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SECURITY CLEARANCE MANUAL
CHAPTER 1
 
INVESTIGATIONS, ACCESS & CLEARANCES
 
INVESTIGATIONS
In the past there were many different security investigations within DoD. They were known as Background Investigations (BI), Special Background Investigations (SBI), Expanded Background Investigations (EBI), Interview-Oriented Background Investigations (IBI), National Agency Checks (NAC), Expanded National Agency Checks (ENAC), Entrance National Agency Checks (ENTNAC), etc.

Today within DoD and DOE for initial security clearance purposes, there are three investigations—the Single Scope Background Investigation (SSBI), the National Agency Check with Local Agency Checks and Credit Check (NACLC), and the Access National Agency Check and Inquiries (ANACI). There are many other types of investigations conducted by OPM and the few federal agencies authorized to conduct their own investigations. Many of these investigations are primarily for employment purposes, but they may be accept-able for security clearances, if they meet the requirements of an SSBI or NACLC.
 
NATIONAL AGENCY CHECK

The National Agency Check (NAC) is part of all investigations and reinvestigations and is described below:

The scope for a NAC is five years or to age 18, whichever is the shorter period. At a minimum, the first three of the described Agencies (DCII, FBI/HQ, and FBI/ID), below, shall be included in each complete NAC; however, a NAC may also include a check of any or all of the other described Agencies, if appropriate.

1. The DCII database consists of an alphabetical index of personal names and impersonal titles that appear as subjects, co-subjects, victims, or cross-referenced incidental subjects, in investigative documents maintained by DoD criminal, counterintelligence, fraud, and personnel security investigative activities. Additionally, personnel security adjudicative determinations are maintained, by subject, in the DCII. DCII records will be checked on all subjects of DoD investigations.

2. FBI/HQ has on file copies of investigations conducted by the FBI. The FBI/HQ check, included in every NAC, consists of a review of files for information of a security nature and that developed during applicant-type investigations.

3. An FBI/ID check, included in every NAC (but not ENTNAC), is based upon a technical fingerprint search that consists of a classification the subject's fingerprints and comparison with fingerprint cards submitted by law enforcement activities. If the fingerprint card is not classifiable, a "name check only" of these files is auto-matically conducted.

4. OPM. The files of OPM contain the results of investigations conducted by OPM under E.O. 9835 and 10450, those requested by the Nuclear Regulatory Commission (NRC), the Department of Energy (DOE), and those requested since August 1952 to serve as a basis for "Q" clearances. OPM records are checked on all persons who are, or who have been, civilian employees of the U.S. Government; or U.S. citizens who are, or who have been, employed by a United Nations organization or other public international organization; and on those who have been granted security clearances by the NRC or the DOE.

5. Immigration and Naturalization Service (I&NS). The files of I&NS contain (or show where filed) naturalization certificates, certificates of derivative citizenship, all military certificates of naturalization, repatriation files, petitions for naturalization and declaration of intention, visitors' visas, and records of aliens (including government officials and representatives of international organizations) admitted temporarily into the U.S. I&NS records are checked when the subject is:
5.1. An alien in the United States, or
5.2. A naturalized citizen whose naturalization has not been verified, or
5.3. An immigrant alien, or
5.4. A U.S. citizen who receives derivative citizenship through the naturalization of one or both parents, provided that such citizenship has not been verified in a prior investigation.

6. State Department. The State Department maintains the following records:
6.1. Security Division (S/D) files contain information pertinent to matters of security, violations of security, personnel investigations pertinent to that agency, and correspondence files from 1950 to date. These files are checked on all former State Department employees.
6.2. Passport Division (P/D) shall be checked if subject indicates U.S. citizenship due to birth in a foreign country of American parents. This is a check of State Department Embassy files to determine if subject's birth was registered at the U.S. Embassy in the country where he was born. Verification of this registration is verification of citizenship.

7. Central Intelligence Agency (CIA). The CIA maintains the following records:
7.1. Directorate of Operations (CIA-DO/IMS) maintains the Foreign Intelligence/Counterintelligence database. This database shall be checked for all aliens residing outside the United States requiring access to classified information (i.e., LAA ). If the requester provides complete personal identifying information (Complete Name, Date of Birth, Place of Birth, and Citizenship), all alien co-subjects (on SSBIs) residing outside the United States are also checked. In addition, this database shall be queried on the Subject any time there is a counterintelligence concern raised during the conduct of the personnel security investigation.
7.2. Office of Security (CIA-SEC) maintains information on present and former employees, including members of the Office of Strategic Services (OSS), and applicants for employment. These files shall be checked if subject has been an employee of the CIA or when other sources indicate that CIA may have pertinent information.

