prescribed period of time;
COMSEC material improperly packaged or shipped;
receipt of classified equipment, CCI or key material marked CRYPTO with a damaged
inner wrapper;
destruction of COMSEC material by other than authorized means;
actual or attempted unauthorized maintenance (including maintenance by unqualified
individuals) or the use of a maintenance procedure that deviates from established
directive;
known or suspected tampering with or penetration of COMSEC material including, but
not limited to, COMSEC material received in protective packaging which shows evidence
of tampering and unauthorized premature opening of a sealed package of key material;
unauthorized copying, reproducing or photographing of COMSEC material;
discovery of a clandestine intercept or recording device in or near a COMSEC facility;
and
any other occurrence which jeopardizes the physical security of COMSEC material.
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16.4 Handling of Incidents
16.4.1 Departmental Procedures
The DCA must establish internal COMSEC incident identification and response procedures that
will ensure prompt and accurate reporting of COMSEC incidents and minimize the potential for
or actual loss or compromise of COMSEC material.
The COMSEC Custodian must ensure that each individual who uses, or otherwise has access to
COMSEC material is capable of recognizing a COMSEC incident and understands the
requirements for immediately reporting COMSEC incidents.
16.4.2 COMSEC Custodian Responsibility
When COMSEC material is actually or potentially compromised, the COMSEC Custodian must
take the following steps:
a. Immediately report the circumstances to the DCA.
b. Mark all item(s) of the affected COMSEC material as “Pending Investigation” in the
COMSEC material inventory file.
c. Maintain accountability for the COMSEC material until the COMSEC investigation is
complete and a Final Assessment and Closure Report have been received from the NCIO
authorizing the disposition of the COMSEC material (e.g. transfer to CSEC for evaluation,
destruction, relief from accountability for lost item).
16.4.3 Departmental COMSEC Authority Responsibility
Upon notification of an actual or potential COMSEC incident, the DCA must:
a. conduct a preliminary investigation to verify the validity of the report and determine any
immediate corrective action that is required;
b. consider the impact of corrective actions or inaction on national or international security;
c. inform all individuals within and outside of the GC department who have a need to be
aware of the incident; and
d. follow-up with a more thorough investigation, if required.
Occurrences that are clearly administrative in nature and that pose no security implications
(e.g. COMSEC material accounting procedural matters) may be reported to NCOR/COR as a
routine matter. If any doubt exists about an occurrence, it must be treated as a COMSEC
incident.
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16.4.4 Reporting COMSEC Incidents
16.4.4.1 Initial Response to COMSEC Incident
Immediately following the preliminary investigation, if it is determined that a reportable
COMSEC incident has occurred, the DCA must, within 24 hours after discovery, forward a
COMSEC Incident Initial Report to the NCIO at CSEC. The NCIO will assess the situation to
determine the significance and potential impact of each case. Except in very minor cases, the
NCIO will require the GC department to conduct a more thorough investigation and to submit a
COMSEC Incident Evaluation Report.
16.4.4.2 COMSEC Incident Initial Report
The COMSEC Incident Initial Report may take the form of a verbal notification by secure
telephone or informal notification by secure facsimile. A formal written report may also be
requested by the NCIO to clarify details. The COMSEC Incident Initial Report must provide the
following information:
identification of the COMSEC Account in which the incident occurred;
category of the incident (i.e. Cryptographic, Physical or Personnel);
identification of all COMSEC material involved including short title(s), edition and
segment of key(s) loaded in COMSEC equipment, accounting numbers (e.g. KMID),
classification, responsible CA and key expiry or supersession date;
identity of all individual(s) involved including name, citizenship, position and security
clearance level;
description of circumstances surrounding the incident including the date of incident or
discovery and the date reported;
name of the DCA responsible for investigating and evaluating the incident;
immediate corrective action(s) taken, or planned; and
an estimation of the possibility of compromise (i.e. “Certain”, “Possible”, “Unlikely” or
“Impossible”) with the basis for the estimation.
16.4.4.3 COMSEC Incident Evaluation Report (Letter)
A COMSEC Incident Evaluation Report provides the NCIO with the required details and facts
surrounding a COMSEC incident.
For simple incidents, the NCIO will request a COMSEC Incident Evaluation Report in the form
of a letter, which must provide:
a detailed chronological account of the nature and circumstances of the COMSEC
incident;
an assessment of the probability of compromise; and
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a description of corrective action taken to limit damage resulting from the incident and to
prevent recurrence of the incident.
For more complex cases, the NCIO will provide additional direction and request a more detailed
COMSEC Incident Evaluation Report.
16.4.4.4 Sensitivity of COMSEC Incident Reports
COMSEC incident reports must be classified and protected at a level consistent with the most
sensitive information actually or potentially exposed, lost or compromised in the incident. The
following additional rules apply:
When deemed necessary, a GC department may classify a COMSEC incident report at a
higher level. A COMSEC incident report involving COMSEC material of different levels
of sensitivity must be classified at the most sensitive level applicable to the incident.
In a case where the incident involves COMSEC equipment, systems or material, the
incident must be handled and reported at a level at least commensurate with that of the
COMSEC equipment, system or COMSEC material.
In a case where the COMSEC material relates to IT systems processing information at a
classification level greater than that of the COMSEC material, the incident must be
handled and reported at the greater classification level (e.g. an incident involving
PROTECTED A authentication key material used on an IT system processing SECRET
information will be controlled and reported at the SECRET level).
16.4.4.5 Dissemination of COMSEC Incident Information
Dissemination of information relevant to any COMSEC incident must be limited to those with a
clear need-to-know.
16.5 Recovery of COMSEC Material
The DCA must ensure that individuals who are responsible for recovery action are able to
quickly implement the required recovery procedures and consequently minimize the impact of a
COMSEC incident.
16.6 Post-Incident Evaluation
Following the collection and assessment of all information received or available from existing
records, the NCIO will issue a COMSEC Incident Final Assessment and Closure Report for each
reported COMSEC incident. The report will include recommendations to prevent a similar
COMSEC incident or reduce the impact of a recurrence.
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16.7 COMSEC Incidents Involving North Atlantic Treaty Organization
COMSEC Material
GC departments holding NATO COMSEC material must report COMSEC incidents involving
NATO material to the NCIO at CSEC. The NCIO, in coordination with DND, will provide
direction with respect to the conduct of the investigation and ensure that NATO authorities are
kept informed.
16.8 COMSEC Incidents Involving In-Process COMSEC Material
Canadian Private Sector organizations holding IP COMSEC material must report COMSEC
incidents to CICA (see reporting COMSEC Incidents in the ICMCM). CICA will, in turn,
immediately notify the CICA DCA who will notify the NCIO.
16.9 Disciplinary Action
The primary purpose of reporting COMSEC incidents is to continuously maintain the maximum
possible level of protection for GC sensitive information and COMSEC material. This directive
provides for administrative control measures in support of GC policy and the PGS. Disciplinary
action, if deemed warranted by circumstance, is entirely in the purview of the DSO and host
departmental authorities. Failure to report a COMSEC incident, or cover it up, may be
considered “wilful or gross neglect” and must be evaluated accordingly.
In cases of non-compliance, CSEC may escalate administrative control of a department’s
COMSEC Account including suspension (refer to Article 4.6.1).
