Pia Nppd_ci Pscp

Privacy Impact Assessment
for the

Critical Infrastructure Private Sector
Clearance Program
DHS/NPPD/PIA-020
November 2, 2011
Contact Point
Richard LePage
Director of Management
Office of Infrastructure Protection
National Protection and Programs Directorate
(703) 235-8133
Reviewing Official
Mary Ellen Callahan
Chief Privacy Officer
Department of Homeland Security
(703) 235-0780

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Abstract
The U.S. Department of Homeland Security (DHS), National Protection and Programs
Directorate (NPPD), Office of Infrastructure Protection sponsors security clearances for certain private
sector officials through the Critical Infrastructure Private Sector Clearance Program. These officials are
identified through the National Infrastructure Protection Plan (NIPP) partnership framework and are
Critical Infrastructure owners/operators, sector leadership (i.e., Sector Coordinating Council members), or
subject matter experts identified by DHS to assist in analyzing Critical Infrastructure-related national
security information to further enhance the Department’s infrastructure protection mission. NPPD
conducted this PIA because sponsoring individuals for security clearances involves the collection of PII,
such as the applicant’s Social Security Number, date and place of birth, and employment contact
information.

Overview
Background
Protecting Critical Infrastructure and key resources requires cooperation between government and
private industry. It is the policy of the DHS to share pertinent information regarding Critical
Infrastructure with the private sector, which at times may include classified information. A private sector
official must be cleared for a federal security clearance prior to receiving classified information from the
government. The Critical Infrastructure Private Sector Clearance Program (hereinafter referred to as the
“Program”) was developed to provide a means to facilitate the processing of security clearance
applications for private sector partners.
There are three phases to clearance processing: 1) applicant processing; 2) investigation; and 3)
adjudication. The Program initiates the applicant processing. However, the U.S. Office of Personnel
Management (OPM) and the DHS Office of Security, Personnel Security Division (hereafter referred to
as “Personnel Security Division”) conduct the background investigation required to obtain a security
clearance and the adjudication of the clearance. During Phases Two and Three, OPM or the Personnel
Security Division may require additional PII to be collected. This additional information is not shared
with the Program, nor stored in the Program system. The Program only collects and retains that
information necessary to monitor the status of the individual’s clearance processing. Upon adjudication,
notification is sent to the Program, who retains the approval. In the event of a denial, only the applicant’s
name, sector, and date of denial are retained.
Applicant Processing
The Program has identified certain DHS employees, hereafter referred to as Nominators, whose
function is to identify specific private sector partners (individuals/applicants) who meet the criteria1 for
sponsorship of a security clearance. Nominators address those individuals in order to seek their
1

To qualify for Program sponsorship, an individual must meet one of the following criteria: 1) be a member of
sector leadership; 2) be a Critical Infrastructure operator/owner or senior corporate official with the authority to
effectuate change with respect to Critical Infrastructure; and/or 3) be a subject matter expert.

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participation in the Program. If an individual meeting the criteria for sponsorship is interested in
becoming part of the Program, the Nominator initiates the applicant processing by providing the
individual with the DHS Form 9014, Critical Infrastructure Private Sector Clearance Program Request.
To minimize the collection of PII, the process is twofold, and sensitive PII is only collected from
those individuals who are approved for DHS sponsorship based on information submitted as part of the
first step of the clearance application process.
Step one: The applicant must provide the following via DHS Form 9014:
•

full name;

•

company name;

•

business title;

•

business physical address;

•

business email address;

•

business phone number;

•

business relationship with the sector;

•

U.S. Citizen (yes/no); and

•

a justification for the need for access to classified information.

Once the applicant completes and returns the application to the Nominator for their signature,
the Nominator forwards the form to the Program’s Security Administrator, who reviews it for
completeness and initial candidate approval. If the basic application is approved, the Program’s Security
Administrator contacts the applicant directly to complete the second step, which requires that the
individual provide the remaining sensitive PII needed to begin the security clearance process.
Step two: The applicant must provide the following:
•

date of birth (DOB);

•

place of birth (POB); and

•

Social Security Number (SSN).

