Social Security Justification Memo

DEFENSE COUNTERINTELLIGENCE AND SECURITY AGENCY
27130 TELEGRAPH RO AD
QUANTICO, V A 22134-2253

April 19, 2021
MEMORANDUM FOR DEFENSE PRIVACY, CIVIL LIBERTIES, AND
TRANSPARENCY DIVISION
THROUGH: Defense Counterintelligence and Security Agency, BI, Policy
Defense Counterintelligence and Security Agency, FOI/P, Charles Watters
SUBJECT: Justification for the Use of Social Security Numbers (SSNs) in Forms General
Request for Investigative Information (INV 40), Employment Data and Supervisor Information
(INV 41), Personal Information (INV 42), Educational Registrar and Dean of Students Record
Data (INV 43), Law Enforcement Data (INV 44).
1. System /Form
The information collected on the General Request for Investigative Information (INV 40),
Employment Data and Supervisor Information (INV 41), Personal Information (INV 42),
Educational Registrar and Dean of Students Record Data (INV 43), Law Enforcement Data (INV
44) forms is used for Federal and Federal contract employment.
2. Documentation
As noted in the Personnel Vetting SORN, the INV 40, 41, 42, 43, and 44 are used to collect
information from a multitude of sources to support federal background investigation and
personnel vetting processes such as: investigations and determinations of eligibility for access to
classified national security information, and for access to special access programs; suitability for
federal employment; fitness of contractor personnel to perform work for or on behalf of the U.S.
Government; and Homeland Security Presidential Directive (HSPD)-12 determinations for
Personal Identity Verification (PIV) credentials to gain logical or physical access to government
facilities and systems. Section 925 of Public Law 115·91; 5 U.S.C. 301, and Executive Order
13467, as amended by Executive Order 13869 authorize the collection of information. The INV
Form 44, in particular, facilitates DCSA's access to criminal history record information under 5
U.S.C. 9101.
The content of the INV forms is also designed to meet notice requirements for personnel
investigations specified by 5 C.F.R. 736.102(c). These notice requirements apply to any
"investigation . . . to determine the suitability, eligibility, or qualifications of individuals for
Federal employment, for work on Federal contracts, or for access to classified information or
restricted areas."
None of the forms are used for any purpose other than a personnel background investigation, as
described above. The completed forms are maintained by DCSA subject to the protections of the
Privacy Act of 1974, as amended.

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Procedurally, the subject of a personnel background investigation discloses the identity of
relevant sources, such as supervisors, coworkers, neighbors, friends, current or former spouses,
instructors, relatives, or schools attended, on the standard form (SF) SF 85, Questionnaire for
Non-Sensitive Positions; the SF 85P, Questionnaire for Public Trust Positions; or the SF 86,
Questionnaire for National Security Positions. The INV forms are distributed to the provided
source contacts identified on the standard form questionnaire through an automated mailing
operation.
The INV 40 is used to collect records from a Federal or State record repository or a credit
bureau. The INV 44 is used to collect law enforcement data from a criminal justice agency. The
INV 41, 42, and 43 are sent to employment references, associates, and educational institutions.
The INV 40, 41, 43, and 44 contain the subject’s full name, date of birth and full SSN. The INV
42 - Personal Information – does not include the subject’s SSN or DOB. The forms disclose that
the source's contact information was provided by the subject to assist in completing a
background investigation regarding the subject's eligibility for employment or security clearance,
and request that the source complete the form to help in this determination.
3. Authorized Uses
ln accordance with DoDI 100.30, continued use of SSNs for forms General Request for
Investigative Information (INV 40), Employment Data and Supervisor Information (INV 41),
Educational Registrar and Dean of Students Record Data (INV 43), Law Enforcement Data (INV
44), must be justified by one or more of the Acceptable Use Cases set forth in DoDI 1000.30,
Enclosure 2. The applicable Acceptable Use Case is as follows:
Acceptable Use Case 2.c. (3), Security Clearance Investigation or Verification. The
initiation, adjudication, verification, quality assurance, and billing fund control of
background investigations and security clearances requires the use of the SSN. The SSN
is the single identifier that links all of the aspects of these investigations together. This
use case is also linked to other Federal agencies that continue to use the SSN as a primary
identifier.

4. The system of records notice (SORN) currently applicable to all the INV forms [the General
Request for Investigative Information (INV 40), Employment Data and Supervisor Information
(INV 41), Personal Information (INV 42), Educational Registrar and Dean of Students Record
Data (INV 43), and the Law Enforcement Data (INV 44)] is DUSDI 02-DoD, Personnel Vetting
Records System.

UNCLASSIFIED//FOUO
Privileged Under the Investigative Files Privilege and Exempt from Disclosure Under FOIA Exemption 7E
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5. A thorough effort has been made to evaluate the risk associated with use of the SSN on the
INV 40, 41, 43, and 44 forms. Only authorized personnel with a need to know will have access
to the form. Privacy Act cover sheets will be used to protect documents in work areas. Paper and
electronic copies will be disposed of as required by the records disposition schedules.
6. Point of Contact
For questions related to this memorandum contact Donna L. McLeod at
[email protected].

Donna L. Mcleod
Executive Program Manager
Defense Counterintelligence and Security Agency

UNCLASSIFIED//FOUO
Privileged Under the Investigative Files Privilege and Exempt from Disclosure Under FOIA Exemption 7E
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