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Glossary
Access
Accountability
Accountable COMSEC
Material (ACM)
Accountable COMSEC
Material Control
Agreement (ACMCA)
Accounting Legend Code
(ALC)
Alternate COMSEC
Custodian
Audit Trail
The capability and opportunity to gain knowledge or
possession of, or to alter, information or material.
The responsibility of an individual for the safeguard and
control of COMSEC material which has been entrusted to
his or her custody.
COMSEC material that requires control and
accountability within the National COMSEC Material
Control System in accordance with its accounting legend
code and for which transfer or disclosure could be
detrimental to the national security of Canada.
A binding agreement between Communications Security
Establishment Canada and an entity (Government or
Canadian private sector) not listed in Schedules I, I.1, II,
IV and V of the Financial Administration Act that will
permit the procurement, ownership, control and
management of COMSEC material. It will also prescribe
the conditions for the financing, resale and final
disposition of the COMSEC material.
Numeric code used to indicate the minimum accounting
controls for COMSEC material which requires
accountability and control within the National COMSEC
Material Control System.
The individual designated by the Departmental COMSEC
Authority to assist the COMSEC Custodian and to
perform the duties of the COMSEC Custodian during the
temporary absence of the COMSEC Custodian.
A chronological record of system activities to enable the
construction and examination of the sequence of events or
changes in an event (or both).
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Authorized User (AU)
BLACK Key
Centrally-Accountable
COMSEC Material
Communications Security
(COMSEC)
Compromise
COMSEC Account
COMSEC Account Audit
COMSEC Courier
Certificate
An individual, who is required to use COMSEC material
in the performance of assigned duties, possesses the
required security clearance or reliability status, has been
COMSEC briefed, has the need-to-know and is
responsible for safeguarding COMSEC material.
Encrypted key (i.e. classified keying material in
encrypted format that has been encrypted with
cryptography approved by Communications Security
Establishment Canada).
COMSEC material that has been assigned an Accounting
Legend Code of 1, 2 or 6 and is continuously accountable
to a Central Office of Record.
The application of cryptographic security, transmission
and emission security, physical security measures,
operational practices and controls to deny unauthorized
access to information derived from telecommunications
and that ensure the authenticity of such
telecommunications.
Unauthorized disclosure, destruction, removal,
modification, interruption or use of assets.
An administrative entity identified by an Electronic Key
Management System Identifier (i.e. COMSEC Account
number), used to maintain accountability, custody and
control of COMSEC material that has been entrusted to
the entity.
Independent cooperative examination of a COMSEC
Account’s records and activities to ensure COMSEC
material produced by or entrusted to the COMSEC
Account is handled and controlled in accordance with
applicable directive.
A document authorizing an individual to transport
COMSEC material.
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COMSEC Custodian
COMSEC Equipment
COMSEC Facility
COMSEC Incident
COMSEC Material
COMSEC Material Report
COMSEC Sub-Account
The individual designated by the Departmental COMSEC
Authority to be responsible for the receipt, storage,
access, distribution, accounting, disposal and destruction
of all COMSEC material that has been charged to the
departmental COMSEC Account.
Communications Security Establishment Canadaapproved
cryptographic equipment and systems designed
to protect classified or PROTECTED C information and
data for the Government of Canada. It may also include
crypto-ancillary, crypto-production and authentication
equipment.
An authorized space in a building or other location that is
employed for the purpose of generating, storing, repairing
or using COMSEC material.
Any occurrence that jeopardizes or potentially
jeopardizes the security of classified or protected
Government of Canada information while it is being
stored, processed, transmitted or received during the
telecommunications process.
Material designed to secure or authenticate
telecommunications information. COMSEC material
includes, but is not limited to, key, equipment, modules,
devices, documents, hardware, firmware or software that
embodies or describes cryptographic logic and other
items that perform COMSEC functions.
A general-purpose form (i.e. GC-223) used by COMSEC
Custodians to report accounting transactions or to provide
notice of an action involving COMSEC material.
An administrative entity identified by an Electronic Key
Management System Identifier (i.e. COMSEC Account
number) established by a COMSEC Account to assist in
the control of the COMSEC material entrusted to the
COMSEC Account.
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Controlled Cryptographic
Item (CCI)
Controlled Cryptographic
Item (CCI) Marking
Controlling Authority (CA)
Conversion Report
CRYPTO
Crypto Material Assistance
Centre (CMAC)
Cryptographic
Cryptographic Logic
Unclassified secure telecommunications or information
handling equipment, or associated cryptographic
components, that are governed by a special set of control
requirements within the National COMSEC Material
Control System and marked “Controlled Cryptographic
Item”, or where space is limited, “CCI”.
A marking applied to COMSEC material that serves as a
warning that material so marked is subject to special
handling and control requirements.
Designated entity responsible for managing the
operational use and control of key assigned to that
cryptographic network.
Accounting report documenting the change of an
Accounting Legend Code and/or short title of physical
COMSEC material, or recording the modification
number(s) assigned to COMSEC equipment.
A marking which is applied to key material indicating
that items so marked are subject to specific controls
governing access, distribution, storage, accounting,
disposal and destruction (see Cryptographic below).
The entity within Communications Security
Establishment Canada responsible for all aspects of key
ordering including privilege management, the
management of the National Central Office of Record and
the administration of the Assistance Centre.
Pertaining to or concerned with cryptography (often
abbreviated as "CRYPTO" and used as a prefix).
The embodiment of one (or more) crypto-algorithm(s)
along with alarms, checks, and other processes essential
to effective and secure performance of the cryptographic
process(es).
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Cryptographic Material
Cryptographic Network
(cryptonet)
Cryptography
Crypto-Ignition Key (CIK)
Cryptoperiod
Departmental COMSEC
Authority (DCA)
Departmental Security
Officer (DSO)
Destruction Device
Destruction Report
All material, including documents, devices and
equipment, which contain crypto-information and is
essential to the encryption, decryption or authentication
of communications.
A telecommunications network (regardless of size or
number of users) in which information is protected by the
use of compatible cryptographic equipment using the
same cryptographic key.
The discipline that treats the principles, means and
methods for making plain information unintelligible and
reconverting the unintelligible information back into plain
information.
A device or electronic key that can be used to unlock the
secure mode of cryptographic equipment.
A specific period of time during which a cryptographic
key is in effect.
The individual designated by, and responsible to, the
Departmental Security Officer for developing,
implementing, maintaining, coordinating and monitoring
a departmental COMSEC program which is consistent
with the Policy on Government Security and its standards.
The individual responsible for developing, implementing,
maintaining, coordinating and monitoring a departmental
security program consistent with the Policy on
Government Security and its standards.
Any device or process used to change the medium which
contains classified or protected information in such a way
that the classified or protected information can no longer
be derived from the medium.
Accounting report documenting the physical destruction
or electronic zeroization of COMSEC material, whether
by authorized means or by accident.
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Electronic Key
Encryption
Facility Security Clearance
Fill
GC-223
Generation Report
Government of Canada
(GC) department
Hand Receipt
Hierarchy of Zones
Key that is stored on magnetic media, optical media, or in
electronic memory, transferred by electronic circuitry, or
loaded into COMSEC equipment.
The transformation of readable data into an unreadable
stream of characters using a reversible coding process.
