Social Security Number Justification Memo

DEFENSE COUNTERINTELLIGENCE AND SECURITY AGENCY
27130 TELEGRAPH ROAD
QUANT ICO, VA 22134-2253

February 6, 2024
MEMORANDUM FOR DEFENSE PRIVACY, CIVIL LIBERTIES, AND FREEDOM OF
INFORMATION DIRECTORATE
THROUGH: Defense Counterintelligence and Security Agency, Office of Privacy, Civil
Liberties, and Freedom of Information
SUBJECT: Justification for the Use of Social Security Numbers (SSNs) in the General Request
for Investigative Information (INV 40), Employment Data and Supervisor Information (INV 41),
Educational Registrar and Dean of Students Record Data (INV 43), and Law Enforcement Data
(INV 44) forms.
1. System /Form
The information collected on the General Request for Investigative Information (INV 40),
Employment Data and Supervisor Information (INV 41), Educational Registrar and Dean of
Students Record Data (INV 43), and 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, 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.

DEFENSE COUNTERINTELLIGENCE AND SECURITY AGENCY
27130 TELEGRAPH ROAD
QUANT ICO, VA 22134-2253

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 and 43 are sent to employment references and educational institutions. The INV 40, 41,
43, and 44 contain the subject’s full name, date of birth and full SSN. 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.
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), 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.
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), and 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. Citation and Migration
Citation of statutory requirement for the use of the SSN is not applicable to the INV Forms. Plan
of Action for the migration from/elimination of the SSN on the INV Forms is not applicable.

DEFENSE COUNTERINTELLIGENCE AND SECURITY AGENCY
27130 TELEGRAPH ROAD
QUANT ICO, VA 22134-2253

5. Safeguards
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
forms. 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 Robert N. Wingard at
[email protected].
signed by
WINGARD.ROBE Digitally
WINGARD.ROBERT.N.11115972
07
RT.N.1111597207 Date: 2024.02.06 11:45:49 -05'00'

Robert N. Wingard
Lead Program Analyst
Defense Counterintelligence and Security Agency
signed by
ALLEMAN.LISA. Digitally
ALLEMAN.LISA.M.1572059622
Date:
2024.02.09
09:38:24 -05'00'
M.1572059622

Lisa M. Alleman
Chief Privacy Officer
Defense Counterintelligence and Security Agency