This two-part process helps minimize the collection of sensitive PII for only those individuals
who meet the threshold and are sponsored by DHS.
Upon completion of the initial two-step collection, the Program Security Administrator is
responsible for entering the applicant’s information into OPM’s secure portal for investigation processing,
the electronic questionnaire for investigation process (e-QIP 2). This will initiate the applicant in OPM’s
system, allowing the applicant to complete OPM’s required online security questionnaire. Specifically,
the Program Security Administrator enters the following data into e-QIP:
2

For more information on e-QIP, see OPM/CENTRAL-9 - Personnel Investigation Records, 75 FR 28307 (May 20,
2010).

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• name;
• DOB;
• POB;
• Social Security Number; and
• business email address.
Once the Program Security Administrator has initiated the applicant in e-QIP, the applicant
accesses e-QIP directly to complete and submit OPM’s online security questionnaire, Standard Form 86,
Questionnaire for National Security Positions. The Program does not collect or have access to the
information provided by the applicant to OPM through e-QIP. However, the applicant must provide the
Program with copies of e-QIP signature pages that are printed at the end of the security questionnaire,
certifying that statements made on the security questionnaire are true, complete, and correct to the best of
the applicant’s knowledge and that knowingly providing a false statement is punishable by fine or
imprisonment or both under 18 U.S.C. §1001.
The applicant’s printed e-QIP signature pages are part of a package of DHS forms and standard
security forms 3 that must be submitted before the investigation process begins. The forms package also
includes a set of fingerprint cards and a DHS Form 11000-9, Disclosure and Authorization Pertaining to
Consumer Reports Pursuant to the Fair Credit Reporting Act. The Program instructs applicants to submit
two copies of this package, one in hard copy and one in electronic form. The Program retains the hard
copy in the individual’s file in a locked filing cabinet, and the electronic copy is password-protected and
stored on the Program’s access-restricted shared drive. The Program Security Administrator sends the
complete, electronic package of forms, fingerprints, including the DHS Form 9014, Critical
Infrastructure Private Sector Clearance Program Request, to the Personnel Security Division, via a
password-protected email attachment, for processing.
Investigation
The Personnel Security Division reviews the applicant’s forms package and performs initial
background checks (such as the FBI fingerprint check). Based on the initial review, the Personnel
Security Division will either grant or deny an interim security clearance, if appropriate, while OPM
conducts a full background investigation.
OPM performs background investigations for all individuals being sponsored by DHS for a
security clearance. For more information on OPM’s background investigations, see OPM’s privacy
impact assessment 4 for e-QIP or OPM/CENTRAL-9 - Personnel Investigation Records, 75 FR 28307
(May 20, 2010). Upon completion of the background investigation, OPM sends the investigation file
back to DHS for adjudication by the Personnel Security Division. That investigation file is not shared
with the Program.

3

The National Archives and Records Administration, Information Security Oversight Office prescribes standard
forms that are used in administering the security classification programs in government.
4
http://www.opm.gov/privacy/PIAs/eQIP.pdf

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Adjudication
The Personnel Security Division evaluates information obtained through the background
investigation process and notifies the Program and the applicant of the decision to grant or deny the
security clearance via email. In the event that a clearance is denied, the Personnel Security Division also
directly advises the applicant in writing of their redress options, to include the ability to access and correct
records pursuant to the provisions of the Privacy Act. The Program is only notified of the final decision
and does not have access to information used by the Personnel Security Division in its evaluation. In the
event of a denial, only the applicant’s name, sector, and date of denial are retained.
Individuals who are granted security clearances are required to complete a Standard Form 312,
Classified Information Nondisclosure Agreement, which serves as contractual agreement between the
individual and the United States government, acknowledging the individual’s responsibilities inherent
with being granted access to classified information. By signing the Standard Form 312, the individual
accepts the obligations of being granted access to classified information including, but not limited to, no
unauthorized disclosure of such information.
Administrative Security/Classified Visit Management
The Program is further responsible for maintenance of the security clearance, including
administering annual training and initiating periodic reinvestigations, as required by Executive Order
12968, as amended, 5 and facilitating classified visit management. The Program maintains a roster to keep
track of the individuals’ clearance status and shares information, as appropriate, to allow individuals
access to classified information for which they have a need to know. To perform these functions, the
Program Security Administrator has access to the Department’s clearance database managed by the
Personnel Security Division, Integrated Security Management System (ISMS), for purposes of verifying
clearance status. The use of ISMS for administrative security and classified visit management is covered
under the privacy impact assessment, DHS/ALL/PIA-038 Integrated Security Management System
(ISMS), published March 22, 2011.
The Program retains the following information, which is collected through the application process
and through ISMS:
•