8. Military Personnel Record Center files are maintained by separate Departments of the Armed Forces, General Services Administration and the Reserve Records Centers. They consist of the Master Personnel Records of retired, separated, Reserve, and active duty members of the Armed Forces. These records shall be checked when the requester provides required identifying data indicating service during the last 5 years.

9. Treasury Department. The files of Treasury Department Agencies (Secret Service, Internal Revenue Service, and Bureau of Customs) will be checked only when available information indicates that an Agency of the Treasury Department may be reasonably expected to have pertinent information.

10. The files of other Agencies, such as the National Guard Bureau, the Defense Industrial Security Clearance Office (DISCO), etc., will be checked when pertinent to the purpose for which the investigation is being conducted.

As of 1 March 2005 (as part of a NAC) OPM requests an Interpol (International Criminal Police Organization) records check through the U.S. National Central Bureau (USNCB) when, for six months or more, the Subject of an investigation: (1) had a non-military foreign residence; (2) had non-military employment overseas; (3) was engaged in academic activities abroad; or (4) when the Subject admits to, or there is developed, criminal activity overseas within the investigative coverage period.

“The following investigative standards are established for all U.S. Government civilian and military personnel, consultants, contractors, employees of contractors, licensees, certificate holder or grantees and their employees and other individuals who require access to classified information, to include Sensitive Compartmented Information (SCI) and Special Access Programs (SAPs), and are to be used by government departments and agencies as the investigative basis for final clearance determinations. However, nothing in these standards prohibits an agency from using any lawful investigative procedures in addition to these requirements in order to resolve any issue identified in the course of a background investigation or reinvestigation.”
 
NATIONAL AGENCY CHECK WITH LOCAL AGENCY CHECKS AND CREDIT CHECK

COMPONENTS OF A NACLC:

Completion of Forms
Completion of Standard Form 86, including applicable releases and supporting documentation.

National Agency Check
Completion of a National Agency Check (on the applicant).
Financial Review
Verification of the subject's financial status, including credit bureau checks covering all locations where the subject has resided, been employed, or attended school for six months or more for the past seven years.
Birth
Corroboration of date and place of birth through a check of appropriate documentation, if not completed in any previous investigation; a check of Bureau of Vital Statistics records when any discrepancy is found to exist.
Local Agency Checks
As a minimum, all investigations will include checks of law enforcement agencies having jurisdiction where the subject has lived, worked, and/or attended school within the last five years, and, if applicable, of the appropriate agency for any identified arrests.
Expanding for Issues
The investigation may be expanded if necessary to determine if access is clearly consistent with the national security.
ACCESS NATIONAL AGENCY CHECK WITH INQUIRIES
The ANACI includes the same components as the NACLC. Additionally, OPM sends inquiry letters to employers, schools, and personal references to confirm the subject’s background and to obtain information about their basic suitability for employment. This investigation is not used for military or contractor personnel. This investigation is used only for new civilian federal employees whose position will require a Secret or “L” clearance. It is a combination of the National Agency Check with Inquiries (NACI) used for federal employment purposes and the NACLC used for security clearance purposes. Civilian federal employees who require a Secret or “L” clearance after they are hired are submitted for a NACLC, since a NACI was previously conducted on them. Because the ANACI is used for a combination of employment and security clearance purposes, and because the security clearance aspects of the ANACI are the same as the NACLC, the ANACI is not addressed separately in this book, except that footnotes are included in the applicable sections to explain any differences between the two investigations. ANACIs are expanded in the same manner and using the same criteria as NACLCs.
 