An administrative determination that an organization is
eligible, from a security viewpoint, for access to
classified and protected information or assets of the same
or lower classification level as the clearance being
granted.
The process of providing key material to an end
equipment or end crypto unit for its internal use.
See COMSEC Material Report.
Accounting report documenting the generation or import
of electronic key.
Any federal department, organization, agency or
institution subject to the Policy on Government Security.
An accounting record that documents the issue of and
acceptance of responsibility for COMSEC material.
Process by which Government of Canada departments
must ensure that access to, and safeguards for, protected
and classified COMSEC material are based on a clearly
discernable hierarchy of zones. There are five zones:
Public Zone; Reception Zone; Operations Zone; Security
Zone and High Security Zone.
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High Security Zone
Information Technology
(IT)
Information Technology
(IT) Security
In-Process (IP) COMSEC
Material
Integrity
Inventory Report
Issue
Key
Key Encryption Key (KEK)
Area to which access is limited to authorized,
appropriately-screened personnel and authorized and
properly-escorted visitors. It must be indicated by a
perimeter built to the specifications recommended in the
Threat and Risk Assessment, monitored continuously (i.e.
24 hours a day and 7 days a week) and be an area to
which details of access are recorded and audited.
The acquisition, processing, storage and dissemination of
vocal, pictorial, textual and numerical information by a
combination of computing hardware, firmware, and
software, telecommunications and automated information
systems, automatic data processing equipment, and video.
Safeguards to preserve the confidentiality, integrity,
availability, intended use and value of electronically
stored, processed or transmitted information.
COMSEC material being developed, produced,
manufactured or repaired.
The accuracy and completeness of information and assets,
and the authenticity of transactions.
An accounting report listing COMSEC material charged
to a COMSEC Account.
The process of distributing COMSEC material from a
COMSEC Account to its COMSEC Sub-Account(s) or
Local Element(s).
Information used to set up and periodically change the
operations performed in crypto-equipment for the purpose
of encrypting and decrypting electronic signals and digital
signatures, determining electronic countermeasures
patterns, or producing other keys.
A key that encrypts or decrypts other key for transmission
or storage.
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Key Management
Key Material
Key Material Support Plan
(KMSP)
Local Accounting
Local Accounting Identifier
Local Element
Locally-Accountable
COMSEC Material
National Central Office of
Record (NCOR)
The procedures and mechanisms for generating,
disseminating, replacing, storing, archiving, and
destroying keys which control encryption or
authentication processes.
Key, code, or authentication information that is in
physical or electronic form.
A detailed description of the COMSEC requirements of a
cryptographic network.
The process used by the COMSEC Custodian to control
and account for COMSEC material and other specified
material that is not reportable to the National Central
Office of Record/Central Office of Record.
A unique number or alpha-numeric designator assigned
locally to material that requires local accounting within a
COMSEC Account.
NOTE: Local accounting identifiers must not be used on
the COMSEC Material Report as an accounting
number. They may be included in the remarks
column.
Individual registered at a COMSEC Account or
COMSEC Sub-Account who may receive COMSEC
material from that account.
COMSEC material that has been assigned an Accounting
Legend Code 4 or 7 and which is continuously
accountable within a COMSEC Account after initial
receipt has been sent to the distributing COMSEC
Account.
The entity at Communications Security Establishment
Canada responsible for maintaining records of
accountability for all accountable COMSEC material,
produced in, or entrusted to, Canada.
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National COMSEC
Incidents Office (NCIO)
National COMSEC
Material Control System
(NCMCS)
Need-to-Know
No Lone Zone (NLZ)
Operations Zone
Organization
Permuter
Personal Identification
Number (PIN)
The entity at Communications Security Establishment
Canada responsible for managing COMSEC incidents
through registration, investigation, assessment,
evaluation, and closure.
A logistic system through which COMSEC material,
including COMSEC material marked “CRYPTO” is
distributed, controlled and safeguarded.
The requirement for someone to access and know certain
information in order to perform his or her duties.
An area, room, or space to which no one person is
permitted to have unaccompanied access, and that when
occupied must have two or more appropriately cleared
individuals within, who must remain within sight of each
other.
Area where access is limited to personnel who work there
and to properly-escorted visitors. It must be indicated by
a recognizable perimeter and monitored periodically.
Any institution, other than a Government of Canada
department, agency or crown corporation, holding or
seeking a Facility Security Clearance. The majority are
commercial corporations, but other institutions are also
included such as universities, partnerships, and other
levels of government and their agencies.
Device used in crypto-equipment to change the order in
which the contents of a shift register are used in various
non-linear combing circuits.
A series of letters, special characters, and numbers used
to unlock the secure mode of COMSEC equipment.
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Personnel Security
Screening
Physical Key
Physical Security
Plik
Possession Report
Private Sector
Protected Information
Protection
The process of examining the trustworthiness and
suitability of employees and, where national interest is
concerned, their loyalty and associated reliability. When
satisfactory, an employee is grated reliability status or a
security clearance. Reliability status applies when only
protected assets are concerned. When the employee has
access to classified assets, a security clearance
corresponding to the level of classified assets is issued.
A security clearance includes reliability status.
Hard copy key in a non-electronic format.
The use of physical safeguards to prevent or delay
unauthorized access to assets, to detect attempted and
actual unauthorized access and to activate appropriate
responses.
A tamper evident, theft prevention, high security seal that
is affixed to packages before shipment.
Accounting report documenting the entry of COMSEC
material into the National COMSEC Material Control
System.
Canadian companies or organizations that do not fall
under the Financial Administration Act or are not
subordinate to a provincial or municipal government.
Information related to other than the national interest that
may qualify for an exemption or exclusion under the
Access to Information Act or Privacy Act.
For physical security, protection means the use of
physical, procedural and psychological barriers to delay
or deter unauthorized access, including visual and
acoustic barriers.
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Protective Packaging
Public Zone
Reception Zone
RED Key
Relief from Accountability
(RFA) Report
Restricted Access Area
Reticule
Risk
Risk Assessment
Screening
Packaging techniques for COMSEC material, which
discourage penetration, and/or reveal that a penetration
has occurred, or which inhibit viewing or copying of
COMSEC material, before the time it is exposed for use.
Area where the public has unimpeded access and
generally surrounds or forms part of a government
facility.
Area where the transition from a public zone to a
restricted access area is demarcated and controlled. It is
typically located at the entry to the facility where initial
contact between visitors and the department occurs.
Access by visitors may be limited to specific times of the
day or for specific reasons.
Unencrypted key.
Accounting report documenting the removal of COMSEC
material from a COMSEC Account inventory.
A work area where access is limited to authorized
individuals. It includes Operation Zones, Security Zones
and High Security Zones.
A disk, or the like, with a pattern of opaque and
transparent portions which can be rotated in the path of a
beam of light or other radiation so as to modulate it.
The chance of a vulnerability being exploited.
An evaluation based on the effectiveness of existing or
proposed security safeguards, of the chance of
vulnerabilities being exploited.
The process of verifying visitors and/or material at entry
points of a facility or a restricted area for authorizing
access.
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Security Classification
Security Screening
Security Zone
Short Title
Sight Inventory
Supersession
Threat
Threat Assessment
Tier 3 Management Device
(T3MD)
A category or grade assigned to information or material to
indicate the degree of danger to national security that
would result from its unauthorized disclosure and the
standard of protection required to guard against
unauthorized disclosure (e.g. TOP SECRET, SECRET
and CONFIDENTIAL).