•
5

In the applicant’s file:
-

the DHS Form 9014, Critical Infrastructure Private Sector Clearance Program
Request;

-

the set of fingerprint cards;

-

the DHS Form 11000-9, Disclosure and Authorization Pertaining to Consumer
Reports Pursuant to the Fair Credit Reporting Act; and

-

a copy of the applicant’s printed e-QIP signature pages.

In the Program roster:

Executive Order 12968, as amended, establishes a uniform federal personnel security program for employees who
will be considered for initial or continued access to classified information.

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-

full name;

-

Social Security Number;

-

DOB;

-

POB;

-

sector affiliation;

-

date the applicant’s package was submitted to the Personnel Security Division;

-

date the package was sent to OPM;

-

clearance granting date;

-

the date the applicant signed their Standard Form 312, Classified Information
Nondisclosure Agreement;

-

their role in their company/sector;

-

clearance/nondisclosure agreement/status remarks;

-

investigation date;

-

clearance level;

-

business email address;

-

company name;

-

business address; and

-

business phone number.

Participation in the Program is entirely voluntary. However, failure to provide the required PII
may prevent the individual from participating in the Program or receiving a security clearance.
Consequently, the individual may not have access to information required to effectively coordinate with
the government on Critical Infrastructure matters that are related to national security.

Section 1.0 Authorities and Other Requirements
1.1

What specific legal authorities and/or agreements permit and
define the collection of information by the project in question?

Section 201 of the Homeland Security Act and Executive Orders 9397,6 12968, 13526, 7 and
13549 8 authorize the collection of this information. Individuals cannot be granted access to classified
6

Executive Order 9397 gives agencies the authority to collect Social Security Numbers whenever the agency finds it
advisable to set up a new identification system for individuals.
7
Executive Order 13526 prescribes a uniform system for classifying, safeguarding, and declassifying national
security information, including information relating to defense against transnational terrorism.
8
Executive Order 13549 establishes a Classified National Security Information Program designed to safeguard and
govern access to classified national security information shared by the federal government with state, local, tribal,

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information unless they have been determined eligible for access based on favorable adjudication of an
appropriate background investigation. Additionally, the Personnel Security Division has the authority to
conduct investigations, as referenced in the privacy impact assessment, DHS/ALL/PIA-038 Integrated
Security Management System (ISMS). While the Program does not conduct investigations, the Program
collects information to facilitate this process.

1.2

What Privacy Act System of Records Notice(s) (SORN(s)) apply
to the information?

Information collected by the Program (i.e., citizenship, Social Security Number, DOB, POB, and
standard form questionnaires, etc.) as well as information collected by the Personnel Security Division as
part of the investigation and adjudication of the security clearance, is covered under DHS/ALL-023 Department of Homeland Security Personnel Security Management, 74 FR 3084 (January 16, 2009). The
interests of national security require that all persons privileged to access national security information
shall be reliable, trustworthy, of good conduct and character, and of complete and unswerving loyalty to
the United States. This means that individuals sponsored by DHS for access to classified information are
subject to investigation.

1.3

Has a system security plan been completed for the information
system(s) supporting the project?

As this is not an IT system, a system security plan is not applicable to this program.

1.4

Does a records retention schedule approved by the National
Archives and Records Administration (NARA) exist?

The records in this system are covered by the NARA General Records Schedule (GRS) 18 Items
21; 22; 23.

1.5

If the information is covered by the Paperwork Reduction Act
(PRA), provide the OMB Control number and the agency number
for the collection. If there are multiple forms, include a list in an
appendix.

The DHS Form 9014, Critical Infrastructure Private Sector Clearance Program Request, is
covered by OMB number 1670-0013.

and private sector entities.

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Section 2.0 Characterization of the Information
The following questions are intended to define the scope of the information requested and/or collected, as
well as reasons for its collection.

2.1

Identify the information the project collects, uses, disseminates, or
maintains.

