3 - Supporting Statement - ATF F 8620.70 - 7-2-2024

ATF F 8620.70, Request for Interim Security Clearance

OMB Control Number 1140-0119

OMB Expiration Date: 12/31/2024

SUPPORTING STATEMENT FOR

ATF F 8620.70, REQUEST FOR INTERIM SECURITY CLEARANCE

1. JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) conducts personnel security investigations on applicants and employees in competitive service positions, as well as candidates, contractors, task force officers (TFOs), and student interns/volunteers 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 13764 and 13467.

ATF recruits individuals for placement into full time equivalent federal positions and solicits individuals through the federal acquisition process to fill non-ATF personnel (contractor, TFO, and student intern/volunteer) positions. Candidates who are tentatively selected for positions must meet federal, Department of Justice (DOJ), and ATF basic qualification requirements before they may be granted access to ATF information, information technology (IT) systems, and/or unescorted access to ATF facilities. Individuals will not be granted access if they fail to meet these requirements and receive an unfavorable adjudication of their background investigation and/or polygraph examination (special agent applicants only).

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

The Request for Interim Security Clearance - ATF Form 8620.70 is used to request approval for a candidate seeking Federal or Contractor employment. This form will gather personally identifiable information (PII) to initiate the process of determining the eligibility for granting a candidate (respondent) an interim security clearance before the completion and adjudication of the individual’s background investigation.

ATF’s Personnel Security Division (PSD) staff may approve the request following a favorable review of the candidate’s completed Standard Form 86, Questionnaire for National Security Positions, and applicable record checks. Upon reviewing the information provided, PSD staff will assess whether the respondent may be granted interim access to classified National Security Information on a need-to-know basis, along with temporary access to ATF information, IT systems, and/or unescorted access to ATF facilities.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also, describe any consideration of using information technology to reduce burden.

ATF makes every effort to take advantage of electronic collection and dissemination capabilities available. This fillable ATF Form 8620.70 (with electronic signature capability) is available on the ATF portal for download and distribution by ATF sponsors (human resources specialists and contracting officer’s representatives) to respondents. The form is emailed to respondents along with submission instructions for returning the completed package to ATF for processing. Respondents electronically complete the form and submit it via an encrypted email, or password protect the completed form and send via email. The respondent may also print and mail the form to a specific address provided by ATF. Individuals with disabilities are also able to access and complete this form. ATF has adopted a fully electronic submission process, which has eliminated the public cost burden for mailing completed forms.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item A.2 above.

ATF uses a uniform subject classification system for forms 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.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

This collection of information has no impact on small businesses or other private entities.

6. Describe the consequence to federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

ATF must ensure that all employees and non-ATF personnel have the highest degree of integrity and character, while maintaining the safety and security of ATF information, IT systems, and facilities. ATF would be unable to ensure the safety and security of its resources without this information collection. A candidate’s onboarding for employment would also be delayed without this information collection.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

• requiring respondents to report information to the agency more often than quarterly;

• requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

• requiring respondents to submit more than an original and two copies of any document;

• requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;

• in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

• requiring the use of statistical data classification that has not been reviewed and approved by OMB;

• that includes a pledge of confidentially that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentially to the extent permitted by law.

There are no special circumstances.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years -- even if the collection-of-information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

The 60-Day Notice was published in the Federal Register on [DATE] (XX FR XXXXX). The comment period ended on [DATE]. No comments were received.

9. Explain any decision to provide any payments or gifts to respondents, other than remuneration of contractors or grantees.

No government funds will be used as payment or for gifts to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

Confidentiality is not assured in the processing of this information collection.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

The information collection does not include questions of a sensitive nature. However, respondents are required to provide PII, including full name and Social Security Number (last four digits) to verify the respondent’s identity.

12. Provide estimates of the hour burden of the collection of information. The statement should:

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. General, estimates should not include burden hours for customary and usual business practices.

• If this request for approval covers more than one form, provide separate hour burden estimates for each form.

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.

Estimated Annualized Respondent Cost and Hour Burden

Activity	Number of Respondents	Frequency	Total Annual Responses	Time Per Response	Total Annual Burden (Hours)	Hourly Rate*	Monetized Value of Respondent Time
ATF Form 8620.70	2000	1	2000	5 min.	167	N/A*	N/A*
Unduplicated Totals

*No hourly rate or monetized value can be established as this information collection relates to respondents who may or may not be employed; and who are voluntarily completing the form (one time) as part of the federal personnel security process for tentatively selected candidates for employment.

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

• The cost estimate should be split into two components: (a) a total capital

and start up cost component (annualized over its expected useful life); and (b) a

total operation and maintenance and purchase of service component.

The estimates should take into account costs associated with generating,

maintaining, and disclosing or providing the information. Include descriptions of

methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

• If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

• Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

There are no start-up costs associated with this collection.

14. Provide estimates of the annualized cost to the Federal Government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 into a single table.

There is no cost to the Federal Government.

15. Explain the reasons for any program changes or adjustments.

ATF has implemented an electronic process for respondents to submit completed personnel security forms. The electronic process has eliminated respondent costs associated with submitting the response.

16. For collections of information whose results will be published, outline plans for tabulations, and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

ATF will not publish the results of this information collection.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

ATF is not requesting approval to omit the expiration date of this information collection.

18. Explain each exception to the certification statement.

This collection of information does not include any exceptions to the certificate statement.

B. COLLECTIONS OF INFORMATON EMPLOYING STATISTICAL METHODS.

This collection does not contain statistical data.