The process which must be completed before an
individual can be granted a security clearance.
Area to which access is limited to authorized personnel
and to authorized and properly-escorted visitors. It must
be indicated by a recognizable perimeter and monitored
continuously (i.e. 24 hours a day and 7 days a week).
Identifying combination of letters and numbers assigned
to COMSEC material to facilitate handling, accounting,
and control.
The physical verification of the presence of each item of
COMSEC material charged to a COMSEC Account.
Scheduled or unscheduled replacement of a key or
COMSEC publication with a different edition.
Any event or act, deliberate or accidental, that could
cause injury to people, information, assets or services.
An evaluation of the nature, likelihood and consequences
of acts or events that could cause injury to people,
information, assets or services.
A Communications Security Establishment Canadaapproved
device (e.g. AN/CYZ-10/10A, KIK-20 and
AN/PYQ-10), that securely stores, transports and
transfers (electronically) both COMSEC and TRANSEC
key and that is programmable to support modern mission
systems. Designed to be backwards compatible with
previous generations of common fill devices.
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Tracer Notice – Transfer
Transfer
Transfer Report
Transmission Security
(TRANSEC)
Two Person Integrity (TPI)
Unauthorized Access
Vulnerability
Zones
A notice sent by a COMSEC Custodian or the National
Central Office of Record/Central Office of Record when a
copy of a Transfer Report or a Transfer Report Receipt is
not received within a pre-determined period of time.
The process of distributing COMSEC material from one
COMSEC Account to another COMSEC Account.
An accounting report that documents the distribution of
COMSEC material from one COMSEC Account to
another COMSEC Account.
The application of measures designed to protect
transmissions from interception and exploitation by
means other than cryptanalysis.
A control procedure whereby TOP SECRET key material
and other specified key material is never handled or made
available to one individual only.
Access to assets by an individual who is not properly
security screened and/or does not have a need-to-know.
An inadequacy related to security that could increase
susceptibility to compromise or injury.
A series of clearly discernable spaces to progressively
control access. See Hierarchy of Zones.
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Bibliography
Documents available from COMSEC Client Services at CSEC:
A Guide to Security Risk Management for Information Technology Systems (MG-2),
January 1996.
Canadian Cryptographic Doctrine for the Government of Canada Electronic Key
Management System (GC EKMS) (CCD-06), November 2006.
Canadian Cryptographic Doctrine for the Local Management Device/Key Processor
(LMD/KP [KOK-22/22A]) (CCD-07), August 2002.
Canadian Cryptographic Doctrine for the Disposal of Accountable COMSEC
Equipment (CCD-49), February 2008.
Industrial COMSEC Material Control (ICMCM) (ITSD-CSD-01), December 2001.
Local Management Device/Key Processor (LMD/KP) Operator’s Manual,
September 2000.
Manual of Cryptographic Equipment and COMSEC Devices (MG-16), July 1997.
NATO Crypto Distribution and Accounting Publication (AMSG 505), undated.
Policy and Procedures for the Handling and Control of Two-Person-Controlled (TPC)
NATO Security Material (AMSG 773), undated.
Short Title Nomenclature in Canada (ITSG-09), October 2001.
Control of Communications Security (COMSEC) Material (NSA/CSS Policy Manual
No. 3-16), U.S., August 5, 2005.
Bibliography October 2011 125

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Documents available on the Internet:
Communications Security Establishment Canada
Directive for the Application of Communications Security in the Government of
Canada (ITSD-01), January 2005.
Cryptographic Key Ordering Manual (ITSG-13), May 2006.
Clearing and Declassifying Electronic Data Storage Devices (ITSG-06), July 2006.
Justice Canada
Financial Administration Act (FAA), 1985 (current as of April 19, 2011).
Public Works and Government Services Canada
Industrial Security Manual, December 11, 2009.
Royal Canadian Mounted Police
Control of Access (G1-024), August 2004.
Protection, Detection and Response (G1-025), December 2004.
Guide to the Application of Physical Security Zones (G1-026), September 2005.
Security Equipment Guide (G1-001), March 2006.
Treasury Board of Canada Secretariat
Policy on Government Security, July 1, 2009.
Operational Security Standard on Physical Security, December 1, 2004.
Operational Security Standard: Management of Information Technology Security (MITS),
May 31, 2004.
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Annex A – Control of In-Process COMSEC Material
A.1 Introduction
A.1.1
Purpose
This annex provides the minimum security requirements for COMSEC material that requires
control and accounting within an “In-Process (IP)” logistics system.
A.1.2
Scope
IP COMSEC material includes:
key material, COMSEC publications or COMSEC equipment (including CCI and
sensitive IP COMSEC parts, components and assemblies) which is being developed,
manufactured, assembled, disassembled, produced or reproduced before being controlled
in the NCMCS (or a foreign national COMSEC system);
A.1.3
COMSEC equipment (controlled in the NCMCS) which is under a Repair and
Maintenance (R&M) contract and includes the removal or insertion of COMSEC parts,
components or assemblies; and
COMSEC publications (controlled in the NCMCS) and IP manuscripts which are under
contract for translation or reproduction.
Content of Annex
This annex contains the following sections:
Section A.1 – Introduction
Section A.2 – IP Plan
Section A.3 – Accounting for IP COMSEC Material
Section A.4 – Control of IP COMSEC Equipment
Section A.5 – COMSEC Equipment under R&M Contract
Section A.6 – COMSEC Publications under Development
Section A.7 – COMSEC Publications under Reproduction or Translation Contract
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A.2 In-Process Plan
A.2.1
Content of the In-Process Plan
The IP Plan must include:
purpose of the IP plan;
references and definitions used in or to develop the IP plan;
name, address and account number of the IP COMSEC Account;
individual responsibilities and duties;
access and storage requirements, including a floor plan if possible, and any NLZ and TPI
control requirements;
list of the item(s) to be controlled and the point in the production process at which an
item becomes IP COMSEC material, and becomes subject to IP accounting;
NOTE: Assistance in identifying this point and in identifying the level of security
classification or protected level is available by contacting the appropriate
approving authority.
accounting records (with examples) that reflect an accurate accounting status of each
individual IP item or portions thereof, at every stage of production at any given time;
internal and external process for the reconciliation of accounting records;
procedures for the control of material during all aspects of its production as well as any
form of drafts, extracts, waste, scrap, etc., applicable to that production;
shipment methods for transfer or issue (hand receipt) of IP material;
methods of disposal of breakage, waste and scrap, as well as accounting procedures to
reflect the disposal of the items;
procedures for the entry of COMSEC material from the NCMCS into the IP accounting
system and transition of completed items into the NCMCS;
identity of subcontractors, where applicable;
COMSEC incident reporting procedures;
an addendum to the plan for each contract where processing of IP COMSEC material is
required, identifying the COMSEC material to be produced under that contract, and
describing any procedures that are specific to that contract; and
any special instructions.
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A.2.2
Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
Approval of an In-Process Plan
An approved IP Plan must be in place before the release of or commencement of work on IP
COMSEC material by the GC, GC contractor or subcontractors. Table 5 outlines the approval
process of IP Plans for GC departments and the private sector, including subcontracts that will
involve COMSEC material that is subject to IP controls.