To minimize the collection of PII, the process is twofold, and sensitive PII is only collected from
those individuals who are approved for DHS sponsorship based on information submitted as part of the
first step of the clearance application process.
Step one: The applicant must provide the following:
•

full name;

•

company name;

•

business title;

•

business physical address;

•

business email address;

•

business phone number;

•

business relationship with the sector;

•

U.S. Citizen (yes/no); and

•

a justification for the need for access to classified information.

If the individual is deemed suitable for sponsorship, the Program’s Security Administrator
contacts the applicant directly to complete the second step, which requires that the individual provide the
remaining, sensitive PII needed to begin the security clearance process.
Step two: The applicant must provide the following:
•

DOB;

•

POB; and

•

Social Security Number (SSN).

Upon completion of the initial, two-step collection, the Program Security Administrator is
responsible for entering the applicant’s information into OPM’s e-QIP. 9 This will initiate the applicant
in OPM’s system, allowing the applicant to complete OPM’s required online security questionnaire.
Specifically, the Program Security Administrator enters the following data into e-QIP:
• name;
9

For more information on e-QIP, see OPM/CENTRAL-9 - Personnel Investigation Records, 75 FR 28307 (May 20,
2010).

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• DOB;
• POB;
• Social Security Number; and
• business email address.
Once the Program Security Administrator has initiated the applicant in e-QIP, the applicant
accesses e-QIP directly to complete and submit OPM’s online security questionnaire, Standard Form 86,
Questionnaire for National Security Positions. The applicant provides all information required by OPM
to perform its background investigation directly to OPM. The Program does not collect or have access to
the information provided by the applicant to OPM through e-QIP. However, the applicant must provide
the Program with copies of e-QIP signature pages that are printed at the end of the security questionnaire,
certifying that statements made on the security questionnaire are true, complete, and correct to the best of
the applicant’s knowledge and that knowingly providing a false statement is punishable by fine or
imprisonment or both under 18 U.S.C. §1001.
The applicant’s printed e-QIP signature pages are part of a package of DHS forms and standard
security forms 10 that must be submitted before the investigation process begins. The forms package also
includes a set of fingerprint cards, and a DHS Form 11000-9, Disclosure and Authorization Pertaining to
Consumer Reports Pursuant to the Fair Credit Reporting Act.
To initiate the background investigation process, the Program provides the complete package of
forms, including the initial DHS Form 9014, Critical Infrastructure Private Sector Clearance Program
Request, to the Personnel Security Division. All other PII required to complete the background
investigation and adjudication of the applicant’s security clearance is collected by OPM and the Personnel
Security Division respectively. The Program does not collect or have access to information obtained by
the Personnel Security Division or OPM during the investigation process. Once the background
investigation is complete and has been adjudicated by the Personnel Security Division, the Program
receives notice of the clearance determination and the date the clearance was granted.
As the Program is responsible for maintenance of the security clearance, including administering
annual training and initiating periodic reinvestigations, the Program maintains a roster to track the status
of individuals’ security clearances. That roster includes the following information: full name, Social
Security Number, DOB, POB, sector affiliation, date the applicant’s package was submitted to the
Personnel Security Division, date the package was sent to OPM, clearance granting date, the date the
applicant signed their Standard Form 312, Classified Information Nondisclosure Agreement, their role in
their company/sector, clearance/nondisclosure agreement/status remarks, investigation date, clearance
level, email address, company name, business address, and business phone number.

10

The National Archives and Records Administration, Information Security Oversight Office prescribes standard
forms that are used in administering the security classification programs in government.

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2.2

What are the sources of the information and how is the
information collected for the project?

