The personnel security clearances (PCL) are granted after a lengthy investigation and adjudication process. The interim clearance can be granted within a few weeks and the final decision can take many months. This security clearance journey begins with the applicant completing the Questionnaire for National Security Positions, also known as Standard Form (SF-86). This is a lengthy form that requires the population of some very personal information to include family members, places lived, academic institutes attended, arrests, drug and alcohol incidents, debt, and more.

FSOs: The First to review your sf-86

The form is completed online and once complete, the applicant should review the form with the Facility Security Officer (FSO). The FSO is the first person to review all the sensitive information with the applicant. The FSO ensures the form is complete, accurate, and all waivers and signatures are applied. FSOs are not decisions makers in the security clearance process and therefore not authorized to pass judgement, make adjudicative calls, or decisions about the clearance request – they are simply reviewing for completeness.

Agency Employees are next

Employees of agencies within the security clearance process will then have access to the SF-86 and are required to handle the information in accordance with their responsibilities and according to the Privacy Act. These employees will access the SF-86 while conducting background investigations, reinvestigations, and continuous evaluations of persons under consideration for, or retention of, national security positions. These also include non-investigating employees conducting administration functions. These include contractor and government personnel security clearance employees, investigators, adjudicators and others who have authorization to conduct legitimate business.

Many others may view redacted data

Additionally the investigation conducted using information on the SF-86 can be used in studies and analyses to evaluate an agency’s effectiveness in applying investigative and adjudicative methodologies. Think about process improvement or reports to congress on government effectiveness.

According to the form itself: “The collection, maintenance, and disclosure of background investigative information are governed by the Privacy Act…. The information you provide on this form, and information collected during an investigation, may be disclosed without your consent by an agency maintaining the information in a system of records as permitted by the Privacy Act…”

The idea is that the data may be aggregated and used for other means – but that one individual’s data cannot be released, and their privacy violated. Because the Privacy Act governs the data on the security clearance questionnaire, even security clearance applicants themselves have to use the Privacy Act to obtain a copy of their report.

The following are those who might view the SF-86 in its entirety:

  • Department of Justice in performing their duties
  • Courts if litigation is involved for civil or criminal violations
  • Employees performing security clearance investigations

The following are those who might view information that is on the SF-86, but will not be able to associate the information with an individual:

  • Federal state local foreign tribal or other public authority as appropriate
  • Contractors, grantees, experts, consultants or volunteers as they cooperate in the investigation
  • News media or general public for factual information, but not PII
  • Congress, national archives, foreign governments, office of management and budget

do I have to allow my data to be released?

Providing information is voluntary, but failure to complete the form will result in disqualification of the process. Since the form is the trigger, the starting gun is never fired and the runners never get off the starting line. If an SF-86 is not completed, the process is never started. Also, if an applicant does not provide all of the requested information it could negatively affect their eligibility for a national security position or access to classified information.

So, the answer to “Who can view my SF-86?” is: only those performing investigations and their support staff. Perhaps law enforcement and courts may view pertinent information during legal proceedings. While many individuals today are pushing for more oversight into the security clearance process, or even the right to view the SF-86 information provided by White House officials, it’s important to remember the privacy protections afforded in the White House also apply to the roughly four million ‘average’ security clearance holders.

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Jeffrey W. Bennett is a security consultant with SFPC, SAPPC, ISOC, ISP certifications. He maintains a security blog and newsletter and is the author of many security books including DoD Security Clearance and Contracts Guidebook-What Cleared Contractors Need to Know About Their Need to Know, The Insider’s Guide to Security Clearances, and books on security certification. Visit his website www.redbikepublishing.com for more information.