OMB Final 1140-0105 ATF F 8620 65 Justification - 508

Department of Justice
Bureau of Alcohol, Tobacco, Firearms and Explosives
Information Collection Request
Supporting Statement
1140-0105
ATF F 8620.65, Request for ATF Background Investigation Information
SUPPORTING STATEMENT
A.

JUSTIFICATION

1.

Necessity of Information Collection
Pursuant to a Memorandum of Understanding between the Office of Personnel
Management (OPM) and the Bureau of Alcohol, Tobacco, Firearms and
Explosives (ATF), ATF is authorized to conduct security and suitability
background investigations on applicants for, or appointees of, positions within the
competitive service. Also, pursuant to Executive Order 10450, ATF has the
authority to conduct background investigations on persons entering employment
of, or employed by, the Government, other than in the competitive service
(including, but not limited to, contractors). In this capacity, ATF serves as an
investigative service provider and, therefore, has a repository of background
investigation records.
ATF collects and disseminates background investigation records in accordance
with Internal Security Record System-Justice/ATF-006 and is subject to all of the
published routine uses of that system of records. ATF background investigation
records may be disclosed to other Federal government agencies in connection
with hiring or continued employment of an employee or contractor. ATF may
also release background investigation records to State or local agencies (including
the District of Columbia) when the requesting agency is seeking to staff a law
enforcement officer position.
ATF receives requests for background investigation records from other Federal,
State, and local agency representatives via agency letterhead; in person office
visits; OPM Portal inquiries; Justice Security Tracking and Adjudication Record
System (JSTARS) inquiries; telephone calls; fax; and email. When a request is
received, other than through the OPM portal or JSTARS, ATF will provide a copy
of ATF F 8620.65, Request for ATF Background Investigation Information, to the
agency representative and request that the representative complete the form.

2.

Needs and Uses
The information from this request form is collected and maintained by ATF’s
Office of Professional Responsibility and Security Operations, Personnel Security
Branch (PSB) to document the official request for the background investigation
record. By maintaining evidence of an agency’s request for a background
investigation record, ATF ensures that proper disclosure requirements are

followed. This documented request assists ATF in ensuring that unauthorized
disclosures of information do not occur and establishes uniformity in disclosure
procedures.
3.

Use of Information Technology
ATF makes every effort to take advantage of the electronic collection and
dissemination capabilities available. Currently, ATF does not have the capability
to accept electronic submissions. This fillable form is available on the ATF
website for PSB personnel to download and forward to the requesting agency
representative. An agency representative may submit the form to ATF by
scanning the completed and signed document and emailing it to a specific ATF
email address. Individuals with disabilities can access this form.

4.

Efforts to Identify Duplication
ATF uses a uniform subject classification system to identify duplication and to
ensure that any similar information already available cannot be used or modified
for use for the purpose of this information collection.

5.

Minimizing Burden on Small Businesses
This information collection has no effect on small businesses. The information
sought is in response to an initial request received from another Federal, State or
local agency. The purpose of creating a record is to document the other agency’s
official request for an ATF background investigation. The information collection
is also used by ATF to make an authorized disclosure of information
determination and streamline the request process.

6.

Consequences of Not Conducting or Less Frequent Collection
The consequences of not conducting this information collection results in ATF
delays in providing other Federal, State and local agencies with their requested
information. Delays in processing requests occur when insufficient information
(reason for requesting the information, authorized agency representative,
preferred method of delivery of information) is received from originating
agencies. With insufficient data, ATF is unable to make a timely authorized
disclosure determination based on the available information.

7.

Special Circumstances
This information collection requirement is consistent with the intent of Executive
Order 10450. The information sought is necessary to allow ATF to make
authorized disclosure determinations of background investigation records based
on the type of agency requesting the information and the reason for the request.
There are no circumstances that would cause the information collection to be
conducted in any manner:

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8.

Requiring respondents to report information to ATF more than quarterly;
Requiring respondents to prepare a written response in fewer than 30 days;
Requiring respondents to submit more than an original of any document;
Requiring respondents to retain any records;
Requiring the use of any statistical data;
Requiring any pledge of confidentiality; or
Requiring respondents to submit any proprietary or trade secrets.

Public Comments and Consultations
No comments were received during the 60-day notice period. However, a
30-day notice will be published to solicit public comments momentarily.

9.

Provision of Payments or Gifts to Respondents
No decision of payment or gift is associated with this collection.

10.

Assurance of Confidentiality
Confidentiality is not assured. The respondent’s completed ATF Form 8620.65 is
kept in a secure location at headquarters within the PSB. The information on the
completed ATF Form 8620.65 becomes a part of the permanent personnel
security record of the subject, is included in Internal Security Record System –
Justice/ATF-006 (68 FR 3555-6), and is subject to all of the published routine
uses of the system of records.
Information collected by PSB is protected by the Privacy Act of 1974 and should
not be released to outside parties who do not have a need to know under the
routine use clause of the Privacy Act of 1974.

11.

Justification for Sensitive Questions
ATF Form 8620.65 asks respondents (other Federal, State and local agencies) to
provide personal identifying information, including the full name and the last four
digits of the social security number, on individuals for whom the respondents
have requested copies of previous ATF background investigations. This
information is necessary to positively identify the individual with the previous
background investigation and allow for the respondent to provide agency
information, reason for the request, agency point of contact, and preferred method
for forwarding the copies of the requested information. This information
collection acts as an official record from which an authorized disclosure
determination can be made and facilitates ATF’s expeditious response to the
request for the background investigation information.

12.

Estimate of Respondent’s Burden
It is anticipated that 300 respondents will complete this form per year. Each
respondent will complete one form for every request for background investigation

information made on individuals. It is estimated that it takes 5 minutes to
complete the form. The total number of annual burden hours associated with this
collection is 25 hours.
13.

Estimate of Cost Burden
There is no new or annualized cost associated with this information collection.

14.

Cost to Federal Government
There is no cost to the Federal Government.

15.

Reason for Change in Burden
There are no program changes or adjustments associated with this collection. The
instrument was added to provide for records of requests received from other
Federal, State, and local agencies for background investigation information; assist
ATF in making authorized disclosure of information determinations; and establish
a uniform process.

16.

Anticipated Publication Plan and Schedule
ATF will not publish this information collection.

17.

Display of Expiration Date
ATF is not requesting approval to omit the expiration date for this information
collection.

18.

Exception to the Certification Statement
There are no exceptions to the Certification Statement.

B.

None

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL
METHODS