All information that the Program collects as part of the clearance application process (e.g. forms,
fingerprint cards, and a copy of the applicant’s printed e-QIP signature pages) are submitted to the
Program directly from the applicant. Applicants are directed to provide information to the Program both
in hard copy and in electronic form. Applicants provide hard copy documents to the Program via regular
mail while electronic documents are provided to the Program via password-protected e-mail attachments.
The only information the Program receives that does not come directly from the applicant is the
administrative tracking information (e.g., date the package was sent to OPM, date the applicant’s
clearance was granted) and the notification of determination from the Personnel Security Division. The
Program Security Administrator also has access to the Department’s clearance database managed by the
Personnel Security Division, Integrated Security Management System (ISMS) for the purpose of
verifying individuals’ clearance status to ensure the Program roster of cleared partners remains current.
For information on ISMS, please review the privacy impact assessment, DHS/ALL/PIA-038 Integrated
Security Management System (ISMS).
The individual has a direct relationship with OPM and provides all information required in
support of OPM’s background investigation directly to OPM via the Standard Form 86, Questionnaire for
National Security Positions, which the applicant submits through OPM’s secure portal for investigation
processing, e-QIP. For more information on e-QIP, see OPM’s privacy impact assessment 11 or
OPM/CENTRAL-9 - Personnel Investigation Records, 75 FR 28307 (May 20, 2010). The Program does
not collect or have access to the information provided by the applicant to OPM through e-QIP.

2.3

Does the project use information from commercial sources or
publicly available data? If so, explain why and how this
information is used.

While commercial sources may be used by OPM or the Personnel Security Division in support of
their background investigations (e.g., to perform credit checks), the Program does not have access to such
information. No commercial sources or publicly available data is used by NPPD or the Program. The
Program only collects and retains information in support of its sponsorship function, and all information
collected is provided voluntarily by the individual.

2.4

Discuss how accuracy of the data is ensured.

The accuracy of the applicant’s information is verified directly with the applicant at the beginning
of the clearance process, by the Program Security Administrator, and during the investigation, by the
Personnel Security Division or OPM investigator. Additionally, the Program Security Administrator,

11

http://www.opm.gov/privacy/PIAs/eQIP.pdf

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who has access to ISMS, verifies the investigation/clearance information with the ISMS clearance
database.

2.5

Privacy Impact Analysis: Related to Characterization of the
Information

Privacy Risk: There is a risk that an individual may be unaware that he/she has been
nominated for sponsorship of a security clearance.

Mitigation: This risk is mitigated in that the Program collects information directly from the
applicant as part of the nomination process and is further mitigated in that the application process is
twofold, and sensitive PII is only collected from those individuals who are approved for DHS sponsorship
based on information submitted as part of the first step of the clearance application process..

Privacy Risk: There is a privacy risk that more information (particularly sensitive PII) than is
necessary may be collected.

Mitigation: This risk is mitigated in that the Program’s policy is to direct the applicant to
exclude certain sensitive PII, such as Social Security Number, DOB, and POB, from the initial clearance
request application until the Program’s Security Administrator has approved the applicant to be sponsored
by DHS for a security clearance. Only after that initial approval does the applicant provide the remaining,
sensitive PII necessary to initiate the requisite background investigations. The Program stores all
electronic files containing PII in a restricted-access folder on a shared drive. Electronic files containing
sensitive PII are password-protected. All hard copy or physical files are stored in locked drawers in
secured DHS office space. Only the Program Security Administrator has the keys to those drawers.

Privacy Risk:

There is a risk that collecting inaccurate information could result in an
unfavorable determination, impacting the applicant’s ability to obtain a security clearance.

Mitigation: To reduce this risk, the Program collects information required as part of the
application process directly from the applicant. The applicant also has a direct relationship with the
Personnel Security Division and with OPM through e-QIP and has the opportunity to correct erroneous
information during the investigation process.

Section 3.0 Uses of the Information
The following questions require a clear description of the project’s use of information.

3.1

Describe how and why the project uses the information.

The Program collects information from private sector partners in order to sponsor those
individuals for security clearances so that DHS may share pertinent information regarding infrastructure
protection, which at times may include classified information. For example, an individual would need a

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security clearance in order to attend a classified meeting or briefing in which Critical Infrastructure
information is being shared.
Specifically, the Program uses information obtained during the security clearance process in
support of the following functions: to initiate a background security investigation; verify identity; grant
physical access to a facility; grant a security clearance; confirm an applicant’s clearance status via ISMS;
communicate security updates; send meeting invites; conduct briefings; share sanitized contact lists, as
appropriate, with DHS cleared officials (e.g., Sector Specialists, Protective Security Advisors, etc.); or to
perform other security activities or general communications.

3.2

Does the project use technology to conduct electronic searches,
queries, or analyses in an electronic database to discover or locate
a predictive pattern or an anomaly? If so, state how DHS plans to
use such results.

