SSN Justification Memorandum

DEFENSE FINANCE AND ACCOUNTING SERVICE
8899 east 56th street
Indianapolis, in 46249-0201

April 18, 2018
MEMORANDUM THROUGH RECORDS, PRIVACY, AND DECLASSIFICATION
DIVISION
FOR: Defense, Privacy, Civil Liberties, and Transparency Division

signed by
SHORT.MARY. Digitally
SHORT.MARY.V.1229496880
Date: 2018.05.03 11:36:26
V.1229496880 -04'00'

SUBJECT: Justification for Use of Social Security Number (SSN) – Department of Defense
(DoD) (DD) Form 2761, Personal Check Cashing Agreement
This memorandum is written to satisfy the requirement established in the DoD Instruction
1000.30, “Reduction of Social Security Number (SSN) Use Within DoD” that requires
justification of the collection and use of the SSN on DD Form 2761.
1. The DD Form 2761 is one of the required agreements entered into with the Disbursing
Office (DO) by eligible individuals for the privilege of cashing personal checks. The
agreement authorizes the DO to immediately check the individuals pay account for the
amount of the check, if it is returned from the bank because of insufficient funds. The
DD 2761 is initiated and completed by the applicant at the appropriate disbursing office.
The disbursing office uses this form to determine the eligibility of the applicant. The
completed form is used by the disbursing office to later collect any indebtedness from the
applicant’s pay account. The paper forms and copies are secured to protect Personally
Identifiable Information in accordance with DoD regulations. Records are stored in
office buildings protected by guards, controlled screening, use of visitor registers,
electronic access, and/or locks. Access to records is limited to individuals who are
properly screened and cleared on a need-to-know basis in the performance of their
official duties.
2. As required in DoDI 1000.30, the acceptable use for the SSN has been identified as
2c.(11) Legacy System Interface. The SSN of the eligible individuals is still used in
various legacy pay systems that interface with disbursing systems. This data is required
for possible collection of indebtedness due to dishonored checks from the individual’s
pay account. The SSN cannot be truncated without the risk of misidentifying the
individual, nor can it be masked since the form is used in a paper format. If the
Department of Defense did not collect the SSN from the individual, there is a risk that
any possible collection action could not be made as required by Public Law 104-134,
Debt Collection and Improvement Act of 1996; 5 U.S.C. Section 5514, Installment
deduction for indebtedness to the United States; and 37 U.S.C. 1007, Deductions from
pay.

3. The information collected on this form is covered under the Privacy Act System of
Records Notices:
T7340, Defense Joint Military Pay System – Active Component, DITPR #92,
(http://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-ArticleView/Article/570191/t7340/);
T7344, Defense Joint Military Pay System – Reserve Component, DITPR #244,
(http://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-ArticleView/Article/570195/t7344/);
T7347b, Defense Military Retiree and Annuity Pay System Records, DITPR# 98,
(http://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-ArticleView/Article/570196/t7347b/); and
M01040-3, Marine Corps Manpower Management Information System Records,
DITPR#113 (http://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-ArticleView/Article/570625/m01040-3/).
4. The SSN will no longer be needed on the DD Form 2761 when an alternate method of
identification is initiated. Once this is accomplished, pay systems will be modified to
recognize the alternate method of identification.
If you have any questions, my point of contact is Mr. Thomas McKenna, and he can be
reached at telephone (216) 204-1679.

KEITH.BRUCE.
NEAL.1185564
700

Digitally signed by
KEITH.BRUCE.NEAL.1185
564700
Date: 2018.05.03
13:46:42 -04'00'

Bruce N. Keith
Director, Finance Standards & Customer Services