SUPPORTING STATEMENT
Title of Information Collection (Police Record Check DD Form 369)
A. JUSTIFICATION
1. Need for Information Collection
Title 10, U.S. Code, Sections 504, 505, 508, 12102, and EO 9397 establish minimal standards for enlistment into the Armed Forces. Among other items, these sections specifically prohibit the enlistment of those convicted of a felony. The Services have therefore developed standards which address the acceptability for Service persons with police records, adverse juvenile adjudication’s, or court convictions. The standards are designed to screen out categories of persons who have probability of either becoming serious disciplinary problems or may not be able to adjust to the disciplinary demands of the Armed Forces. This information collection is needed to identify persons who may be undesirable for military service. The existence of a police record is one of the factors considered in establishing eligibility for enlistment or entry into highly sensitive career fields. Therefore, verification data from the individual and law enforcement agencies must be obtained before enlistment can occur.
2. Use of Information
The primary purpose of this information is to identify individuals who may be undesirable for military service. The respondent is the state, local police or law enforcement agency for which the inquiry is directed. The form associated with this information collection is the DD Form 369, “Police Records Check.” It is used by recruiters to inquire on applicants backgrounds prior to acceptance to the Armed Forces, when in the judgment of the recruiter; an applicant may be withholding information of a prior offense history. The recruiter utilizes this information provided by law from the law enforcement agency to determine an applicant’s general enlistment eligibility and to identify individuals who may be undesirable for military service. This information is extracted at the law enforcement agency be either computer or a card file. This information is maintained as confidential and is utilized currently as a screening tool for recruiters; it is stored in their personnel file and is destroyed within 3-6 months after enlistment or rejection from Service.
The data which has been collected over the past 3 years has allowed recruiters to process qualified applicants who meet the acceptable entry standards for the Armed Forces and assisting in the reduction of the attrition rate for basic trainees.
Improved Information Technology.
The form is available on the DoD Electronic Forms Website in Fillable Adobe PDF files and used by the Military Entrance Processing Command (MEPCOM) Integrated Resource System (MIRS) at the Military Entrance Processing Stations (MEPS). The initial completion of applicant’s information occurs electronically at the recruiting station. However, full implementation of electronic transmission and digital signatures, as required under the GPEA, is not yet possible due to the unavailability of electronic connections (standardized hardware and/or software) between Federal and state/local government agencies at this time. Strategic planning has occurred and research and development has begun on ongoing initiatives, including biometrics. Progress is contingent upon funding of these ongoing initiatives.
4. Efforts to Identify Duplication
A review by military recruiting representatives resulted in no findings of duplicate information, records, or reporting. No similar information or verification procedure exists that can be used for this information collection.
5. Methods Used to Minimize Burden on Small Entities
The collection of information does not involve small businesses or other small entities.
Consequences of Not Collecting the Information
If collection of information ceased, the ability to meet determination for
enlistments as required by law for prior offense history could not be met.
Special Circumstances
This collection of information is not conducted under special circumstances; the respondent is asked questions by the recruiter and the form is completed one time. The information is utilized for none other than enlistment purposes by the Department of Defense. No requirements are placed on the respondent after providing the information and the personal information collected is kept confidential to the qualification process and the individual’s military record. This collection will be conducted in a manner consistent with guidelines contained in 5 CFR 1320.5 (d) (2).
Agency 60-Day Federal Register Notice and Consultations Outside the Agency
The 60-day Federal Register Notice announcing this information collection (as required by 5 CFR 1320.8(d)) was published in Vol. 74, No. 212, Wednesday, November 4, 2009, Federal Register, page 57153, as required by 5 CFR 1320.8(d). No public comments were received in response to the notice. This information collection was also reviewed by designated representatives from each Service Department Headquarters and Recruiting Commands.
Payments to Respondents
No payments, gifts, or guarantees are made to respondents who provide this
information.
