Justification A for OMB 1140-0058 (ATF Form 8620.7) 9.25.2020

Department of Justice
Bureau of Alcohol, Tobacco, Firearms and Explosives
Information Collection Request
Supporting Statement
OMB 1140-0058
Investigator Quality Survey - ATF Form 8620.7
A.

JUSTIFICATION
1.

Necessity of Information Collection
Pursuant to the Memorandum of Understanding (MOU) between the
Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) and the
Office of Personnel Management (OPM), dated March 3, 2000, ATF is
authorized to use its Federal or contract investigators to conduct personnel
security and suitability background investigations and periodic
reinvestigations. Investigations are conducted on applicants and employees
in competitive service positions, as well as candidates, contractors, Task
Force Officers (TFOs), or volunteers/interns in ATF service provider
positions. All personnel security investigations are conducted in
accordance with the Intelligence Reform and Terrorism Prevention Act of
2004, 5 C.F.R. Part 736, and Executive Orders 13467 and 13764.
Per Executive Order 12968, each investigator must have a favorably
adjudicated national security, critical sensitive clearance that meets the
OPM requirements, prior to performing investigative assignments.
Contract investigators are required to complete the same level of
background screening and re-screening as Federal investigators.
In accordance with the MOU, ATF must also maintain an "Investigator
Integrity Follow-up Program," to ensure that contract investigators are
conducting their duties in accordance with the 2012 Federal Investigative
Standards. The Investigator Quality Survey - ATF Form 8620.7 was
created as part of this follow-program, and is currently used to ensure that
ATF contract investigators conduct themselves professionally, while
performing their investigative duties.
ATF requests approval to make the following changes to OMB 1140-0058
(Investigator Quality Survey - ATF Form 8620.7):
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The name of this IC is being changed from Investigator Integrity
Questionnaire to Investigator Quality Survey.
Electronic completion and submission of the form.
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•
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Type of interview question expanded to include “Virtual”
interview.
Interview schedule question now includes “Randomly Contacted.”
Question 5 added – When the interview ended, did you have
sufficient information to contact the investigator if necessary (i.e.,
name and email address/telephone number)?
Question 7 added – Provide the number of times you were
contacted by the investigator after the interview and the reasons for
the contact(s). (Previous version of form requested this information
as part of another question.)
Question 14 added - The length of the interview was sufficient to
thoroughly address each topic – “yes” or “no” response.
Updated Privacy Act Statement – References to Executive Orders
10450 and 12968 were replaced with Executive Orders 13764 and
13467.

2.

Needs and Uses
ATF Personnel Security Program Managers or their designees will
randomly solicit feedback from persons who have been interviewed by
ATF contract investigators, using the Investigator Quality Survey
- ATF Form 8620.7. The respondent will receive the survey and
instructions for completion by email, and will be required to verify that
contract investigators are conducting interviews in a professional manner,
in accordance with prescribed policies. Specifically, policy requirements
regarding conducting interviews include scheduling appointments in
advance and informing respondents about the Privacy Act rights of the
individual under investigation. Investigators must also present a
professional appearance, properly identify him/herself, professionally
conduct interview(s), and provide post-interview contact information.

3.

Use of Information Technology
The Investigator Quality Survey- ATF Form 8620.7 is available for
electronic completion. Personnel Security Division (PSD) personnel will
email the form to the respondent and request feedback regarding a recent
interview with an ATF contract investigator. Once the respondent
electronically completes the survey, he/she will submit the form via email,
to the designated ATF email inbox.

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.

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5.

Minimizing Burden on Small Businesses
This information collection has no effect on small businesses. The
information sought is in response to a voluntary interview in which an
individual participated, during a Federal background investigation. The
purpose of creating a record is to document a contractor’s performance
while conducting their investigative duties.

6.

Consequences of Not Conducting or Less Frequent Collection
ATF utilizes contract investigators to conduct security/suitability
investigations about prospective or current ATF employees, as well as
those contractors and consultants doing business with ATF. The use of
contract investigators to conduct personnel security/suitability interviews,
allows ATF to dedicate its Federal investigators to combating crime.
Without this information collection, ATF would be unable to obtain public
feedback about personnel security/suitability investigations.

7.

Special Circumstances
This information collection requirement is consistent with the intent of the
MOU requiring that ATF implement an "Investigator Integrity Follow-up
Program," to ensure that contract investigators are conducting
investigations in accordance with the 2012 Federal Investigative
Standards. Respondents may voluntarily participate in this survey. There
are no special circumstances causing this information collection to be
conducted in a different manner, including but not limited to:
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8.

Requiring respondents to report information to ATF more often
than quarterly;
Requiring respondents to prepare a written response in fewer than
30 days after receipt of the questionnaire;
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
OPM representatives were consulted during the creation of this
information collection. No comments were received during the 60-day
Federal Register notice period. However, a 30-day notice will be published
in the Federal Register to solicit public comments.

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9.

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

10.

Assurance of Confidentiality
Confidentiality is not assured. Information collected by the PSD is
protected by the Privacy Act of 1974 and will not be released to outside
parties, unless authorized as set forth in the Privacy Act of 1974.

11.

Justification for Sensitive Questions
The survey does not include questions of a sensitive nature. However,
questions concerning the behavior and degree of professionalism of the
contract investigator are asked.

12.

Estimate of Respondent’s Burden
It is anticipated that 2,500 respondents will complete this form annually.
Each respondent will respond one time. It is estimated that it takes 5
minutes to complete the form. The total number of annual burden hours
associated with this collection is 208 hours.

13.

Estimate of Cost Burden
There is no new cost associated with this information collection since all
requests will be electronically submitted.

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.

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.

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18.

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

B.

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL
METHODS
None

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