Ssn Justification

DEPARTMENTS OF THE ARMY AND AIR FORCE
ARMY & AIR FORCE EXCHANGE SERVICE
Office of the General Counsel – Compliance Division
P.O. Box 650060
Dallas, TX 75265-0060
PH: 214-312-6103 / FAX 214-465-2388

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May 26, 2022

MEMORANDUM THRU:
Army Privacy Office (AAHS-RDF), 9301 Chapek Rd. Bldg. 1458 Fort Belvoir, VA 22060-5605
FOR Defense Privacy, Civil Liberties and Transparency Division, 4800 Mark Center Drive,
Alexandria, VA 22350-3100
SUBJECT: Justification for the Use of the Social Security Number (SSN) – Accounts
Receivable Files; Exchange Credit Program.
1. This memorandum is to satisfy the requirements of DoDI 1000.30, “Reduction of Social
Security Number (SSN) Use Within the DoD,” requiring justification to collect and use the SSN.
2. The Exchange Accounts Receivable Files is a system of records consisting of information
collected from potential, past, or authorized Exchange patrons. Disclosure of information is
necessary so the Exchange can take steps to process, monitor, and post audit accounts receivable,
to administer the Federal Claims Collection Act, to answer inquires pertaining thereto, and report
to the consumer reporting agencies as an incentive for debtors to repay delinquent Federal
Government debts. The SSN is used to search for responsive documents relative to such debt.
3. The applicable acceptable uses for collection and use of the SSN are (4) Interactions With
Financial Institutions and (12) Operational Necessity. SSN collected is necessary to open
accounts, locate accounts, and to correspond with financial institutions and places of
employment for the need of garnishing wages, salaries, or to collect credit information. Tax
related issues require the use of the SSN. These uses are consistent with the SSN Instruction Use
Case in Enclosure 2 section 2.c.(4), and (7) of DoDI 1000.30.
4. The Systems of Records (SORNs) associated with the Exchange Accounts Receivable Files is
currently AAFES 0702.34, “Accounts Receivable Files.” Exchange systems are stand-alone
technologies and not part of the Department of Defense Business Information Systems. There is
no DIPTR number to provide. Information maintained within this system is being consolidated
into SORN DoD 00xx, “Patron Authorization, Retail and Services,” and once approved and
published, AAFES 0702.34 will be rescinded.
5. Authorities supporting collection of the SSN are Title 10 U.S.C. §7013. Secretary of the
Army; Title 10 U.S.C. §9013, Secretary of the Air Force; Federal Claims Collection Act of 1966
(Pub.L. 89-508, as amended) and Debt Collection Act of 1982 (Pub.L 97-365, as amended), as
amended by the Debt Collection Improvement Act of 1996 (Pub.L 104-134, section 31001) as

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SUBJECT: Justification for the Use of the Social Security Number (SSN) – Accounts
Receivable Files; Exchange Credit Program.

codified in 31 U.S.C. §3711, Collection and Compromise; 31 CFR 285.11, Administrative Wage
Garnishment; DoD Instruction 1330.21, Armed Services Exchange Regulations; DoD 7000.14R, Department of Defense Management Regulation Volume 13, “Nonappropriated Funds Policy”
and Volume 16 “Department of Defense Debt Management;” Army Regulation 215-8/Air Force
Instruction 34-211(I) Army and Air Force Service Operations; and E.O. 9397 (SSN), as
amended.
6. The Exchange has taken steps to minimize the risk of unauthorized access to information
located in this system of records. Paper and electronic records are maintained in controlled areas
which are accessible only to authorized personnel in controlled facilities. Physical entry is
furtherly restricted by use of locks, guards, and accessible only to authorized personnel. Access
to records is limited to person(s) with an official “need to know” responsible for servicing the
records in performance of their official duties who have been properly screened and cleared for
access. Computerized access is controlled by role-based security and restricted with passwords,
which are changed periodically.
Disclosures of information located within this system is pursuant to those permitted under Title 5
U.S.C. §552a(b) of the Privacy Act of 1974, as amended. This may include disclosures to the
U.S. Department of Justice/U.S. Attorneys for legal action, the Internal Revenue Service to
obtain locator status for delinquent accounts, to private collection agencies for collection actions,
to the Department of the Treasury, Financial Management Service for the purpose of collecting
debts, to any employer for garnishment purposes, and to military banking facilities.
7. My POC is Ms. Teresa Schreurs, Senior Paralegal, Privacy Manager, schreurste@aafes.com,
214-202-5541.

On behalf of:
TROY C. WALLACE
Deputy General Counsel
General Law Branch
Office of the General Counsel