Assurance of Confidentiality
Respondents are advised that statements will be held in strictest confidence and procedures are in place to protect the confidentiality of the information. The forms are maintained in personal records and are seen only by individuals who have a need to verify information contained on the form. The paper forms will be secured to protect Personally Identifiable Information (PII) in accordance to DoD regulations. Records are maintained in secure, limited access, or monitored areas. Physical entry by unauthorized persons is restricted through the use of locks, passwords, or other administrative procedures. Access to personal information is limited to those individuals who require the records to perform their official assigned duties. The Privacy Act Statement is contained on the DD Form 369.
Personal Identifying Information, Sensitive Questions, and Protection of the
Information
Gender and race/ethnicity and social security numbers are asked to confirm identity of the respondent. The uniqueness of the SSN allows proper validation of data across several state, local, and federal systems and ensures that the correct information is provided for the purposes of moral qualification. Failure to provide information or providing incorrect information could have a detrimental affect on the Armed Services moral qualification process. Since law enforcement agencies may have several persons with the same name, distinguishing characteristics, including gender/race and ethnicity, law enforcement agencies ask these questions in order to ensure the validity of the applicant’s identity before releasing any prior offense history to the Military Services. The paper forms will be secured to protect Personally Identifiable Information (PII) in accordance to DoD regulations. Records are maintained in secure, limited access, or monitored areas. Physical entry by unauthorized persons is restricted through the use of locks, passwords, or other administrative procedures. Access to personal information is limited to those individuals who require the records to perform their official assigned duties.
Estimates of Annual Response Burden and Labor Cost for Hour Burden to the
Respondent for Collection of Information.
a. Response Burden:
(1) DD Form 369
Total annual respondents: 175,000
Frequency of response: 1
Total annual responses: 175,000
Burden per response: 27 minutes
Total burden hours: 78,750
Explanation of How Burden was Estimated. Burden estimate of 27 minutes for
processing the DD Form 369 verified telephonically by a local law enforcement agency.
Labor Cost to Respondents. There is a labor cost to the respondent to fill out
this form or to manually annotate the date on the form from law enforcement agencies’ card files or process computer copies of the data. The requirement estimated for a clerk to look up the information on a computer screen and print out the information and send out the form has been estimated at:
$17.49/hr. x 27 minutes = $7.87 per form.
175,000 respondents at $7.87 = $1,377.250.
13. Estimates of Other Cost Burden for the Respondent for Collection of Information.
a. Total Capital and Start-up Cost. There is no capitol or set up cost associated
with this information collection. Respondent will utilize systems currently in
place to identify data requested not only from the government but other law
enforcement agencies and other public and private agencies.
b. Operation and Maintenance Cost. Of the 175,000 DD Form 369, “Police
Records Check” that is verified and completed by law enforcement agencies,
10% has a computer –generated copy of the police record attached to the request.
17,500 at .10/page (paper cost) = $1750
17,500 X $5.60 (computer time) = $98,000
Total O&M cost to respondent: $99,750
14. Estimates of Cost to the Federal Government.
a. Work load requirements.
1. E-5 / E-7 hourly pay = $15.08 at 3 minutes/form $.75
2. GS-06/ Step 03 hourly pay = $15.40 at 3 minutes/form $1.28
3. Printing at .10 cents per form $.10
4. Cost of postage $.85
Cost to the Federal Government per respondent $2.98
Total Federal Government costs (175,000 X $2.98) $521,500
15. Changes in Burden.
The increase in estimated burden hours is due to additional recruiting requirements due to the increase in recruiting missions of the Armed Services. Increase in cost is an adjustment to correct mathematic/computation error in previous reporting.
16. Publication Plans/Time Schedule.
Results of this information collection will not be published.
Approval Not to Display Expiration Date.
Approval not to display the expiration data is not being sought.
Exceptions to the Certification Statement.
No exceptions to the certification statement are being sought.
B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS
Statistical methods are not employed for this collection of information.
| File Type | application/msword |
| File Title | The following are the headings for each question to be used in the Supporting Statement: |
| Author | OUSD PR |
| Last Modified By | pltoppings |
| File Modified | 2010-04-01 |
| File Created | 2010-01-04 |