No, the Program does not utilize technology to analyze the data in any way.

3.3

Are there other components with assigned roles and
responsibilities within the system?

The clearance process is initiated by the Program and completed by the Personnel Security
Division. No other DHS components are involved unless the applicant previously held a reinstateable
clearance with another DHS component. For example, if an applicant is a former cleared U.S. Secret
Service employee and is within the two-year window of reinstating their clearance, the Personnel Security
Division will contact the U.S. Secret Service to obtain the individual’s previous investigative file.

3.4

Privacy Impact Analysis: Related to the Uses of Information

Privacy Risk: As the Program acts as a liaison between the applicant and the Personnel
Security Division, there is a risk of loss or misuse of PII while the clearance request application and other
documents are being routed for signature or further processing.

Mitigation: This risk is mitigated in that the Program limits the collection of most sensitive PII
to those individuals who receive initial approval for DHS sponsorship from the Program’s Security
Administrator. Additionally, all Program personnel comply with DHS annual privacy training
requirements and are briefed on the proper safeguarding and handling requirements for sensitive PII, to
include ensuring access to information is only provided to those with a need to know. This risk is fully
mitigated in that the Program instructs individuals who must provide sensitive PII to do so via passwordprotected e-mail attachments. Passwords are sent via separate email to further minimize this risk should
an email be inadvertently misdirected. When the Program forwards information to the Personnel Security
Division, the same protections remain in place.

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Section 4.0 Notice
The following questions seek information about the project’s notice to the individual about the information
collected, the right to consent to uses of said information, and the right to decline to provide information.

4.1

How does the project provide individuals notice prior to the
collection of information? If notice is not provided, explain why
not.

The Program provides notice at the point of collection via a Privacy Act statement on the DHS
Form 9014, Critical Infrastructure Private Sector Clearance Program Request. This statement advises
the individual as to how their information will be used and why it is needed. Additionally, DHS provides
notice in the form of this PIA and the system of records notice for DHS/ALL-023 - Department of
Homeland Security Personnel Security Management, 74 FR 3084 (January 16, 2009).

4.2

What opportunities are available for individuals to consent to
uses, decline to provide information, or opt out of the project?

Providing information to the Program is voluntary, and the individual can opt out at any time by
notifying the Nominator or Program Security Administrator of their intent to do so. If an individual
chooses to opt out of the Program, and/or leaves the Department, after having started or completed the
clearance process, their records are removed from the Program roster, and the associated hard copy
records are moved to a separate file that is purged after three years.
Failure to provide sensitive PII, such as Social Security Number, would prevent the individual
from being processed for a security clearance, as that is required by OPM to perform its background
investigation.

4.3

Privacy Impact Analysis: Related to Notice

Privacy Risk: There is a risk that the notice provided may be inadequate.
Mitigation: This risk is mitigated in that the Program provides notice to ensure that Program
applicants are aware of how their information is being used. Participation in the Program is completely
voluntary, and Nominators address the criteria for sponsorship with each applicant upon expressing
interest in becoming part of the Program. The Program provides notice in this PIA and the SORN. OPM
also provides notice applicable to the collection of information through e-QIP.

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Section 5.0 Data Retention by the project
The following questions are intended to outline how long the project retains the information after the initial
collection.

5.1

Explain how long and for what reason the information is retained.

In accordance with the Personnel Security Division’s procedures, the Program maintains the
applicant’s clearance information both in a secured folder on the shared drive and in a physical file in a
locked drawer, with access limited to only those that have a need to know. The Program maintains
certain information pertaining to the individual’s clearance status on a clearance roster, which is also
maintained in a secure folder on the shared drive. The records retention schedule is covered by the
NARA General Records Schedule (GRS) 18 Items 21; 22; 23. Records are maintained from the time an
applicant begins the clearance application process until their security clearance is deactivated or the
individual’s participation with the Program is terminated. Destruction of an individual’s record will occur
upon notification of death or not later than five years after separation or transfer of employee or no later
than five years after contract relationship expires, whichever is applicable. Individuals who no longer
require access to classified information are removed from the roster, and their records are moved to a
separate drawer and purged after three years.