A.2.3
Approving Authority
CSEC is the approving authority for private sector IP Plans and GC IP Plans.
A.2.4
Changes to an In-Process Plan
If changes to the planned development or production process are required, the IP plan must be
amended in accordance with the instructions in this section. Changes to an IP plan must not be
implemented before approval from the appropriate approval authority.
Table 5 – Approval of IP Plans
Private Sector IP Plan Approval Process
Step
Action
The contractor must submit a draft IP Plan to CSEC ninety (90) calendar days
1
before the start date of the IP work.
CSEC will review the draft IP Plan and provide comments, if any, to the
2
contractor.
When the plan is acceptable to CSEC, the contractor must, if required by
3 contractual agreement, submit the IP Plan formally to the GC client department’s
contract coordinating office or Project Management Office, with a copy to CSEC.
4 CSEC will issue formal approval to the GC client department and the contractor.
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Government IP Plan Approval Process
Step
1
2
3
Action
The GC department must submit a draft IP Plan to CSEC ninety (90) calendar
days before the start of the IP work.
CSEC will review the draft IP Plan and provide comments, if any, to the GC
department.
When the plan is acceptable to CSEC, the GC department must, if required by
contractual agreement, submit the IP Plan formally to the GC client department’s
contract coordinating office or Project Management Office, with a copy to CSEC.
4 CSEC will issue formal approval to the GC department and the contractor.
Sub-Contractor IP Plan Approval Process
Step
Action
The primary contractor must ensure that the applicable requirements for IP Plan
1
(as set forth in this Annex) are specified in the contract with the subcontractor.
2 The primary contractor must ensure that the subcontractor develops an IP Plan.
The primary contractor will review the draft IP Plan and provide comments, if
3
any, to the subcontractor.
The primary contractor must submit a draft IP Plan to CSEC on behalf of the
4
subcontractor ninety (90) calendar days before the start date of the IP work.
CSEC will review the draft IP Plan and provide comments, if any, to the primary
5
contractor.
When the plan is acceptable to CSEC, the primary contractor must, if required by
contractual agreement, submit the IP Plan formally to the GC department’s
6
contract coordinating office or Project Management Office, with a copy to CSEC
and the subcontractor.
CSEC will issue formal approval to the GC department and the primary
7
contractor.
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A.3 Accounting for In-Process COMSEC Material
A.3.1
Automated In-Process Accounting System
The COMSEC Custodian must use a CSEC-approved IP accounting system to account for IP
COMSEC material.
A.3.2
In-Process Accounting Records
IP accounting records must contain the following information for each item:
the date that the item was introduced into the IP accounting system within the facility
(including IP items being returned by a subcontractor or the government, or being
returned for rework);
a brief, unclassified description of the items to be controlled which may include one or a
combination of the following –
o NATO Stock Number
o U.S. Federal Stock Number
o CSEC or vendor part number
o short title (if applicable)
o sensitivity (classification or protected level, or CCI), or
o ALC (if required);
quantity (when accounting by quantity is approved) or serial number (if individual item
accounting is required); and
disposition –
o incorporated into a higher assembly (identify the higher assembly), or otherwise made
a part of, another item of IP COMSEC material;
o transferred or issued within IP accounting procedures;
o entered into the NCMCS as an individual accountable item;
o destroyed or declassified;
o re-entered into the IP for rework; or
o any other disposition not covered above.
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A.3.3
Reconciliation of In-Process Accounting Records
The IP COMSEC Custodian and an appropriately cleared and COMSEC briefed witness must
conduct a reconciliation of IP accounting records semi-annually and at final delivery of the
COMSEC material. The reconciliation must determine that every item brought into the IP
accounting system or produced within the IP process is accounted for by physically sighting the
COMSEC material to ensure that it:
is still in the IP process or has been integrated or destroyed;
is in IP COMSEC material storage;
has been transferred out as a delivery of completed COMSEC material; or
has been transferred or issued to a contractor, subcontractor or the GC client department.
Any item that cannot be accounted for must be immediately reported as a COMSEC incident in
accordance with the directive in Chapter 16.
A.3.4
In-Process Accounting Reports
A.3.4.1
Transfer before Government of Canada Acceptance
Before GC acceptance, the IP COMSEC Custodian must transfer IP material from one IP
COMSEC Account to another IP COMSEC Account using an IP Transfer Report with an IP
transaction number. The IP Transfer Report must state that the COMSEC material is IP
COMSEC material and the reason for the transfer, such as “provided to support contract (insert
number)”. The IP accounting records must be annotated to reflect the transfer quoting the IP
transaction number of the IP Transfer Report.
NOTE: CSEC will provide IP COMSEC Account information for the transfer of IP COMSEC
material to the Private Sector.
A.3.4.2
Transfer following Government of Canada Acceptance
Following GC acceptance and purchase, the IP COMSEC Custodian must transfer IP COMSEC
material from the IP COMSEC Account to the GC COMSEC Account using an IP Transfer
Report. The IP Transfer Report must be annotated in the remarks column with “NEW COMSEC
MATERIAL”. When received, the COMSEC Custodian must sign the IP Transfer Report and
immediately enter the COMSEC material into the NCMCS via a Possession Report in
accordance with Chapter 6.
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A.3.4.3
Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
In-Process Transfer Report Receipt
The IP Transfer Report must be signed and assigned an IP transaction number by the IP
COMSEC Custodian. The IP accounting records must be annotated to reflect the receipt of this
material.
A.3.4.4
In-Process Hand Receipt
When IP COMSEC material is issued to an authorized user (i.e. Local Element) before GC
acceptance, the IP COMSEC Custodian must issue the material on an IP Hand Receipt. The IP
Hand Receipt must be assigned an IP transaction number and contain the information in Figure
2. The loan period should not exceed 90 calendar days without renewal. The IP accounting
records must be annotated to reflect the issue. The IP COMSEC material must be shipped
directly to the Local Element.
A.3.4.5
Temporary Release to Government of Canada
When the IP COMSEC material is temporarily released to the GC, a copy of the Hand Receipt
must be provided to the COMSEC Account at which the Local Element is registered (or to the
DSO if the GC department does not have a COMSEC Account). The IP material must not be
entered into NCMCS.
NOTE: The IP COMSEC Custodian must contact the COMSEC Custodian or the DSO to
ensure the authorized user has the appropriate security clearance, has been COMSEC
briefed and has the appropriate storage for the IP COMSEC material.
A.3.4.6
Temporary Release to Private Sector
When the IP COMSEC material is temporarily released to the Private Sector, a copy of the Hand
Receipt must be provided to CSEC. The IP material must not be entered into NCMCS.
NOTE: The IP COMSEC Custodian must contact CSEC to ensure the authorized user has the
appropriate security clearance, has been COMSEC briefed and has the appropriate
storage for the IP COMSEC material.
A.3.4.7
Hand Receipt Renewal
The IP COMSEC Custodian must review hand receipts on a regular basis to ensure IP COMSEC
material is returned before its due date. If the Hand Receipt needs to be renewed, the IP
COMSEC Custodian must prepare a new IP Hand Receipt with a new IP transaction number and
a reference to the previous IP Hand Receipt transaction number. The IP Hand Receipt for the
renewal must include the additional information provided in Figure 2. The Local Element must
sign the new Hand Receipt each time it is renewed.
