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National Geospatial-Intelligence Agency 

INSTRUCTION

NUMBER 1100.1 

29 July 2014 

Administrative Update 04 November 2015 

OIG

SUBJECT: Protecting Whistleblowers with Access to Classified Information 

References: See Enclosure 1. 

1. PURPOSE. This Instruction:

a. Establishes policy, assigns responsibilities, and provides guidance to ensure that

all NGA employees making a protected disclosure as defined in Reference (c) are 

protected against reprisal. 

b. Incorporates and cancels NGA Policy Notice 7410.10, “Protecting Whistleblowers

with Access to Classified Information,” 06 June 2013 (Reference (h)). 

2. APPLICABILITY. This Instruction applies to all NGA civilian employees, military

personnel, and contractors, hereafter referred to as employees, as defined in the 

Glossary (Reference (d)). 

3. POLICY. It is NGA policy that:

a. Employees with access to classified information can effectively make a protected

disclosure while protecting classified national security information, and that retaliation 

against employees for making said protected disclosure, to include personnel actions 

and actions affecting an employee’s eligibility for access to classified information, is 

prohibited (Reference (c)).

b. Employees can make protected disclosures to the Director of National Intelligence

(DNI), the Inspector General of the Intelligence Community (IC IG), the Inspector 

General of the Department of Defense (IG DoD), the Director of NGA (D/NGA), the 

Inspector General of NGA (IG), and/or a direct supervisor in the employee’s chain of

command (Reference (c)).

4. RESPONSIBILITIES. See Enclosure 2.
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5. PROCEDURES. See Enclosure 3.

6. EFFECTIVE DATE. This Instruction is effective on the date of signature.

Enclosures

1. References

2. Responsibilities

3. Procedures

Glossary
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ENCLOSURE 1

REFERENCES

(a) Title 5 United States Code, Section 2302 (b) (8)

(b) Title 10 United States Code, Section 1034

(c) Presidential Policy Directive 19, “Protecting Whistleblowers with Access to Classified 

Information,” 10 October 2012

(d) Intelligence Community Directive 120, “Intelligence Community Whistleblower 

Protection,” 20 March 2014

(e) DoD Directive 7050.06, “Military Whistleblower Protection,” 23 July 2007

(f) DoD Instruction 1400.25, Volume 2001, “DoD Civilian Personnel Management 

System: Defense Civilian Intelligence Personnel System (DCIPS) Introduction,” 

29 December 2008, Incorporating Change 1, Effective 17 March 2014

(g) “Directive-type Memorandum (DTM) 13-008, ‘DoD Implementation of Presidential 

Policy Directive 19,’” 08 July 2013, Incorporating Change 1, Effective 17 December 

2013

(h) NGA Policy Notice 7410.10, “Protecting Whistleblowers with Access to Classified 

Information,” 06 June 2013 (hereby rescinded)

(i) NGA Directive 5200.2, “Personnel Security,” 18 May 2014

(j) NGA Manual (NGAM) 1450.2, “Administrative Grievance System and Adverse 

Action Appeals Process,” 26 August 2013

(k) NGAM 1455.1, “Disciplinary and Adverse Actions,” 26 August 201319 February 

2015
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ENCLOSURE 2

RESPONSIBILITIES

1. D/NGA.

a. Carefully considers IG and External Review Panel findings and recommendations 

with respect to complaints of reprisal by NGA employees (Reference (c)).

b. Directs staff to take appropriate action to include but not limited to, reinstatement, 

reassignment, the award of reasonable attorney’s fees, other reasonable costs, back 

pay and related benefits, travel expenses, and compensatory damages (Reference (c)).

c. Ensures all employees are aware of the availability of an external review of their 

complaint.

2. Inspector General (IG).

a. Receives and processes protected disclosures using procedures documented in 

Enclosure 3.

b. Maintains a review process that permits employees to appeal a personnel action

affecting eligibility for access to classified information that is perceived to be the result of 

making a protected disclosure (Reference (c)).

c. Makes employees aware of the protections and review processes available to 

them through workforce communications (Reference (d)).

3. Director, Human Development (D/HD).

a. Ensures that procedures are incorporated into relevant personnel guidance for 

individuals who seek review of personnel actions alleged to be in violation of 

Reference (c).

b. Makes employees aware of the protections and review processes available to 

them by including this information in HD training courses (Reference (d)).

4. Director, Security and Installations.

a. Ensures that no action is taken that affects an employee’s eligibility for access to 

classified information as a reprisal for making a protected disclosure (Reference (c)).

b. Ensures Reference (i) and NGAM 5200.2 “Personnel Security” include preventive 

measures to preclude reprisals.
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5. Component Directors.

a. Ensure employees are aware of their responsibility to make protected disclosures

to any of the following officials:

 (1) A direct supervisor in the employee’s chain of command

(2) NGA IG

 (3) D/NGA 

 (4) IC IG

(5) IG DoD 

 (6) DNI

b. Ensure employees are aware of the protections and review process to address 

reprisals if they believe such action was taken against them (Reference (c)).