5.2

Privacy Impact Analysis: Related to Retention

Privacy Risk: Applicants covered by the Program are private sector individuals whose DHS
sponsorship is based on their relationship with DHS and need for access to classified information at the
time of their nomination to the Program. There is a risk that the Program may retain information longer
than necessary where an applicant separates from the Program or no longer requires access to classified
information.
Mitigation: The Program only retains the minimal amount of information necessary to perform
routine security activities, such as verifying clearance status or granting access to a facility. This risk is
fully mitigated in that applicants are advised that the Program’s sponsorship is based on their current
employment, and the individual is responsible to notify DHS if their employment changes, in which case
the program would re-evaluate their need for access to classified information. Additionally, the Program
continually updates its roster to ensure that only current and relevant information is maintained. The
Program Security Administrator has access to ISMS, the clearance database maintained by the Personnel
Security Division, in order to verify an individual’s clearance status. If access to classified information is
revoked, the individual’s information is purged in accordance with the GRS.

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Section 6.0 Information Sharing
The following questions are intended to describe the scope of the project information sharing external to
the Department. External sharing encompasses sharing with other federal, state and local government, and private
sector entities.

6.1 Is information shared outside of DHS as part of the normal
agency operations? If so, identify the organization(s) and how the
information is accessed and how it is to be used.
The Program shares limited information with OPM in order to initiate the applicant in e-QIP
where the applicant completes OPM’s online security questionnaire, Standard Form 86, Questionnaire for
National Security Positions. To initiate the applicant, the Program Security Administrator enters the
following data into e-QIP:
• full name;
• DOB;
• POB;
• Social Security Number; and
• business email address.
The Program may at times share lists of cleared individuals with external federal agencies to
facilitate clearing those individuals for participation in classified communications hosted by agencies
other than DHS. For example, in order for our financial sector partners to participate in a classified
briefing from the Department of Treasury, the Program would need to share a list of those partners who
hold security clearances with the Department of Treasury. The Program would accomplish this by
extracting relevant information from its clearance roster, sanitizing the list, to remove any sensitive PII,
and sharing information pertaining only to those individuals who require access to the classified briefing.
The sanitized list would include:
•

full name;

•

company name;

•

city;

•

state; and

•

business email address.

While the Program is responsible for compiling lists of cleared partners to facilitate classified
briefings, the Program does not share any sensitive PII outside of DHS. Where sensitive PII or other
information is required to verify an individual’s security clearance, the Personnel Security Division is
responsible for passing the information to the external agency.

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6.2

Describe how the external sharing noted in 6.1 is compatible with
the SORN noted in 1.2.

The Program only shares information outside of DHS to allow external agencies to confirm the
individual’s clearance status when access to classified information is required. This sharing is compatible
with the routine uses published in DHS/ALL-023 - Department of Homeland Security Personnel Security
Management, 74 FR 3084 (January 16, 2009).

6.3

Does the project place limitations on re-dissemination?

If any participant’s information is shared with external agencies, the information is marked as For
Official Use Only (FOUO)/Privacy Act Information, and the recipient is notified not to further
disseminate.

6.4

Describe how the project maintains a record of any disclosures
outside of the Department.

The Program keeps both paper and electronic records of external sharing. There is a log of
external requests that have been made along with email communication regarding the dissemination.

6.5

Privacy Impact Analysis: Related to Information Sharing

Privacy Risk: There is a risk of information being shared beyond the intended scope of the
Program.

Mitigation: Recipients of any PII collected by the Program are informed that the information is
FOUO/Privacy Act Information and, as such, should not be re-disseminated. When the Program
transmits any lists or information regarding cleared private sector individuals, the lists are passwordprotected, and the password is sent separately. All Program personnel are required to complete the
Department’s annual privacy training, and sharing of the information is compatible with the Department’s
published SORN.

Section 7.0 Redress
The following questions seek information about processes in place for individuals to seek redress which
may include access to records about themselves, ensuring the accuracy of the information collected about them,
and/or filing complaints.

7.1

What are the procedures that allow individuals to access their
information?