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A.3.4.8
Return of In-Process COMSEC Material
When the IP COMSEC material is to be returned, the IP COMSEC Custodian must prepare an IP
Hand Receipt for the Local Element. The Local Element must include this Hand Receipt with the
shipment. Upon receipt of the material, the IP COMSEC Custodian will sign the IP Hand
Receipt and return a copy to the Local Element. The IP Hand Receipt must include the additional
information provided in Figure 3.
The above listed IP COMSEC material has not been accepted by the Government of Canada
and is the property of:
_____________________________________________.
(Name)
This IP COMSEC material is being issued (on a Hand Receipt) for 90 calendar days for:
_____________________________________________.
(Reason for Loan)
Should the length of the loan exceed 90 calendar days, the recipient must sign a new IP Hand
Receipt Report provided by:
_____________________________________________.
(Name)
THIS IP COMSEC MATERIAL MUST NOT BE ENTERED INTO THE NCMCS.
Figure 3 – IP Hand Receipt Required Information
The above listed IP COMSEC material has not been accepted by the Government of Canada
and is the property of:
_____________________________________________.
(Contractor Name)
This IP COMSEC material is being returned to the originator.
THIS IP COMSEC MATERIAL MUST NOT BE ENTERED INTO THE NCMCS.
Figure 4 – Return of Issued IP COMSEC Material
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A.3.4.9
In-Process Destruction Report
The IP COMSEC Custodian must prepare an IP Destruction Report to report the destruction of
COMSEC material and to record the removal of IP COMSEC material from the IP accounting
system. The IP Destruction Report must be signed by the IP COMSEC Custodian and the
witness who performed the destruction. The remarks column of the IP Destruction Report must
be annotated with the authority for destruction (e.g. breakage, waste, scrap). Destruction must be
carried out in accordance with the directive in Chapter 12.
A.3.5
Retention and Disposition of In-Process Records and Reports
IP records, files and reports must be retained for a minimum of two years.
A.3.6
Audit of In-Process COMSEC Accounts
IP COMSEC Accounts must be audited annually or more frequently if deemed necessary. An
unscheduled audit of an IP COMSEC Account may be conducted if audit reports (or other
sources) reveal a significant deviation from the IP Plan, resulting in a lack of control and/or
accountability of IP COMSEC material.
NOTE 1: CSEC will audit all GC departmental IP COMSEC Accounts.
NOTE 2: CICA will audit all private sector IP COMSEC Accounts.
A.4 Control of In-Process COMSEC Equipment
A.4.1
Integrated Circuits
A.4.1.1
Individual Items
Individual classified or protected IP wafers, masks, reticules, masters, test samples, pattern
generation tapes, etc., must be controlled on a continuous receipt system from one manufacturing
process to another, and from one IP COMSEC Account to another. The accounting and control
record must show the receipt or fabrication of each IP item, description and quantity of the
COMSEC material and the disposition of the item and bear the signatures of the responsible
individuals (e.g. production supervisor, loan holder) for each phase of fabrication.
A.4.1.2
Partial Items
Less than a full wafer must be controlled as individual dies, in accordance with Article A.4.1.1,
unless the wafer is reconstructed on an adhesive base. In that case, accountability resumes by
wafer count, and the record must show the number of dies removed. An attempt should be made
to determine the number of possible full dies in a wafer before dicing the wafer.
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If this cannot be accomplished, the number of full dies must be established immediately after
dicing the wafer. Less than a full die must be considered classified or protected scrap and
controlled accordingly.
A.4.1.3
Broken Items
Any area in which the breakage of an IP wafer, mask, reticule or die has occurred must be
immediately safeguarded. Every effort must be made to reconstruct the broken item onto an
adhesive base. If any chip or portion thereof cannot be accounted for, a COMSEC Incident
Report must be made in accordance with Chapter 16. If the missing portion or the entire wafer,
mask, reticule or die has fragmented to such a degree that reconstruction is impossible, the
COMSEC Custodian must:
a. remove all particles from the breakage area by vacuuming;
b. mark, once the area has been vacuumed, the vacuum bag containing the residue of the item
with the wafer, mask or reticule number and its sensitivity (or, where applicable, with the
identification of the chip or portion thereof belonging to the wafer, mask or reticule
number);
c. ensure the vacuum cleaner bag is initialled by two properly cleared individuals; and
d. control the vacuum bag as classified and protected COMSEC material until its contents can
be destroyed using a CSEC-approved destruction method or transported to the NDA at
CSEC for destruction.
A.4.2
Controlled Cryptographic Items
A.4.2.1
Development
The development, manufacture or assembly of IP CCI equipment may begin with either:
A.4.2.2
an IP design which goes through transition during development to become an IP CCI
component or assembly, which the contractor further processes into IP CCI equipment; or
CCI component or assembly that the contractor receives from an authorized source and
further processes into IP CCI equipment.
Protection of In-Process COMSEC Functions
Microcircuit chips used in hardware or firmware embodiments must be protectively coated by a
CSEC-approved process that will resist attempts to:
recover IP design information by reverse engineering;
defeat the security features; or
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otherwise recover information in memory (e.g. by external probing), unless, as verified
by the CSEC Project Manager, one of the following applies –
o the protective coating is incompatible with the microcircuit chip, such that the
reduced effectiveness inherent with the use of the coating is unacceptable, or
o other equally protective measures have been adopted in order to resist the abovementioned
threats.
NOTE 1: Unless it can be demonstrated that it is not technically feasible to do so, hardware
embodiments of IP COMSEC functions must be in custom microcircuit form
(i.e. embodiments that are composed of discrete components or standard
microcircuits are not permitted).
NOTE 2: Firmware embodiments of IP COMSEC functions must be in microcircuit form
(custom or standard). They must employ an irreversible security feature that prevents
both readout and modification, of the programmed information in the on-board
memory from external, physically accessible pins.
A.4.2.3
Transition from In-Process Design Status to In-Process Controlled
Cryptographic Items – Hardware Embodiments
For hardware embodiments, the transition from IP design status to IP CCI occurs at the
microcircuit photo-mask stage. Design automation by-products leading to, and including, the
reticule for each layer of the microcircuit must be handled at the same classification or protected
level as the engineering drawings from which they were derived. The photo-masks ultimately
used as tooling in the actual production process, as well as the resulting semiconductor wafers
and its subsequent forms (e.g. individual chips) leading to sealed devices, must be controlled as
IP CCI material, in accordance with Article A.4.2.5.
A.4.2.4
Transition from In-Process Design Status to In-Process Controlled
Cryptographic Items – Firmware Embodiments
For firmware embodiments, the transition from IP design status to IP CCI occurs after the
IP design information has been entered into the microcircuit memory, and the security feature
described in Article A.4.2.2 has been set. Thereafter, the microcircuits must be controlled as
IP CCI material, in accordance with Article A.4.2.6. Software source data for firmware
embodiments of IP design information remain IP and must be safeguarded in accordance with
this directive.
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A.4.2.5
Control of In-Process Microcircuit Devices
Following the transition from IP design status to IP CCI, the microcircuit devices must be
controlled throughout the remainder of the manufacturing and assembly process as follows:
Photo masks and wafers must –
o be clearly marked “CONTROLLED CRYPTOGRAPHIC ITEM” or “CCI”;
o bear a serial number and be accounted for by that serial number (until the photo
masks are securely destroyed and the wafers are diced); and
o be accounted for by quantity after a wafer is diced.