SINGLE SCOPE BACKGROUND INVESTIGATION

COMPONENTS OF AN SSBI:
Completion of Forms
Completion of Standard Form 86, including applicable releases and supporting documentation.
Scope
Past ten (10) years. If the applicant is under 28 years of age, back to the 18th birthday or two years, whichever is longer.
National Agency Check
Completion of a National Agency Check (on the applicant).
National Agency Check for the Spouse or Cohabitant (if applicable)
Completion of a National Agency Check, without fingerprint cards, for the spouse or cohabitant.
Birth
Corroboration of date and place of birth through a check of appropriate documentation and a check of Bureau of Vital Statistics records when any discrepancy is found to exist.
Citizenship
For individuals born outside the United States, verification of US citizenship directly from the appropriate registration authority; verification of US citizenship or legal status of foreign-born immediate family members (spouse, cohabitant, father, mother, sons, daughters, brothers, sisters).
Education
Corroboration of most recent or most significant claimed attendance, degree, or diploma. Interviews of appropriate educational sources if education is a primary activity of the Subject during the most recent three years.
Employment
Verification of all employments for the past seven years; personal interviews of sources (supervisors, coworkers, or both) for each employment of six months or more; corroboration through records or sources of all periods of unemployment exceeding sixty days; verification of all prior federal and military service, including discharge type. For military members, all service within one branch of the armed forces will be considered as one employment, regardless of assignments.
References
References: four references, of whom at least two are developed; to the extent practicable, all should have social knowledge of the Subject and collectively span at least the last seven years.
Former Spouse
An interview of any former spouse divorced within the last ten years.
Neighborhoods
Confirmation of all residences for the last three years through appropriate interviews with neighbors and through records reviews.
Financial Review
Verification of the Subject's financial status, including credit bureau checks covering all locations where Subject has resided, been employed, and/or attended school for six months or more for the last seven years.
Local Agency Checks
A check of appropriate criminal history records covering all locations where, for the last ten years, the Subject has resided, been employed, and/or attended school for six months or more, including current residence regardless of duration. (NOTE: If no residence, employment or education exceeds six months, local agency checks should be performed as deemed appropriate.)
Public Records
Verification of divorces, bankruptcies, and other court actions, whether civil or criminal, involving the Subject.
Subject Interview
A Subject Interview, conducted by trained security, investigative, or counterintelligence personnel. During the investigation, additional Subject Interviews may be conducted to collect relevant information, to resolve significant inconsistencies, or both. Sworn statements and unsworn declarations may be taken whenever appropriate.
Polygraph (only agencies with approved personnel security polygraph programs):
In departments or agencies with policies sanctioning the use of the polygraph for personnel security purposes, the investigation may include a polygraph examina-tion, conducted by a qualified polygraph examiner.
Expanding the Investigation:
The investigation may be expanded as necessary. As appropriate, interviews with anyone able to provide information or to resolve issues, including but not limited to cohabitants, relatives, psychiatrists, psychologists, other medical professional, and law enforcement professionals may be conducted.
 
PERIODIC REINVESTIGATIONS

INTERVALS AND STANDARDS
Individuals holding security clearances must be reinvestigated periodically to maintain their clearances. Intervals for Periodic Reinvestigations (PR) are:

Confidential Clearance—15 years
Secret & “L” Clearance—10 years
Top Secret & “Q” Clearance—5 years

The investigative standard for PRs for Confidential and Secret clearances is the same as the standard for an initial Confidential or Secret clearance—the NACLC. There are two investigative standards for PRs for Top Secret clearances and for others whose initial investigation was an SSBI. The standards are an SSBI-PR and a Phased Periodic Reinvestigation (PPR).

