SSN Justification

DEFENSE HUMAN RESOURCES ACTIVITY
FEDERAL VOTING ASSISTANCE PROGRAM
4800 MARK CENTER DRIVE, SUITE 03J25-02
ALEXANDRIA, VA 22350-4000

MEMORANDUM FOR DEFENSE PRIVACY AND CIVIL LIBERTIES OFFICE
THROUGH: Office of the Secretary of Defense/Joint Staff Privacy Office
FROM: Matt Boehmer, Acting Director, Federal Voting Assistance Program

BOEHMER.MATT
HEW.D.11629344
37

Digitally signed by
BOEHMER.MATTHEW.D.1162934437
DN: c=US, o=U.S. Government, ou=DoD,
ou=PKI, ou=DODHRA,
cn=BOEHMER.MATTHEW.D.1162934437
Date: 2013.04.18 09:34:55 -04'00'

SUBJECT: Justification for the Use of the Social Security Number (SSN) - Federal Write-in
Absentee Ballot (SF 186)
The Federal Write-in Absentee Ballot (FWAB) is used by members of the Uniformed
Services, Merchant Marine, their dependents and U.S citizens living abroad (collectively referred
to as Uniformed and Overseas Citizen Absentee Voter Act (UOCAVA) voters) to vote in
elections if they have previously requested an absentee ballot but have not yet received it. In
some States, it may be used for voter registration and ballot request as well. The FWAB is
available in paper (SF186) and electronic (SF186a) versions. The same automated tool on
FVAP.gov can also be used to complete SF186a. Attached is the proposed FWAB revision.
When citizens complete the paper FWAB they mail it directly to the appropriate State or
territory office. It is not received or used by the Federal government, but used by the States and
territories in order to determine voter eligibility, register voters, and identify if the owner
submitted backup ballot is an eligible registered voter. If the automated tool on FVAP.gov is
used to complete the forms, any information entered by the voter (to include the SSN) is not
stored in the system and is deleted when the citizen exits the program.
The acceptable use applicable for continued collection of Social Security Numbers is (13)
Other Cases. In this instance the FWAB form must broadly satisfy the varied requirements in all
50 States, 4 territories, and the District of Columbia. Only Massachusetts and North Dakota do
not use the SSN in any form. The full SSN is required as a voter identification number by
Hawaii, Kentucky, South Carolina, Tennessee, and Virginia. American Samoa, Delaware, and
New Mexico allow voters to provide either their full SSN or their State Driver’s License (or ID)
number as their voter identification number. The remaining States and territories either allow
voters to provide the last 4 digits of their SSN or their State Driver’s License (or ID) number.
The 2005 iteration of the FWAB form had marked the full SSN as “Required”
information. In the 2011 iteration of the FWAB form, FVAP worked to increase voter privacy,
and removed the “Required” language. The 2013 iteration that we are currently working to
approve makes clear that most States do not require the full SSN. The option to provide either
the State Driver’s License or ID number is listed prior to the social security number. Revised
instructions on the forms indicate that voters should check their individual State instructions in
the Voting Assistance Guide or at FVAP.gov to verify whether their full SSN is required.

Because the collection of SSNs is governed by State and territorial laws the SSN Usage
Instruction Use Case that applies to the forms is Other Cases.
Attachments: As stated
OSD/JS Privacy Official Initials: _________ Date: _________

ALLARD.CI
NDY.L.123
1656614

Digitally signed by
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ou=DoD, ou=PKI, ou=WHS,
cn=ALLARD.CINDY.L.12316566
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Date: 2013.04.30 11:51:43
-04'00'

Prepared by: Kathleen McDonnell, DHRA-FVAP, 571-372-1168