SSN Memo

DEFENSE HEALTH AGENCY

7700 ARLINGTON BOULEVARD, SUITE 5101
FALLS CHURCH, VIRGINIA 22042-5101
DESHIELDS.RITA.
SCHINE.12293617
98

Digitally signed by
DESHIELDS.RITA.SCHINE.1229
361798
Date: 2019.02.15 12:39:25 -05'00'

DHA Privacy
Office Review
MEMORANDUM FOR DEFENSE PRIVACY, CIVIL LIBERTIES AND TRANSPARENCY
DIVISION
SUBJECT: Justification for the Use of the Social Security Number (SSN) in Department of
Defense Suicide Event Report (DoDSER), DoD Information Technology Portfolio Repository
(DITPR) #13190
This memorandum is to satisfy the requirements of the Department of Defense
Instruction (DoDI) 1000.30, Reduction of Social Security Number (SSN) Use Within DoD, dated
August 1, 2012, requiring justification to collect and use the SSN in DoD systems, with respect
to DoDSER. DoDSER is a surveillance tool for the collection and analysis of data on cases of
suicide behavior, including death by suicide, suicide attempt, and self-harm. The data reported
on an annual basis is for the purpose of describing the population that engaged in suicidal
behavior and to monitor changes in the frequency of behavior.
The system of records notice (SORN) applicable to DoDSER is EDHA 20 DoD,
Department of Defense Suicide Event Report (DoDSER) System (April 15, 2016, 81 FR 22240)
(Attachment A). The DoDSER Privacy Impact Assessment (PIA) is currently being updated.
Therefore, the executed DoDSER PIA dated October 23, 2013 is included for reference
(Attachment B). DoDSER is subject to the Paperwork Reduction Act (PRA). The current
version of the OMB control number is 0720-0058 with an expiration date of 08/31/2019
(Attachment C).
In accordance with DoDI 1000.30, continued use of SSNs within DoDSER must be
justified by one or more of the Acceptable Uses set forth in DoDI 1000.30, Enclosure 2, Section
2. The Acceptable Uses applicable to DoDSER are Section 2.c.(8), Computer Matching.
“Systems, processes, or forms that interact with other Government agencies may require the
continued use of the SSN as a primary identifier until such time as the applications to which they
are linked move to some other identifier as a primary means for transferring, matching, or
checking information.” The data collected in DoDSER are merged with data from other existing
record systems for the purpose of case verification and data quality assurance. The DoDSER
program is working on transitioning to the exclusive use of the electronic data interchange
personal identifier to the extent practicable. At this time, case verification for deaths involves
linkage to compiled state death records that are identified the SSN.
The discussion below sets forth why SSNs still need to be currently collected in DoDSER
under Acceptable Use Case 2.c.(8).

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. If DoDSER 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.
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. EDI-Pis are not,
and cannot be used, by non-DoD organizations as an identifier or for their business processes.
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 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 Information (PII) data is not placed into analytical
reports. The program will evaluate potential alternatives to SSNs and examine the costs and
business requirements associated with shifting to an alternative.
The DHA Component/Office point of contact for this program is Derek Smolenski,
Epidemiologist, (253) 968-4250, [email protected].
Digitally signed by

CURRY.JUSTIN.CAM CURRY.JUSTIN.CAMPBELL.110
PBELL.1104624762 4624762
Date: 2019.02.13 13:38:14 -05'00'

Justin Curry, PhD
Section Chief, Performance and Analytics
Psychological Health Center of Excellence
Defense Health Agency, J-9
Attachments:
As Stated