SSN Justification memo

OFFICE OF THE ASSISTANT SECRETARY OF DEFENSE

HEALTH AFFAIRS

SKYLINE FIVE, SUITE 810, 5111 LEESBURG PIKE

FALLS CHURCH, VIRGINIA 22041-3206

TRICARE
MANAGEMENT
ACTIVITY

MAR - 9 2012

MEMORANDUM FOR THE RECORD
SUBJECT: Justification for the Use of the Social Security Number in the Department of
Defense Suicide Event Report; Department of Defense Information Technology
Portfolio Repository Identification 13190
This memorandum is written to satisfy the requirements established in the Office of the
Under Secretary of Defense for Personnel and Readiness (USD(P&R)) Directive-Type
Memorandum (DTM) 07-015-USD(P&R), "DoD Social Security Number (SSN) Reduction
Plan" with respect to the Department of Defense (DoD) Suicide Event Report (DoDSER). The
DoD Information Technology Portfolio Repository Identification assigned to DoDSER is 13190.
This memorandum provides justification for the continued collection and use ofSSNs by
DoDSER. The System of Records Notice applicable to DoDSER is Defense-Health Affairs
(DHA) 20 (May 6,2010, Volume 75 Federal Register 24928) (attached). The Privacy Impact
Assessment for DoDSER became effective June 25, 2010 (attached). The DoDSER Plan of
Actions and Milestones (POAMs) for elimination of the use ofSSNs is included as an
attachment. We are not aware of any Paperwork Reduction Act requirements with respect to
DoDSER data collection.
DoDSER is a population-based surveillance system that provides integrated enterprise
and survey data used for direct reporting of suicide events and on-going population-based health
surveillance activities. DoDSER is used to collect information on Active Duty and Reserve
military personnel and members of the National Guard with reportable suicide and self-harm
behaviors, including suicide attempts, self-harm behaviors, and suicidal ideation. All other DoD
Active and Reserve military personnel records collected without evidence of reportable suicide
or self-harm behaviors exist as a control group. An individual's record within DoDSER includes
the individual's SSN.
DoDSER records are integrated from enterprise systems and also developed from record
reviews and interviews to create a set of standardized data items regarding suicide and self-harm
behaviors. Data collected over time is connected to create longitudinal records of an individual's
ideation, self-harm behaviors, and/or suicides. Surveillance activities conducted through
DoDSER include the systematic collection, analysis, interpretation, and reporting of
outcome-specific data for use in planning, implementation, evaluation, and prevention of
suicide behaviors within DoD.

DTM 07-015, Paragraph 2.c.(l1), includes "Legacy System Interface" as an acceptable
use ofSSNs so long as there are plans in place for the migration away from SSNs in the future.
The discussion below sets forth why SSNs still need to be currently collected in DoDSER under
Acceptable Use Case 2.c.( 11).
DoDSER is an active surveillance program, particularly with respect to individuals whose
information is in DoDSER as a result of a suicidal ideation event or a self-harm behavior event.
DoDSER data regarding an individual is obtained from both DoD and non-DoD sources.
Although a DoD data source may be able to identify an individual's record in a DoD system
through the individual's Electronic Data Interchange - Personal Identifier (EDI-PI), the EDI-PI is
not an identifier used by non-DoD data sources (such as law enforcement agencies and/or state
and local governments). These non-DoD data sources, however, generally are able to identify an
individual through the individual's SSN, coupled with another identifier such as the individual's
name. IfDoDSER does not collect an individual's SSN, it will not be able to request or connect,
with a requisite degree of certainty, non-DoD sourced data relevant to an individual's suicide,
suicidal ideation, or self-harm behaviors.
As previously referenced, DoDSER provides a longitudinal record of individuals with
prior histories of self-harm behaviors and suicidal ideation. Creation of accurate longitudinal
data requires the capacity to relate new DoDSER data with data that has been previously
collected within DoDSER (including new and existing DoDSER data obtained from non-DoD
sources). A common identifier that may be used to connect old and new data and records,
whether created within DoD or by a non-DoD source, is the individual's SSN. Accurate
longitudinal records are essential to ongoing population-based health surveillance activities and
for developing statistical summaries needed by federal, state, and local governments for health
surveillance and research activities (See DHA 20, attached). Without a SSN, the difficulty in
creating accurate and detailed longitudinal records creates risks to DoDSER's capacity to
provide the intended surveillance and analytical data.
In addition, one of the key purposes of the DoDSER program is to support research. A
critical requirement to accomplish this purpose is the ability to link DoDSER data to other
databases, including non-DoD databases (e.g., Department of Veterans Affairs' databases). An
individual's SSN is the single most important variable for matching cases in the DoDSER
database to other non-DoD databases prior to de-identifying data for research.
The DoDSER program has taken significant steps to reduce the vulnerability ofSSNs.
For example, the program does not permit individuals to retrieve a DoDSER case by SSN (or
other personally identifiable variable) 180 days after the DoDSER record is submitted. This
significantly reduces the chances of inappropriate or accidental releases of personally identifiable
data, since cases are "locked" by the system after 6 months. In addition, the system uses
role-based accounts to ensure that users have access to only the specific cases they need in order
to accomplish their mission. The vast majority of users are basic data entry users, and they can

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only access cases that they personally submitted through the system. They cannot view SSNs or
other data submitted by others. Furthermore, when the data is used for surveillance or research
purposes, the data is only used in aggregated group analyses (e.g., de-identified forms).
Personally identifiable data is not placed into analytical reports.
The DoDSER program has developed a POAM for the elimination of the use of SSNs
(attached). The program will evaluate potential alternatives to SSNs and examine the costs and
business requirements associated with shifting to an alternative.
If there are any questions, the point of contact is Gregory Gahm, PhD. Dr. Gahm may be
reached at (253) 968-2282, or [email protected]

~---W. Bryan Gamble, M.D., F ACS
Brigadier General, US Army
Deputy Director

Attachments:
As stated

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