While the Program collects information at the initial stages of the application, the Personnel
Security Division maintains the official security file for the individual. The Personnel Security Division
advises clearance applicants of their clearance status via email notification, to include advising them of

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the procedures for requesting access to their information under the provisions of the Privacy Act. An
individual may request information from DHS by submitting a Freedom of Information Act/Privacy Act
(FOIA/PA) request to the DHS FOIA Officer at 245 Murray Lane SW, Washington, D.C. 20528. Further
information on the specific requirements of submitting a FOIA/PA request to DHS is available from
http://www.dhs.gov/xfoia/editorial_0316.shtm.

7.2

What procedures are in place to allow the subject individual to
correct inaccurate or erroneous information?

Once OPM initiates its background investigation, OPM works directly with the applicant,
providing that individual with the opportunity to correct inaccurate or erroneous information. Once the
clearance process is complete and has been adjudicated by DHS, the individual can correct erroneous
information in DHS’s records by submitting a request to the DHS FOIA Officer at 245 Murray Lane SW,
Washington, D.C. 20528. For any information that is under the control of OPM, the individual would
need to contact OPM directly.

7.3

How does the project notify individuals about the procedures for
correcting their information?

The Program advises applicants of procedures for correcting their information in various ways
throughout the application process. First, applicants are advised of the procedures during the nomination
and initial application processes. Second, OPM’s e-QIP system has built-in mechanisms for identifying
erroneous information. For example, if the applicant is unable to log into e-QIP, this generally indicates
that the information the Program Security Administrator inputted into e-QIP to initiate the applicant’s
security clearance questionnaire was entered incorrectly. The e-QIP system prompts users to contact their
agency point of contact for assistance with log-in help. In such instances, the applicant is instructed to
contact the Program Security Administrator who works with the applicant to correct any erroneous
information. The Program Security Administrator also instructs applicants to print out a review copy of
their e-QIP form to verify the accuracy of their responses before finalizing them. Lastly, the e-QIP
system provides error messages when information is missing or entered incorrectly, which prompts the
user to address the error before the user is able to submit information for processing.

7.4

Privacy Impact Analysis: Related to Redress

Privacy Risk: There is a risk that applicants may be unaware of or not understand their redress
options.

Mitigation: This risk is mitigated in that the Program provides individuals with clear notice of
their ability to access and correct their information, as well as to seek redress. Applicants are advised of
what information is in the custody of the Program and what information is maintained with the Personnel
Security Division or with OPM respectfully, and how to seek redress from those organizations.

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Section 8.0 Auditing and Accountability
The following questions are intended to describe technical and policy based safeguards and security
measures.

8.1

How does the project ensure that the information is used in
accordance with stated practices in this PIA?

The Program has undergone Site Assistance Visits by the Privacy Office in the past, as well as by
the Office of Security Administrative Security Division (December 2009). The Program has also met
with the Inspector General’s Office (December 2010). Access restrictions to the physical and electronic
files do not change unless a new employee or contractor begins work on the Program.

8.2

Describe what privacy training is provided to users either
generally or specifically relevant to the project.

All DHS employees and contractors are required to take Privacy Act training annually. The
Program fully complies with the Department’s required training.

8.3

What procedures are in place to determine which users may
access the information and how does the project determine who
has access?

Only the Program Security Administrator and staff directly supporting the Program have direct
access to the physical and electronic files. The Program only shares information for the purpose of
facilitating the clearance application processing and for classified visitor management. When information
is requested, the requestor’s “need-to-know” is reviewed, and if approved by the Program Security
Administrator, the Program shares only that information required to fulfill a specific purpose. For
example, a state-specific list of clearance holders may be required to facilitate a classified briefing for
private sector partners. If approved by the Program Security Administrator, the Program would share a
password-protected list of clearance holders, sanitized of sensitive PII, with the agency hosting the
briefing. This list would typically include: full name, sector, clearance level, company name, role in
company, their location (city/state), and business email address.

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8.4

How does the project review and approve information sharing
agreements, MOUs, new uses of the information, new access to the
system by organizations within DHS and outside?

The Program does not currently have any information sharing agreements or MOUs for sharing
data with other organizations.

Responsible Officials
Richard LePage
Director of Management
Office of Infrastructure Protection
National Protection and Programs Directorate
Department of Homeland Security

Approval Signature
[Original signed copy on file with the DHS Privacy Office]

Mary Ellen Callahan
Chief Privacy Officer
Department of Homeland Security