Justification For The Use Of The SSN
By DON CIO Privacy Team - Published, October 5, 2012
Phase II of the Department of the Navy Social Security Number (SSN) Reduction Plan addressed a review of information technology systems that collect the SSN. The purpose of the review was to assess whether continued collection was required, whether collection could cease (i.e., elimination of the SSN), or whether the SSN could be substituted with another unique identifier (i.e., the DoD ID number).
In the case where continued collection was required a written justification signed by a Flag, SES, or individual given by direction signature authority was required. The attached template was provided to be used for providing this justification. The justification template can also be found in the Reference Documents (Ref Doc) section under the References tab in DITPR DON.
This review is an ongoing process and must also be applied to all new systems. The justification memo should be submitted with the new system's initial privacy impact assessment (PIA).
PIAs are reviewed and resigned every three years in conjuction with the Certification and Accreditation process and/or when there has been a significant change to the system. Each time a PIA is submitted to the DON CIO for final review and approval, a new memo should also be submitted verifying that the continued collection is necessary.
Once the justification memo has been signed it is stored in DITPR DON under the Documents (Doc) section and the Other (Optional) tab for the individual system.
DITPR DON questions should also be reviewed and updated as necessary to ensure consistency between all documents.