0704-0514 SSN Justification Memo

DEFENSE LOGISTICS AGENCY
HEADQUARTERS
8725 JOHN J. KINGMAN ROAD
FORT BELVOIR, VIRGINIA 22060-6221

MEMORANDUM FOR DEFENSE PRIVACY CIVIL LIBERTIES AND TRANSPARENCY
DIVISION
SUBJECT: Social Security Number Justification for PoliceCenter (POLC) Information System
Department of Defense Instruction (DODI) 1000.30, “Reduction of Social Security
Number (SSN) Use Within DoD,” (August 1, 2012), requires all DoD personnel to reduce or
eliminate the use of SSNs wherever possible, except when the use of the SSN meets one or
more of the acceptable use criteria DoDI 1000.30 establishes. To continue use of the SSN in a
system or form, DLA must provide a memorandum justifying the continued use to the
Defense Privacy, Civil Liberties, and Transparency Division.
This memorandum serves to justify the continuing need for the collection and use of
the SSN for the Police Center (POLC) information system. The POLC information system
has a Privacy Impact Assessment (PIA) and maintains records from the following DLA
Privacy Act systems of records notices (SORNs):
S500.30 – Incident Investigation/Police Inquiry Files
S500.41 – Vehicle Traffic Incident Files
S500.42 – Seizure and Disposition of Property Records
S500.43 – Firearms Registration Records
S500.50 – Facility Access Records
Please note that DLA is working to combine the above referenced SORNs into a single SORN
covering the enterprise collection and administration of DLA police incident investigation,
seized property management, firearms registration, and facility access related records. When
the new SORN is published a revised SSN Justification Memo will be provided.
Under the DODI 1000.30, Enclosure 2, section 2, paragraph c, there are 13 designated
acceptable uses for SSNs. The designated acceptable use for the POLC information system is
as follows:
“(2). Law Enforcement, National Security, and Credentialing. Almost every law
enforcement application available to Federal, State, and local law enforcement and
other criminal justice agencies reports and tracks individuals, and makes
application information available to other agencies, through the use of the SSN. This
includes, but is not limited to, checks of the National Crime Information Center;
State criminal histories; and Federal Bureau of Investigation records checks.”
Information collected directly from the public is captured via DLA Form 635. This
collection is in accordance with Sections 3501-3520 of the Paperwork Reduction Act and has
an OMB Collection number (0704-0514).
The SSN is used within the DLA POLC information system by DLA Police, DLA
Installation Support, DLA Office of the Inspector General, and DLA Office of General
Counsel personnel to refer and investigate reported incidents; to monitor the progress of cases;
to ensure proper maintenance and safekeeping of privately owned firearms by personnel
residing on DLA controlled premises or who are required to register firearms with DLA; to

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control access into DLA-managed installations, buildings, facilities, and parking lots; to verify
security clearance status of individuals requiring entry into restricted access areas; and to relay
threat situations and conditions to DoD law enforcement officials for investigative or
evaluative purposes.
The SORNs used for the POLC information system cite several authorities for the
collection and maintenance of the records it contains. These include: 5 U.S.C. 301,
Departmental Regulations; 5 U.S.C. 303(b), Oath to Witnesses; 10 U.S.C. 133, Under
Secretary of Defense for Acquisition, Technology, and Logistics; 10 U.S.C. 136, Under
Secretary of Defense for Personnel and Readiness; 10 U.S.C. 1580, Emergency Essential
Personnel, designation; DOD Directive 5210.56, Arming and the Use of Force; 10 U.S.C.
1585, Carrying of Firearms; 10 U.S.C. 1593, Uniform allowance: civilian employees; 18
U.S.C. 499, Military, Naval, or Official Passes; 18 U.S.C. 701, Official Badges, Identification
Cards, Other Insignia; 18 U.S.C. 716, Police Badges; National Highway Safety Act of 1966
(23 U.S.C. 401, Highway Safety, et seq.); Section 21 of the Internal Security Act of 1950 (50
U.S.C. 797, et seq.); DOD Instruction 5200.8, Security of DOD Installations and Resources
and the DOD Physical Security Review Board (PSRB); DOD Instruction 6055.17, DOD
Emergency Management (EM) Program; CJCSI 3121.01B, Standing Rules of
Engagement/Standing rules for the Use of Force for US Forces; DOD Directive 5105.22,
Defense Logistics Agency; and E.O. 9397 (SSN) as amended by E.O. 13478.
DLA Police gather this information and safeguard it. The POLC information system
will be protected by DLA policies on Information Assurance. All infrastructure supporting the
POLC information system will have all applicable Security Technical Implementation Guides
(STIGs), checklists, and vulnerability scans applied. Additionally, only DLA Police Officers,
DLA Installation Support, Security and Emergency Services (DM-S) personnel, and DLA
Office of General counsel attorneys are authorized access to records within or from the POLC.
Personnel are vetted by the designated POLC installation application administrative officer,
prior to granting access to the system. Each POLC installation application administrator has
the ability to add, modify, and deactivate users from their site-specific portion of the POLC
information system. Access requires Common Access Card (CAC) authentication and use of
a unique user identification and DoD-compliant password. Insider and outsider threats for
information theft, hacking, etc., are mitigated through the use of encryption,; and ensuring
compliance with information assurance and other DOD Directives, policies and procedures for
DOD use and implementation of Commercial-Off-the-Shelf (COTS) applications. The
assigned Information System Security Manager (ISSM) reviews associated risks and provides
detailed information to both the DLA Chief Privacy and FOIA Officer and the DLA decision
authority for acceptable/non-acceptable use and maintains applicable Plan of Action and
Milestones (POA&M) for security and privacy controls. Significant changes to the POLC
information system are reviewed for privacy implications by the DLA Chief Privacy and
FOIA Officer.
My signature below constitutes approval and justification for continued use and
storage of SSNs in the POLC information system.
My points of contact are Mr. Alexander Logan (DLA Police Files) and Mr. Gerald
Barb (DLA Access Control Files), DLA Installation Support, Security and Emergency
Services, at (571)767-3071, DSN 392-3071, e-mail: alexander.logan@dla.mil or (571)7675425, DSN 392-5425, email: Gerald.barb@dla.mil.

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signed by
CUTLER.KATH Digitally
CUTLER.KATHY.D.1229501662
2019.02.13 12:24:50
Y.D.1229501662 Date:
-05'00'

KATHY CUTLER
Director, DLA Information Operations
Chief Information Officer
The below signature serves as acknowledgement that this document has been reviewed by the
DLA Chief Privacy Officer.

OLEINICK.LEWI
S.W.1286751934

Digitally signed by
OLEINICK.LEWIS.W.1286751934
Date: 2018.04.02 13:04:12 -04'00'

LEWIS OLEINICK, CIPP/US/G
DLA Chief FOIA and Privacy Officer