COMPONENTS OF AN SSBI-PR:
Completion of Forms
Completion of Standard Form 86, including applicable releases and supporting documents.
National Agency Check
Completion of a National Agency Check (fingerprint cards are required only if there has not been a previous valid technical check of the FBI).
National Agency Check for the Spouse or Cohabitant (if applicable)
Completion of a National Agency Check, without fingerprint cards, for the spouse or cohabitant. The National Agency Check for the spouse or cohabitant is not required if already completed in conjunction with a previous investigation or reinvestigation.
Employment
Verification of all employments since the last investigation. Attempts to interview a sufficient number of sources (supervisors, coworkers, or both) at all employments of six months or more. For military members, all service within one branch of the armed forces will be considered as one employment, regardless of assignments.
References
Interviews with two character references who are knowledgeable of the subject; at least one will be a developed reference. To the extent practical, both should have social knowledge of the Subject and collectively span the entire period of the reinvestigation. As appropriate, additional interviews may be conducted, including co-habitants and relatives.
Neighborhoods
Interviews of two neighbors in the vicinity of the subject's most recent residence of six months or more. Confirmation of current residence regardless of length.
Financial Review
(1) Financial Status: Verification of the subject's financial status, including credit bureau checks covering all locations where subject has resided, been employed, and/or attended school for six months or more for the period covered by the reinvestigation;
(2) Check of Treasury's Financial Data Base: Agencies may request the Department of the Treasury, under terms and conditions prescribed by the Secretary of the Treasury, to search automated data bases consisting of reports of currency transactions by financial institutions, international transportation of currency or monetary instruments, foreign bank and financial accounts, and transactions under $10,000 that are reported as possible money laundering violations.
Local Agency Checks
Check of appropriate criminal history records covering locations where, during the period covered by the reinvestigation, the subject has resided, been employed, and/or attended school for six months or more, including current residence regardless of duration. (NOTE: If no residence, employment or education exceeds six months, local agency checks should be performed as deemed appropriate.)
Former Spouse
An interview with any former spouse unless the divorce took place before the date of the last investigation or reinvestigation.
Public Records:
Verification of divorces, bankruptcies and other court actions, whether civil or criminal, involving the Subject since the date of the last investigation.
Subject Interview
A Subject Interview, conducted by trained security, investigative, or counterintelligence personnel. During the reinvestigation, additional Subject Interviews may be conducted to collect relevant information, to resolve significant inconsistencies, or both. Sworn statements and unsworn declarations may be taken whenever appropriate.
Expanding the Reinvestigation
The reinvestigation may be expanded as necessary. As appropriate, interviews with anyone able to provide information or to resolve issues, including but not limited to cohabitants, relatives, psychiatrists, psychologists, other medical professionals, and law enforcement professionals may be conducted.
PHASED PERIODIC REINVESTIGATION (PPR) FOR SSBIs:

“The phased approach to periodic reinvestigations involves conducting a reinvestigation in two phases; a more extensive reinvestigation would be conducted only if potential security issues were identified in the initial phase. Specifically, investigative staff would verify residency records and conduct interviews of listed references, references developed during the investigation, and individuals residing in the neighborhood only if potential security issues were identified in other parts of the standard reinvestigation process. . . . In December 2004, the President approved the use of the phased PR for personnel needing to renew their top secret clearances.”

Essentially Government departments and agencies may, in their discretion, exclude SSBI-PR requirements noted under References and Neighborhoods when no information of security concern is listed on the applicant’s SF86 or is developed during the other aspects of the investigation. If there is information of security concern, the SSBI-PR requirements under References and Neighborhoods must be met as well as the requirement under Expanding the Reinvestigation.

CONDITIONS THAT WOULD REQUIRE A FULL SCOPE SSBI-PR ARE DESCRIBED AS:

Self-Disclosed Security Concerns Requiring Processing of a Full Scope SSBI-PR
A positive response by the subject, or subject-provided information related to the following questions on the Standard Form 86, Questionnaire for National Security Positions, may indicate a security concern. A positive response to any of the following questions will result in investigations submitted as a PPR (case type 19) to be scheduled as a full scope SSBI-PR (case type 18) and billed accordingly.

SF 86 Question Response
8a Citizenship “I am not a U.S. Citizen” checked
8d Dual Citizenship Checked
17 Your Foreign Activities A positive response to questions b, c, or d.
21 Your Medical Record A positive response
23 Your Police Record A positive response to questions a, b, c, d, e, or f
24 Your Use Of Illegal Drugs
And Drug Activity A positive response to questions a, b, or c
25 Your Use Of Alcohol A positive response
26 Your Investigations Record A positive response to question b
30 Your Association Record A positive response to questions a or b

Developed Security Concerns Requiring Processing of an Expanded PPR
If certain issues are developed during the conduct of the field-work portion of any PPR, OPM will automatically expand the investigation to include reference, residence and education coverage. The cost to expand a PPR once the investigation has begun is in addition to the basic PPR cost, and the additional charge will be billed at the time the investigation is expanded. The following issues, when developed during the course of the investigation, will result in expansion and applied surcharge:

 Evidence that the Subject is not a U.S. citizen, or has renounced or otherwise lost his U.S. citizenship since the time of the last investigation;

 Evidence that the Subject is a dual citizen or has obtained dual citizenship since the time of the last investigation;

 Evidence that the Subject has been employed by or acted as a consultant for any foreign government, firm or agency; that the Subject has engaged in any contact with a foreign government or its establishments or representatives on other than official U.S. government business; that the Subject holds or has been issued a foreign passport;