When a microcircuit is completely fabricated, purchased, accepted and transferred to the
government, accountability must be in accordance with NCMCS accounting procedures.
When a microcircuit is completely fabricated, and purchased and shipped to another
private sector organization for use in a manufacturing process, accountability must be in
accordance with the IP accounting procedures.
When the microcircuit is stored for future sale or stored for contractual obligations or
moves to the next level of assembly, the microcircuit must be maintained in the
contractor’s IP accounting system.
A.4.2.6
Control of Printed Wiring Assemblies
The PWAs assume IP CCI status as soon as a CCI microcircuit is installed upon it. Following
this transition, the PWA must be controlled throughout the remainder of the manufacturing and
assembly process as follows:
At the point of transition, accountability for the microcircuit ceases, and accountability for
the PWA begins.
NOTE: This disposition of the microcircuit, and the subsequent accountability for the
PWA, must be reflected in the IP accounting records.
Completely fabricated PWAs are accountable by quantity when they fit the definition of
“CCI Component” and by serial number when they fit the definition of “CCI Assembly”.
During further assembly, PWAs must be accounted for by quantity.
When a PWA is completely fabricated, and purchased and transferred to the government,
accountability must be in accordance with NCMCS accounting procedures.
When a PWA is completely fabricated, purchased and shipped to another private sector
organization for use in a manufacturing process, accountability must be in accordance
with the IP accounting procedures.
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When the PWA is stored for future sale or stored for contractual obligations or moves to
the next level of assembly, it must be maintained in the contractor’s IP accounting system.
A.4.2.7
Labelling Controlled Cryptographic Item Components, Assemblies and
Equipment
CCI components, assemblies and equipment must be labelled, “CONTROLLED
CRYPTOGRAPHIC ITEM” or “CCI” depending on the labelling space available, in accordance
with standard drawings available from CSEC and with the information provided in Table 6.
Table 6 – Labelling CCI
CCI
CCI
Components
CCI
Assemblies
CCI
Equipment
Labelling and Control Requirements
Each CCI component must be labelled “CCI” at the same time as other
part-specific nomenclature is applied.
Each CCI assembly must bear a government serial number for
accounting purposes, in accordance with criteria which will be furnished
by CSEC.
Labelling may be applied at any stage of the assembly process before the
end of the assembly process.
CCI controls applicable to a CCI assembly need not take effect until a
CCI component is installed.
Each item of CCI equipment must be labelled “CONTROLLED
CRYPTOGRAPHIC ITEM” in a conspicuous, external location.
Each item of CCI equipment must also bear a government serial number
for accounting purposes, in accordance with criteria furnished by CSEC.
Labelling may be applied at any stage of the assembly process before the
end of the assembly process.
CCI controls applicable to such equipment need not take effect until a
CCI component or CCI assembly is installed.
A.4.3
Breakage, Waste and Scrap In-Process COMSEC Material
IP COMSEC material leaving the development, production, manufacturing or assembly process
due to failure, breakage or normal waste (e.g. broken wafer, partial die, broken or faulty PWAs
or microcircuit devices) must be controlled until its approved destruction can be performed.
When authorized methods of destruction are not available, contact COMSEC Client Services, at
CSEC for disposal guidance.
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A.4.4
Loss of In-Process COMSEC Material
An extensive search must be made for any lost IP COMSEC material. Loss of such material must
be documented in the IP COMSEC Account records and immediately reported as a COMSEC
incident in accordance with the direction in Chapter 16.
A.5 COMSEC Equipment under Repair and Maintenance Contract
A.5.1
Transfer to/from the Contractor
The COMSEC Custodian for the GC department must transfer COMSEC equipment requiring
repair or maintenance to the contractors COMSEC Account. The COMSEC Custodian will issue
the COMSEC equipment to the IP COMSEC Account and annotate the Hand Receipt with an IP
transaction number. When the item is ready to be returned to the GC department, the process will
be reversed. Transfers of COMSEC equipment destined for the contractor’s COMSEC Sub-
Account must be through the CICA unless a direct transfer has been pre-approved by CSEC.
A.5.2
Accountability within the Repair and Maintenance In-Process Facility
Special attention must be given to ensure that the IP accounting procedures record the removal,
insertion, disposal, destruction (if authorized) and conversion (if required) of all COMSEC parts,
components and assemblies used in the R&M process as well as the continuous accountability of
the COMSEC equipment being serviced by the contractor or maintenance depot.
A.5.3
Sources of Spare COMSEC Parts, Components and Assemblies
A.5.3.1
In-House Sources
If the R&M contractor is the same as the contractor who built the COMSEC equipment, the
required COMSEC parts, components and assemblies require an in-house IP Transfer Report
from the manufacturing IP accounting system to the R&M IP accounting system.
A.5.3.2
Government Sources
The COMSEC Custodian must transfer the COMSEC parts, components and assemblies to the
CSEC CICA who will, in turn, transfer the material as GFE to a Canadian industrial COMSEC
Account in accordance with Article 7.4.1 of this directive.
Transfer of GFE to or from allied contractors is handled on a case-by-case basis. Contact
COMSEC Client Services at CSEC.
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A.5.3.3
Directive for the Control of COMSEC Material in the Government of Canada (ITSD-03)
Another Contractor
COMSEC parts, component and assemblies that originate from another contractor, whether by
purchase or by contractual agreement, should be transferred from the manufacturer’s IP
accounting system to the R&M contractor’s IP accounting system using an IP Transfer Report.
A.5.4
Non-Serviceable In-Process Parts, Components and Assemblies
A.5.4.1
Disposition
Any COMSEC part, component or assembly removed from GC COMSEC equipment and
replaced with IP COMSEC material (part, component or assembly) automatically becomes nonserviceable
IP COMSEC material for disposal. Disposal of these items can consist of local
destruction or transfer for destruction. The IP disposition records must show the disposition, and
if required, replacement of non-serviceable COMSEC parts, components and assemblies. IP
disposition must be detailed in the IP Plan.
A.5.4.2
Local Destruction
When local destruction is authorized by CSEC, the IP COMSEC Custodian must prepare an
IP Destruction Report for the local destruction of non-serviceable parts, components and
assemblies. The destruction must be carried out in accordance with the direction in Chapter 12.
A.5.4.3
Transfer to Private Sector Destruction Facility
If non-serviceable items are to be moved out of the R&M IP accounting system for disposal at a
private sector destruction facility, the destruction facility requires an IP Plan. The IP COMSEC
Custodian must transfer the items from the R&M contractor’s IP accounting system to the
destruction facility’s IP accounting system using an IP Transfer Report. Disposition records must
reflect this transfer. Upon destruction, the destruction facility must originate an IP Destruction
Report and their IP disposition records must reflect the destruction.
A.5.4.4
Transfer to Government of Canada for Destruction
If non-serviceable items are to be moved out of the R&M IP accounting system for disposal at a
GC destruction facility, the IP COMSEC Custodian must transfer the items from the R&M
contractor’s IP accounting system to CSEC using an IP Transfer Report. Disposition records
must reflect this transfer. CSEC will prepare a Possession Report to enter the items into the
NCMCS and initiate final transfer for disposal.
