SUPPORTING STATEMENT - PART A
Defense Counterintelligence and Security Agency (DCSA)
Freedom of Information / Privacy Act Records Request for Background Investigations
DCSA Form INV 100 – 0705-0001
Summary of Changes from Previously Approved Collection
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1. Need for the Information Collection
The purpose of the information collection is to enable the DCSA Freedom of Information and Privacy (FOIP) Office for Investigations to accurately locate relevant records maintained on individuals when they are requested pursuant to the Privacy Act of 1974. Authority to collect this information is contained in 5 U.S.C. § 552a, the Privacy Act of 1974, as amended; 10 U.S.C. 113, Secretary of Defense; 32 C.F.R. part 310, DoD Privacy Program, 32 C.F.R. part 321, Defense Security Service Privacy Program, and DoD 5400.11-R, Department of Defense Privacy Program, and Executive Order 9397, as amended.
The DCSA is the primary personnel vetting agency of the Federal Government dedicated to protecting America’s trusted workforce conducting approximately 2 million background investigations annually. Upon the completion of a background investigation, the individual on whom the investigation was conducted may invoke their right to access those records under the provisions of the Privacy Act. Furthermore, they have a right to request Amendment of those records.
Information collected by the DCSA from individuals requesting a copy of their background investigation, or amendment of such, includes personal identifiable information (PII) such as: full name, social security number (SSN), address, date and place of birth, and other personal information. The information is used to accurately identity individuals and to ensure the highly sensitive information gathered during the investigative process is not inadvertently disclosed to a third party. The collection of PII is also necessary because many Federal employees, contractors, civilians, and military personnel share identical names and/or birth dates and their identities can only be distinguished by this information.
2. Use of the Information
The INV100 is published on the DCSA website and can be provided to an individual, hardcopy via postal mail or digitally via email) if a respondent contacts the DCSA FOIP Office for Investigations. The DCSA FOIP Office for Investigations accepts / receives requests for records from respondents via e-mail, facsimile, or postal mail. Due to the highly sensitive personal information that is contained in our records, in order to positively verify the identity of the requester per DoD 5400.11-R, May 14, 2007, section C3.1.3, requests from individuals for information on themselves are required to provide their: full name, full social security number, date and place of birth and verify their identity under penalty of perjury to include a handwritten signature, or an electronic signature made via the a Common Access Card (CAC)/Personnel Identity Verification (PIV) signature. While not required, the Freedom of Information/Privacy Act Records Request for Background Investigations (INV 100) form standardizes the collection of the required information.
The DCSA FOIP Office for Investigations understands that while individuals are aware they are entitled to receive a copy of the records pertaining to themselves, they are not always aware of procedures required to make such a request and may choose not to utilize the INV 100. Often, requests are missing data elements which require contact with the requester, thereby adding time to the process. In these instances, the requester is notified that additional information is necessary prior to processing their request. Although the information is voluntary, we inform the requester that without the additional information we may be unable to locate relevant records. The information collection tool will decrease the burden on the requester to provide additional required information in order to gain access to their records and to simplify the process for identifying responsive records.
Once the DCSA FOIP Office for Investigations receives the completed form, the request is added to the workflow queue to be processed on a first-in, first-out basis. The INV100 is used to ensure that the relevant responsive records are retrieved from available data systems. For those records maintained at DCSA, but not under DCSA release authority, the FOIP Office will ensure those records are referred to the appropriate Federal agency(ies) having the jurisdictional control and release authority. The individual’s request form (INV100) is attached to any referred records, so the receiving agency is privy to the initial request.
3. Use of Information Technology
The collection does involve a degree of automation, since the form is available in a portable document file (PDF) format. The form may be delivered as a scanned email attachment, via postal mail or facsimile to the FOIP Office for Investigations. If a respondent decides to digitally transmit their completed request, we advise that they validate the security of their system before transmitting. Respondents may also leverage use of the DoD Secure Access File Exchange (SAFE) system if they are unable to send their request via secure/encrypted email.
If the requester is submitting a FOIA request for agency records not pertaining to themselves, INV 100 may be transmitted electronically once completed, or printed and mailed or faxed to DCSA FOIP Office for Investigations. Percentage of electronically submitted responses make up 95-98% of those total responses.
If the requester is making a request for records about themselves, the INV 100 must be completed, then signed electronically with a PIV or CAC signature, or printed and contain a handwritten signature. DCSA’s Protection of Privacy and Access to and Amendment of Individual Records under the Privacy Act of 1974 regulation (32 C.F.R. § 310.3) explain a requester must sign the request and have it notarized or submit the request under 28 U.S.C. 1746. The completed Freedom of Information/Privacy Act Records Request for Background Investigations can then be mailed hardcopy, faxed, or scanned and emailed as an attachment to DCSA FOIP Office for Investigations.
4. Non-duplication
The information obtained through this collection is unique and is not already available for use or adaptation from another cleared source.
Information collected on the INV 100 is specific to the DCSA FOIP Office for Investigations. Use of the form is voluntary and collection of the information is only required if the individual makes a FOIA, Privacy Act or Amendment request.
5. Burden on Small Businesses
This information collection does not impose a significant economic impact on a substantial number of small businesses or entities.
6. Less Frequent Collection
Use of the INV 100 is intended to standardize the collection of the necessary information to simplify and make more efficient the process of making a Freedom of Information Act (5 U.S.C. § 552) and/or Privacy Act of 1974 (5 U.S.C. § 552a) request. Additionally, the standardized collection of information will enhance DCSA’s request processing and minimize the number of imperfect requests submitted.
