SSN Justification Memo

OFFICE OF THE ASSISTANT TO THE SECRETARY OF DEFENSE FOR
PRIVACY, CIVIL LIBERTIES, AND TRANSPARENCY
1155 DEFENSE PENTAGON
WASHINGTON, DC 20301-1155

September 5, 2024
Ref: SSNJ-2024-0001-NDU
MEMORANDUM FOR THE OFFICE OF CHIEF INFORMATION, NATIONAL DEFENSE
UNIVERSITY
SUBJECT: Justification for the Use of Social Security Numbers in the National Defense University
(NDU) Student Management System (SMS) called “NDU Connect,” Student Data Files,
and DataMart database - Approval
Thank you for completing a review of Social Security Number (SSN) use within the subject
system. My office has reviewed and approved your request to use the SSN for the following Acceptable
Use: (13) Other Cases. Note, SSN use is approved indefinitely or until the establishment of a reasonable
alternative for the collection of data other than the SSN such as the Department of Defense Identification
Number, the program’s mission changes thus eliminating the need for the SSN use, or the system is
decommissioned.
NDU Connect is an integrated digital platform designed for managing student information,
academic records, and other administrative functions. The SSN is used to register students and generate
their official transcripts, and is the unique identifier used to provide accurate data on each student to
verify the academic record (e.g., course grades, length of enrollment, etc.). The NDU Registrar uses
student SSNs to verify a student’s identity to ensure the integrity of each student’s academic record, that
is, that each course and grade reflected in each student’s transcript belongs to that student. NDU’s
accrediting body, the Middle States Commission on Higher Education (MSCHE), requires the SSN.
Accurate student data is essential for institutions accredited by MSCHE for several reasons such as
compliance and reporting, institutional planning and assessment, and financial aid enrollment. Removing
the use of the SSN impacts identification, data integrity, and federal reporting requirements including to
the Department of Education. Furthermore, the submission notes several legacy system interfaces with
plans to transfer those systems to NDU Connect by mid-2027.
While this system has been identified as requiring the collection, maintenance, and use of the
SSN, you must ensure this data is afforded the highest protections practicable through use of appropriate
administrative, technical, and physical safeguards. Please maintain a copy of your justification and this
approval in your records.
The reference number for this action is listed at the top of this memorandum. If you have any
questions, my point of contact is Mr. Joseph Redd at [email protected].
KELETA.RAHW
A.AMDEMARIA
M.1298456431

Digitally signed by
KELETA.RAHWA.AMDEMA
RIAM.1298456431
Date: 2024.09.05 13:18:20
-04'00'

Ms. Rahwa A. Keleta
Director, Privacy and Civil Liberties
cc:
NDU Privacy Office