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A.5.5
Non-repairable COMSEC Equipment
Non-repairable COMSEC equipment under an R&M contract must be returned to the GC
department for disposal. The R&M contractor may only dispose of a GC department’s COMSEC
equipment by returning it to that GC department. The GC department is responsible for the
disposition of their COMSEC equipment in accordance with the Canadian Cryptographic
Doctrine for the Disposal of Accountable COMSEC Material (CCD-49).
A.6 Accountable COMSEC Publications under Development
A.6.1
In-Process Manuscripts
Manuscripts that will eventually become accountable COMSEC publications within the NCMCS
must be categorized as “IP Manuscripts”. An IP manuscript is an item that in any form
(e.g. computer printout, artwork, magnetic or optical media) provides information relative to
COMSEC management, design, operability or repair and maintenance and is used as input to the
development of an accountable COMSEC publication.
A.6.2
Working Papers
Material drafted in support of IP manuscripts must be handled as “working papers” (including
hand written or electronic notes) in accordance with the classification or protected level of the
source information. Working papers held by a writer for a period of thirty (30) calendar days
must, at that time, become accountable under the IP accounting system. Once entered into the IP
accounting system, records must be maintained of its existence, location, quantity, and
disposition. This process must continue until all portions of the manuscript are developed, and
are entered into the IP system. When fully developed, the manuscript must remain in the IP
accounting system until final disposition.
A.6.3 Release of In-Process Manuscripts before Government of Canada
Acceptance
A.6.3.1
Release of In-Process Manuscripts Portions
When it is necessary to release portions of an IP manuscript outside of the organization
responsible for its creation, the following rules apply:
The IP accounting records must reflect the number of pages comprising the initial
release;
The number of pages must also be annotated on the IP manuscript’s cover;
When the release is in a form other than physical copy, the label identifying the contents
must also be annotated with the number of pages contained therein; and
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Whenever manuscripts are released in parts, the pages of all parts must be numbered
consecutively (e.g. if 50 textual pages are released first, the second-portion of the release
must be numbered beginning with page 51).
A.6.3.2
Draft of In-Process Manuscripts
When it is necessary to release a completed draft of an IP manuscript outside of the organization
responsible for its creation, the following rules apply:
The IP accounting records must reflect the number of pages comprising the release.
A.6.3.3
The pages must be numbered consecutively and the number of pages must be annotated
on the IP manuscript’s cover.
When the release is in a form other than physical copy, the label identifying the contents
must also be annotated with the number of pages contained therein.
Marking In-Process Manuscripts for Release before Government of
Canada Acceptance
The cover page of an IP manuscript must be marked with a short title (CSEC is the authority for
all short titles), edition (if applicable), copy number and classification or protected level. Each
section, part, paragraph or similar portion of an IP manuscript must be marked to reflect the
highest level of its classification or protected level. The IP manuscript must bear the marking
“COMSEC MATERIAL” as illustrated in Figure 4.
NOTE 1: If release to U.K. or U.S. contractors has been authorized by CSEC, the above
marking must be modified to indicate “U.K./CANADIAN CITIZENS” or
“U.S./CANADIAN CITIZENS”, as appropriate.
NOTE 2: If release to a GC department has been authorized by the originator, the above
marking must be modified to indicate the name of the GC department instead of
contractor and MOU or LOA instead of contract number.
A.6.3.4
Printing In-Process Manuscripts before Government of Canada
Acceptance
If the IP Plan calls for the printing of copies of IP manuscripts within the IP developer’s facility,
the IP COMSEC Custodian must ensure that all copies are accounted for within the IP COMSEC
Account. If the IP Plan calls for the printing of copies of IP manuscripts outside the IP
developer’s facility under a reproduction contract, refer to Section A.7 of this annex.
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A.6.4
Government of Canada Acceptance of a Final Manuscript
An IP manuscript must remain under IP accounting system controls until such time as it reaches
a final state for acceptance by the GC. At that time, the manuscript will be brought into the
NCMCS, as specified in Section A.3.4 of this annex.
A.6.5
Destruction of In-Process Manuscripts
The IP COMSEC Custodian should destroy IP manuscripts and working papers as soon as a
requirement for the material no longer exists. Once the IP manuscript has been delivered and
accepted by the GC, the COMSEC Custodian must prepare an IP Destruction Report and destroy
all copies of the manuscript and associated working papers. The destruction must be carried out
in accordance with the directive in Chapter 12.
IP COMSEC MATERIAL
THE ENCLOSED COMSEC INFORMATION HAS BEEN RELEASED TO
_____________________________________________.
(Name of Contractor)
BY THE GOVERNMENT OF CANADA FOR CONTRACT
_____________________________________________.
(Contract Number)
ACCESS BY CONTRACTOR PERSONNEL MUST BE RESTRICTED TO CANADIAN
CITIZENS (INCLUDING DUAL NATIONALITY) WITH A “NEED-TO-KNOW” WHO
HOLD A VALID SECURITY CLEARANCE AND HAVE BEEN COMSEC BRIEFED. ANY
OTHER DISCLOSURE OR RELEASE WITHOUT SPECIFIC CSEC APPROVAL, AS
APPLICABLE, IS STRICTLY PROHIBITED.
Figure 5 – IP COMSEC Material Label
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A.7 Accountable COMSEC Publications under Reproduction or
Translation Contract
A.7.1
In-Process Manuscripts
IP manuscripts provided to a contractor for reproduction or translation must originate from either
the GC department or a private sector contractor who wrote the IP manuscript. The IP COMSEC
Custodian must transfer the manuscript from the originator’s IP COMSEC Account to the
contractor’s IP COMSEC Account using an IP Transfer Report. On completion of the translation
or reproduction contract, the original IP manuscript and all physical and electronic copies must
be transferred back to the originating IP COMSEC Account using an IP Transfer Report. All
items going to the private sector must be through CICA unless pre-approval for direct transfer
has been granted by the COMSEC Client Services at CSEC.
A.7.2
COMSEC Publications Controlled within the National COMSEC Material
Control System
When existing COMSEC publications controlled within the NCMCS are authorized for
reproduction under a reproduction contract, the COMSEC Custodian will issue a copy to the
contractor’s IP COMSEC Custodian in accordance with Section A.3.4 of this directive. The
COMSEC Custodian must review and renew the hand receipt every ninety (90) calendar days
until the COMSEC publication is returned.
On completion of the translation or reproduction contract, the IP COMSEC Custodian must
return the original copy and transfer the reproduced copies (electronic or physical) to the
originating IP COMSEC Account using an IP Transfer Report. On receipt, the COMSEC
Custodian must sign for the copies on the Transfer Report and prepare a Possession Report to
enter the copies into the NCMCS.
NOTE: Accountable COMSEC publications may only be reproduced upon specific written
authorization from the originator. Instructions for reproduction of extracts will be
contained in the publication’s handling instructions.
A.7.3
Destruction of In-Process Material Surplus to Contract Requirement
Once the copies have been delivered and accepted by the GC, the IP COMSEC Custodian must
prepare an IP Destruction Report and destroy all start up runs, additional electronic copies,
partial electronic copies, over runs, misprints, misfeeds, etc. The destruction must be carried out
in accordance with the direction in Chapter 12.
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