7. Paperwork Reduction Act Guidelines
This collection of information does not require collection to be conducted in a manner inconsistent with the guidelines delineated in 5 CFR 1320.5(d)(2).
8. Consultation and Public Comments
Part A: PUBLIC NOTICE
A 60-Day Federal Register Notice (FRN) for the collection published on Monday, April 17, 2023. The 60-Day FRN citation is Vol. 88, No. 73, FRN 23412.
No comments were received during the 60-Day Comment Period.
A 30-Day Federal Register Notice (FRN) for the collection published on Monday, August 21, 2023. The 30-Day FRN citation is 88 FR 56806.
Part B: CONSULTATION
No additional consultation apart from soliciting public comments through the Federal Register was conducted for this submission.
9. Gifts or Payment
No payments or gifts are being offered to respondents as an incentive to participate in the collection.
10. Confidentiality
A Privacy Act Statement is included on page 1 of the information collection tool.
Any disclosure of this information collection tool or the information contained therein is in accordance with the Privacy Act of 1974, as amended, and the routine uses are found in DoD-wide System of Record Notice (SORN), DoD-0008 Freedom of Information Act and Privacy Act Records:
The information collection tool is maintained in the Privacy Act Case File located on the shared drive and may be retained for up to six years in accordance with the NARA General Records Disposition Schedules 4.2, item 20.
A draft copy of the PIA, DCSA Enterprise Service Delivery Platform, has been provided with this package for OMB’s review.
11. Sensitive Questions
The information collection tool does not ask questions of a sensitive nature pertaining to sexual behavior and attitudes, religious beliefs, race and/or ethnicity, and other matters that are commonly considered private.
Social Security Number (SSN): The collection of a requester’s social security number is necessary to conduct an adequate search of records maintained in DCSA systems. The SSN is the primary personal identifier used in major national security systems, of many Federal agencies, and it remains the only unique identifier that ensures the accuracy across all the systems for proper data retrieval. DoD Instruction 1000.30, Reduction of Social Security Number (SSN) Use Within DoD, stipulates that the use of the SSN as the single identifier which links personnel vetting files (e.g., background investigations, adjudication records, security clearance records, etc.) pertaining to a person is an acceptable use of the SSN. The solicitation of the SSN is voluntary; however, without it the FOIP Office for Investigations may not be able to retrieve records from the systems response to the request. See Social Security Number Justification Memo submitted with this package.
12. Respondent Burden and its Labor Costs
Part A: ESTIMATION OF RESPONDENT BURDEN
Collection Instrument(s)
[DCSA Form INV 100]
Number of Respondents: 10,097
Number of Responses Per Respondent: 1
Number of Total Annual Responses: 10,097
Response Time: 5 minutes
Respondent Burden Hours: 841 hours
Total Submission Burden (Summation or average based on collection)
Total Number of Respondents: 10,097
Total Number of Annual Responses: 10,097
Total Respondent Burden Hours: 841 hours
Part B: LABOR COST OF RESPONDENT BURDEN
Collection Instrument(s)
[DCSA Form INV 100]
Number of Total Annual Responses: 10,097
Response Time: 5 minutes
Respondent Hourly Wage: $ 20.71 (~$ .35 per minute)
Labor Burden per Response: $ 1.75
Total Labor Burden: $ 17,670
Overall Labor Burden
Total Number of Annual Responses: 10,097
Total Labor Burden: $17,670
The Respondent hourly wage was determined by using the [Department of Labor Wage Website] (https://www.bls.gov/oes/current/oes_nat.htm)
13. Respondent Costs Other Than Burden Hour Costs
There are no annualized costs to respondents other than the labor burden costs addressed in Section 12 of this document to complete this collection.
14. Cost to the Federal Government
Part A: LABOR COST TO THE FEDERAL GOVERNMENT
Collection Instrument(s)
[DCSA Form INV 100]
Number of Total Annual Responses: 10,097
Processing Time per Response: 1 Hour
Hourly Wage of Worker(s) Processing Responses: $ 35.10
Cost to Process Each Response: $ 35.10
Total Cost to Process Responses: $ 354,404.70
Overall Labor Burden to the Federal Government
Total Number of Annual Responses: 10,097
Total Labor Burden: $ 354,404.70
Part B: OPERATIONAL AND MAINTENANCE COSTS
Cost Categories
Equipment: $0
Printing: $0
Postage: $0
Software Purchases: $0
Licensing Costs: $0
Other: $0
Total Operational and Maintenance Cost: $0
Part C: TOTAL COST TO THE FEDERAL GOVERNMENT
Total Labor Cost to the Federal Government: $ 354,404.70
Total Operational and Maintenance Costs: $0
Total Cost to the Federal Government: $ 354,404.70
15. Reasons for Change in Burden (1-7 sentences)
There has been no change in burden since the last approval.
16. Publication of Results (1 sentence/ 1 paragraph)
The results of this information collection will not be published.
17. Non-Display of OMB Expiration Date
We are not seeking approval to omit the display of the expiration date of the OMB approval on the collection instrument.
18. Exceptions to “Certification for Paperwork Reduction Submissions”
We are not requesting any exemptions to the provisions stated in 5 CFR 1320.9.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Kaitlin Chiarelli |
| File Modified | 0000-00-00 |
| File Created | 2023-09-01 |