Non-Duplication Justification

non-duplication justification.docx

Supplemental Investigative Data

Non-Duplication Justification

OMB: 1620-0001

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DHS Question: Explain how ICR 1620-0001 (Secret Service Form (SSF) 86A, Supplemental Investigative Data) is not duplicative of information collected on Standard Form (SF) 86, and what the U.S. Secret Service (USSS) has done to assure that this ICR is not duplicative of SF 86.

USSS Answer: Due to security requirements unique to the USSS, applicants must undergo an extensive background investigation prior to beginning their career with the USSS.


The USSS requires applicants to complete SF 86, as well as SSF 86A, because questions on SF 86 do not compel the respondent to disclose the sufficient amount of information that is required for the USSS to grant the applicant a Top Secret security clearance, or Sensitive Compartmented Information (SCI) access.


While some questions on SSF 86A are similar to questions on SF 86, each section of SSF 86A requires the applicant to give either extra or more extensive information than questions on SF 86. Moreover, any similar question appearing on SSF 86A is needed to identify individuals (e.g., name, Social Security Number, address), or as a precursor for the sake of logic and clarity. For example, the USSS cannot ask about a spouse’s address or employer (information not required on SF 86) without first asking for the spouse’s name. Similarly, the USSS cannot ask about the details of an individual’s foreign contacts without first asking the name of the contact.


To assure that SSF 86A is not duplicative of information collected on SF 86, the USSS contacted the Office of Personnel Management (OPM), the responsible office for SF 86. OPM explained that SF 86 had been revised to include new “branching questions,” and advised the USSS to review these new questions to ensure that they do not negate the need for some of the questions on SSF 86A . OPM provided the USSS with a copy of the revised form, and the USSS analyzed every question on SSF 86A, and compared each one to the revised version of SF 86, including all the branching questions.


The USSS found that OPM’s inclusion of the branching questions on SF 86 did not sufficiently override the need for the supplemental investigative questions on SSF 86A.


The following are the specific questions that are omitted from SF 86:


Section 1: Applicant-General Personal and Physical Data


SF 86 omits questions regarding age, physical description, and vision.


Section 2: Selective Service/Military Service Reserve Status


SF 86 omits questions regarding location of service registration, location where military service was entered, serial number, current location of military records, and current location of military medical records.


Section 3: Marital Status and Spouse/Cohabitant/Fiancé Information


SF 86 omits to questions to include “engaged” under a choice for marital status, and, if applicable, does not request any information regarding an applicant’s fiancé. SF 86 does not request the following information regarding an applicant’s spouse/cohabitant/ex-spouse:


  • Particulars regarding a legally changed name

  • Former citizenship(s)

  • Date and place citizenship acquired

  • Date and place of arrival in U.S.

  • Date and cause of death

  • Address of spouse prior to marriage if other than U.S.

  • Occupation, employer, annual earnings, or employer’s address


Section 4: Parents, Children, and other Dependents


SF 86 omits questions concerning an applicant’s number of children who are unmarried, under 21 years of age, and not self-supporting; and an applicant’s number of other dependents depending on them for at least 50% of their support, or children over 21 who are not self-supporting.


Section 5: Citizenship of Your Relatives and Associates


SF 86 omits questions regarding the citizenship of frequently contacted aunts, uncles, and cousins. Regarding proof of citizenship status for relatives and associates, SF 86 omits questioning the date the naturalization certificate was issued, and the date and location of the individual’s alien registration. SF 86 also omits asking the sex of the relative or associate, and the date and place of this person’s entry into the U.S.


Section 6: Neighbor References


SF 86 asks for only one reference from a neighbor; SSF 86 A asks for two references.


Section 7: Financial Information


All information gathered in section 7 is omitted on SF 86.


Section 8: Personal Declarations


SF 86 omits questions regarding receivership proceedings, employment or activity with political organizations, connections with private or commercial investigative services for private entities, formal complaints against the applicant, and incidents in an applicant’s own or family background that might compromise job performance. Also, while Section 23 of SF 86 asks about the respondent’s illegal use of drugs or drug activity in the last seven years, SSF 86A does not limit questions regarding drug use to any length of time.


Section 9: Income Tax Status


All information gathered in section 9 is omitted on SF 86.

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