6. Employees can report, through protected disclosure to the individuals listed in section 

5.a., information that they reasonably believe evidences any violation of law, rule, or 

regulation; gross mismanagement; gross waste of funds; abuse of authority; or a 

substantial and specific danger to public health or safety (Reference (c)).
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ENCLOSURE 3 

PROCEDURES 

1. Reprisal-Related Complaints. 

a. Submit complaints or other reports of possible violations to the IG or directly to the 

other individuals noted in Enclosure 2. 

b. Contact the NGA Office of the Inspector General (OIG) by: 

(1) Calling the OIG Hotline at 

(2) Sending unclassified email to or TS/SCI email at 

(3) Submitting the complaint form at 

c. Employees may file anonymously or by name. 

d. Employees may request withdrawal of their OIG complaint after it is submitted via 

the submission methods. However, OIG has the authority to continue the investigation. 

e. The IG reviews all submitted complaints and determines an appropriate course of 

action in accordance with internal IG procedures. The IG will refer those complaints that 

do not fall under OIG purview to the relevant external agency. 

2. Reprisal Complaints. 

a. IC employees are protected under the terms of Reference (c) from reprisal for 

making a protected disclosure. 

b. OIG will review and determine whether to accept the allegation of reprisal for 

investigation or, if appropriate, refer the matter to another organization for investigation. 

 

3. External Review Panel. 

a. An employee alleging a reprisal who has exhausted the applicable review process 

mentioned in this Instruction may request an external review by an External Review 

Panel. 

b. External review panels will be chaired by the IC IG (on behalf of the DNI, acting in 

his or her capacity as the head of the entity selected by the President under subsection 

435(b) of Title 50 United States Code and as the designated Security Executive Agent). 

The IC IG shall designate two other panel members from the Inspectors General of the 

(b)(3) 10 USC 424 (b)(3) 10 USC 424 (b)(3) 10 USC 424 (b)(3) 10 USC 424 (b)(3) 10 USC 424
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following agencies: Department of State, Department of the Treasury, Department of 

Defense, Department of Justice, Department of Energy, and Department of Homeland 

Security, or the Central Intelligence Agency (Reference (c)).
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GLOSSARY

DEFINITIONS

Eligibility for 

Access to 

Classified 

Information

The result of the determination whether an employee a) is eligible 

for access to classified information in accordance with Executive 

Order 12968 (relating to access to classified information), or any 

successor thereto, or Executive Order 10865 of 20 February 1960, 

as amended (relating to safeguarding classified information with 

industry), or any successor thereto; and b) possesses a need to 

know under such orders (Reference (c)).

Employee For the purposes of implementation of this instruction, as defined in 

Intelligence Community Directive 120, “Intelligence Community 

Whistleblower Protection” section F, “Protections Under PPD-19, 

Section B, Prohibition on Retaliation by Affecting Eligibility for 

Access to Classified Information,” an employee is defined as a 

person detailed to or assigned to NGA, including members of the 

Armed Forces; an expert or consultant to NGA; an industrial or 

commercial contractor, licensee, certificate holder, or grantee of 

NGA, including all subcontractors; a personal services contractor; or 

any other category of person who acts for or on behalf of NGA as 

determined by D/NGA (Reference (d)).

Personnel 

Action

Appointment, promotion, detail, transfer, reassignment, demotion, 

suspension, termination, reinstatement, restoration, reemployment, 

or performance evaluation; a decision concerning pay, benefits, or 

awards; a decision concerning education or training if the education 

or training may reasonably be expected to lead to an appointment, 

reassignment, promotion, or performance evaluation rating; a 

decision to order psychiatric testing or examination; any other 

significant change in duties, responsibilities, or working conditions 

(Reference (c)).
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Protected 

Disclosure

Defined as a) a disclosure of information by the employee to a 

supervisor in the employee’s direct chain of command up to and 

including D/NGA, to NGA IG, to DNI, to IC IG, or to an employee

designated by any of the above officials for the purpose of receiving 

such disclosures, that the employee reasonably believes evidences 

(i) a violation of any law, rule, or regulation; or (ii) gross 

mismanagement, a gross waste of funds, an abuse of authority, or a 

substantial and specific danger to public health or safety; b) any 

communication described by and that complies with subsection 

(a)(1), (d), or (h) of section 8H of the Inspector General Act of 1978 

(5 United States Code App.); subsection (d)(5)(A), (D), or (G), of 

section 103H of the National Security Act of 1947 (50 United States 

Code 403-3h); c) the exercise of any appeal, complaint, or 

grievance with regard to the violation of Section A or B of 

Presidential Policy Directive 19; d) lawfully participating in an 

investigation of proceeding regarding a violation of Section A or B of

Presidential Policy Directive 19; or e) cooperating with or disclosing 

information to an IG, in accordance with an audit, inspection, or 

investigation conducted by the IG, if the actions described under 

subparagraphs c) through e) of this definition do not result in the 

employee disclosing classified information of other information 

contrary to law (Reference (c)).