SSN Justification Memo Submission

DEPARTMENT OF DEFENSE
DEFENSE HUMAN RESOURCES ACTIVITY
DEFENSE MANPOWER DATA CENTER
4800 MARK CENTER DRIVE, SUITE 04E25-01
ALEXANDRIA, VA 22350-6000

MEMORANDUM FOR OFFICE OF THE ASSISTANT SECRETARY OF DEFENSE FOR
PRIVACY, CIVIL LIBERTIES, AND TRANSPARENCY
THROUGH: DEFENSE MANPOWER DATA CENTER PRIVACY OFFICE

PETERSON.SAM
UEL.MARKEE.128
8769903

Digitally signed by
PETERSON.SAMUEL.MARKE
E.1288769903
Date: 2024.05.02 14:55:27
-07'00'

SUBJECT: Justification for the Use of Social Security Numbers - Defense Sexual Assault
Incident Database Department of Defense Information Technology Portfolio
Repository Identification Number 11499
This memorandum is to satisfy the requirements of the Department of Defense
Instruction (DoDI) 1000.30, “Reduction of Social Security Number (SSN) Use Within DoD,”
that requires justification of the collection and use of the Social Security Number in the Defense
Sexual Assault Incident Database (DSAID).
Public Law 110-417, the Duncan Hunter National Defense Authorization Act (NDAA)
for Fiscal Year (FY) 2009, required that the DoD develop a centralized, case-level database for
the collection and maintenance of information regarding sexual assaults involving a member of
the Armed Forces. To fulfill this requirement, as well as the reporting requirements outlined in
10 United States Code (U.S.C.) 113 note, “DoD Policy and Procedures on Prevention and
Response to Sexual Assaults Involving Members of the Armed Forces,” the Department
developed and deployed DSAID. As the system of record for the Annual Report to Congress on
Sexual Assault in the Military, DSAID maintains information (if available) about the nature of
the assault, the victim, the alleged offender, investigative information, and case outcomes in
connection with the assault. Under 10 U.S.C. 932, DSAID is also required to include
information on the claims of retaliation connected with an Unrestricted Report of sexual assault
made by or against a member of the Armed Forces. Additionally, DSAID will now maintain
data on assaults committed by a member of the Armed Forces against the member’s spouse or
other family member, per Section 538 of Public Law 115-91, NDAA for FY 2018.
As documented in the DSAID System of Records Notice (DHRA 06) and Privacy
Impact Assessment, the SSN is collected and maintained in DSAID from victims and/or alleged
perpetrators in a sexual assault as part of an Unrestricted Report (reports that trigger an
investigation). The SSN may also be collected from retaliation reporters when there is claims of
retaliation in connection with an Unrestricted Report of sexual assault made by or against a
member of the Armed Forces. This information is collected, as appropriate, via the DD Form
2965 (DSAID Data Form), DD Form 2910 (Victim Reporting Preference Statement), DD Form
2910-1 (Replacement of Lost DD Form 2910, Victim Reporting Preference Statement), and DD
Form 2910-2 (Retaliation Victim Reporting Preference Statement) and utilized by Sexual
Assault Response Coordinators for case creation and entry.

DD Form 2910 series, including 2910, 2910-1, and 2910-2, are stored in DSAID in
their entirety, within the DSAID File Locker. The DSAID File Locker provides a central and
secure record retention capability to ensure compliance with federal requirements and allow
victims, retaliation reporters, and Catch A Serial Offender “CATCH” participants to access
these forms for potential use to include accessing Department of Veterans Affairs benefits
applications and the identification of serial sexual assault offenders. The DD Forms 2910, 29101 and 2910-2 for Unrestricted Reports are maintained in a searchable format, whereas statements
for the Restricted Reports are maintained in a non-searchable format and can only be accessed
with an encryption key. The last four of the SSN, date of birth, mother's maiden name, and state
or country of birth may be maintained as an encryption key to grant victims access to their
Restricted Report records.
The use case justifying the collection of the SSN in DSAID is “Legacy System Interface”
as outlined in DoDI 1000.30, Enclosure 2, paragraph 2c (11). DSAID must interface weekly
with the Department of the Army Law Enforcement Reporting and Tracking System, the
Department of the Navy Consolidated Law Enforcement Operations Center, and the Department
of the Air Force Investigative Information Management System to capture case investigation
data required for congressional reporting. These legacy systems report and track individuals, and
make application information available to other agencies through the use of the SSN. DSAID
must, therefore, continue to collect the SSN to allow for data matching and verification to be
conducted to ensure the correct sexual assault case information is being pushed from the Military
Criminal Investigative Organizations (MCIO) systems to DSAID. Once the legacy MCIO
systems transition from the use of the SSN to another primary form of identification (e.g. the
DoD Identification Number), DSAID will also transition from the use of the SSN. This office, in
coordination with the DSAID Change Control Board, will continue to assess options for removal
of the SSN as they become available.
The data collected is covered by the System of Records Notice DHRA 06 DoD,
“Defense Sexual Assault Incident Database (DSAID),” which provides the authorities to
collect, and is available at: DHRA-06-DoD.pdf (defense.gov).
The Defense Human Resource Activity (DHRA) remains committed to continuously
monitoring and evaluating the DSAID program and safeguarding the privacy of individuals
whose information is contained in the system, in accordance with the Privacy Act of 1974 and
DoD 5400.11-R, “Department of Defense Privacy Program”. My point of contact for this
matter is the DHRA Component Privacy Officer, Mr. Samuel Peterson, (571) 438-1951,
samuel.m.peterson2.civ@mail.mil.

YOUSEFZADEH.
SAM.1299285614

Digitally signed by
YOUSEFZADEH.SAM.12992856
14
Date: 2024.05.01 09:14:58 -04'00'

Sam Yousefzadeh
Director

2