Ssn Justification

DEPARTMENTS OF THE ARMY AND AIR FORCE
ARMY & AIR FORCE EXCHANGE SERVICE
Office of the General Counsel
P.O. Box 650060
Dallas, TX 75265-0060

GC-C

APRIL 23, 2019

MEMORANDUM THRU:
Army Privacy Office (AAHS-RDF), 9301 Chapek Rd. Bldg. 1458 Fort Belvoir, VA 22060-5605
FOR Defense Privacy, Civil Liberties and, Transparency Division, 4800 Mark Center Drive,
Alexandria, VA 22350-3100
SUBJECT:

Justification for the Use of the Social Security Number (SSN) – Accounts
Receivable Files

1.
This memorandum is to satisfy the requirements of DoDI 1000.30, “Reduction of Social
Security Number (SSN) Use Within the DoD,” requiring justification to collect and use the SSN.
2.
The Exchange Accounts Receivable Files is a system of records consisting of information
collected from potential, past, or authorized Exchange patrons. Disclosure of information is
necessary so the Exchange may take steps to process, monitor, and post audit accounts
receivable, to administer the Federal Claims Collection Act, to answer inquiries pertaining
thereto, and report to the consumer reporting agencies as an incentive for debtors to repay
delinquent Federal government debts. The SSN may be used to search for responsible
documents relative to such debt.
3.
The applicable acceptable uses for collection and use of the SSN are (4) Interactions With
Financial Institutions and (12) Operational Necessity. SSN collected is used to open account,
locate account, and to correspond with financial institutions and places of employment for the
need of garnishing wages, salaries, or to collect credit information. The SSN is also used in
regards to taxpayer information. These uses are consistent with the SSN Instruction Use Case in
Enclosure 2 sections 2.c.(4), and (7) of DoDI1000.30.
4.
The System of Records Notice (SORNs) associated with the Exchange Accounts
Receivable Files is AAFES 0702.34, “Accounts Receivable Files”. Exchange systems are standalone technologies and not part of Department of Defense Business Information Systems.
Therefore, there is not DIPTR number to provide.
5.
Information contained in this system is solicited by authority of Title 10 U.S.C. §7013,
Secretary of the Army; Title 10 U.S.C. §9013, Secretary of the Air Force; Federal Claims
Collection Act of 1966 (Pub.L. 89-508, as amended)and Debt Collection Act of 1982 (Pub.L. 97365, as amended), as amended by the Debt Collection Improvement Act of 1996 (Pub.L. 104134, section 31001) as codified in 31 U.S.C. §3711, Collection and Compromise; 31 CFR
285.11, Administrative Wage Garnishment; DoD Instruction 1330.21, Armed Services Exchange
Regulations; DoD 7000.14-R, Department of Defense Financial Management Regulation
Volume 13:, “Nonappropriated Funds Policy” and Volume 16: “Department of Defense Debt

Management”; Army Regulation 215-8/Air Force Instruction 34-211(I), Army and Air Force
Exchange Service Operations; and E.O. 9397 (SSN), as amended.
6.
The Exchange has taken steps to minimize the risk of unauthorized access to information
located in this system of records. Paper and electronic records are maintained in controlled areas
which are only accessible to authorized personnel. Records are maintained in a controlled
facility. Physical entry is restricted by the use of locks, guards, and is accessible only to
authorized personnel. Access to records is limited to person(s) with an official "need to know"
who are responsible for servicing the record in performance of their official duties. Persons are
properly screened and cleared for access. Access to computerized data is role based and further
restricted by passwords, which are changed periodically.
Disclosures of information located within this system is pursuant to those permitted under Title
5 U.S.C. §552a(b) of the Privacy Act of 1974, as amended. This may include disclosures to the
U.S. Department of Justice/U.S. Attorneys for legal action, the Internal Revenue service to
obtain locator status for delinquent accounts, to private collection agencies for collection
action, to the Department of the Treasury, Financial Management Service for the purpose of
collecting debts, to any employer for garnishment purposes, and to military banking facilities.
7.
My POC is Mrs. Teresa Schreurs, Paralegal, FOIA/Privacy Manager,
[email protected], 214-312-6103.

On behalf of:
EDWIN LLEWELLYN
Deputy General Counsel
Office of the General Counsel

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