ISS COMMUNIQUE: IMPORTANT INFORMATION REGARDING SUBCONTRACTOR COMPLIANCE AND THE
REGISTRATION OF INDEPENDENT CONTRACTORS IN THE INDUSTRIAL SECURITY PROGRAM
The Industrial Security Sector (ISS) of Public Works and Government Services Canada (PWGSC) wants to reinforce
that as per the Treasury Board of Canada’s Policy on Government Security, all individuals operating as independent
contractors must register in the Industrial Security Program (ISP) in order to qualify for government contracts. For
the purposes of the ISP, an independent contractor encompasses any individual business entity, including:
independent contractors, independent and freelance consultants, and independent suppliers and business owners.
Registration is a requirement to obtain an organization security clearance and benefit from increased mobility and
flexibility to participate in contracts across government organizations.
ISS is aware that some registered organizations are currently not complying with the ISP requirements, and are
clearing independent contractors in the same manner as if they were employees of the Prime contractor /
registered organization. This practice contravenes the Policy on Government Security and is not permitted.
It undermines the ISP’s ability to enforce program compliance by ensuring all contractual security requirements
are carried out through the supply chain, from the Prime contractor to any of its subcontractors, including
independent contractors. It also limits the ability of independent contractors to move from company to company
to support government contracts without unnecessary delays.
By registering with the ISP as an independent organization, independent contractors benefit from greater mobility
and flexibility as they hold their own clearance and can easily enter into a subcontract without delays for security
In order to help organizations become compliant, specifically those who have cleared independent contractors as
employees, ISS will be implementing a measure to allow Prime contractor organizations who are registered in the
ISP, to sponsor independent contractors into the ISP in a timely and controlled manner, without negatively
affecting the delivery of services to the Government of Canada.
This measure will rely on the current Reliability Status (RS) and Personnel Security Clearances (PSC) duplication and
update process to trigger the Company Security Officer (CSO) of a Prime contractor organization to take key
actions as outlined in the Annexe: Subcontractor Compliance Roles and Responsibilities, attached.
Effective immediately, any organization registered with the ISP that requests a RS or PSC duplication or update for
an independent contractor taking part in a Government contract awarded with a Security Requirements Check List
(SRCL), will be required to initiate the separate registration of that independent contractor with the ISP, while
work on the government contract is being performed.
Note that this measure does not apply to unscreened / non-ISP registered resources. To obtain a RS or PSC,
unscreened / non-registered independent contractors need to be sponsored for registration in the ISP by the
Prime contracting organization, as per the regular sponsor process as outlined in the Industrial Security Manual.
By working together to register all suppliers in the ISP, from the Prime contracting organizations to subcontractors,
including independent contractors, ISS can continue to help industry participate in Government of Canada and
foreign government contracts, while maintaining the Government of Canada’s security posture.
ISS would like to thank you in advance for your cooperation.
For more information on the organization and personnel security screening process, please visit our website at ssi-
iss.tpsgc-pwgsc.gc.ca, or contact us at firstname.lastname@example.org / 1-866-368-4646, Monday to Friday, 8:00 a.m. to
5:00 p.m., ET.
Ensuring compliance with the ISP is a shared responsibility.