 Evidence that the Subject has undergone mental health treatment (except marital, family or grief counseling, not related to violence by the Subject) since the last investigation, whether this treatment began before or after the last investigation;

 Evidence that the Subject has been charged with or convicted of any criminal offenses (excluding traffic violations resulting in fines less than $150) since the last investigation;

 Evidence that the Subject used any drugs (illegally) since the last investigation;

 Evidence that the Subject has abused alcohol or has received any alcohol-related treatment or counseling since the last investigation;

 Evidence that the Subject has had a clearance or access authorization denied, suspended or revoked, or has been debarred from Federal employment since the last investigation; and

 Evidence that the Subject has associated with any individuals or groups dedicated to the violent overthrow of the United States government or that the Subject has acted to do so.

For the most part all federal background investigations contain some or all of the components (sources) listed under the three investigative standards (four if you count the PPR separately) described above. For security clearance investigations the information collected from these sources should be directly related to the Adjudicative Guidelines. Investigations conducted for employment purposes and for a combination of employment and security clearance purposes use basically some or all of the same investigative sources. However, differences exist in the nature of the information collected, because the criteria for employment is often different than the criteria for granting security clearances.

Table 1 (below) was extracted from GAO Report 06-1070, September 2006 and presents a comparison of the NACLC, SSBI and SSBI-PR.


Table 1: Information Gathered in an Investigation to Determine Eligibility for a Security Clearance

                                                                 Type of security clearance and investigation

                                                                                        Confidential/Secret                     Top Secret

                                                                                                                Initial investigation                Initial                  Reinves-
Type of information gathered                                                         & reinvestigation                    investigation    tigation

1. Personnel security questionnaire: The subject’s self-                                   X                                          X                          X
reported answers on a paper SF-86 form or electronic form

2. National agency check: Data from Federal Bureau of                                  X                                          X                          X
Investigation, military records, and other agencies as required

3. Credit check: Data from credit bureaus where the                                       X                                           X                           X
subject lived/worked/attended school for at least 6 months

4. Local agency checks: Data from law enforcement                                       X                                           X                           X
agencies where the subject lived/worked/attended school
during the past 10 year or—in the case of reinvestigations—
since the last security clearance investigation

5. Date and place of birth: Corroboration of information                                 X                                            X
supplied on the personnel security questionnaire

6. Citizenship: For individuals born outside of the United                                                                              X
States verification of U.S. citizenship directly from the
appropriate registration authority

7. Education: Verification of most recent or significant                                                                                  X                            X
claimed attendance, degree, or diploma

8. Employment: Review of employment records and                                                                                     X                            X
interviews with workplace references, such as supervisors
and coworkers

9. References: Data from interviews with subject                                                                                          X                             X
identified and investigator-developed leads

10. National agency check for spouse or cohabitant:                                                                                   X                              X
National agency check without fingerprints

11. Former spouse: Data from interview(s) conducted                                                                                X                               X
with spouse(s) divorced within the last 10 years or since
the last investigation or reinvestigation

12. Neighborhoods: Interviews with neighbors and                                                                                      X                                X
verification of residence through records check

13. Public Records: Verification of issues, such as                                                                                     X                                X
bankruptcy, divorce, and criminal and civil court cases

14. Subject interview: Collection of relevant data,                                                                                       X                                 X
resolution of significant inconsistencies, or both

Source DOD and OPM
FINAL AND INTERIM SECURITY CLEARANCES

The SSBI is required for final Top Secret clearance and “Q” clearances and for access to SCI and designated SAPs at any classification level. The NACLC is required for final “L” clearances, Confidential clearances, and Secret clearances, not involving access to SCI or designated SAPs.

An Interim Security clearance is based on the completion of minimum investigative requirements. It is granted on a temporary basis, pending the completion of the full investigative requirements.
An Interim Top Secret clearance may be granted on the basis of a favorable NAC, a favorable review of the applicant’s SF-86, a favorable review of local personnel, base/military police, medical, and other security records as appropriate, and the submission of a request for an SSBI.
An Interim Secret clearance may be granted on the basis of a favorable review of the applicant’s SF86, a favorable review of local personnel, base military police, medical, and security records as appropriate, and the submission of a request for a NACLC.
CLEARANCE TERMINATION, DOWNGRADE & REINSTATMENT
A security clearance remains in force until the individual granted the clearance leaves the position for which the clearance was needed. If they remain with the same employer in a position that doesn’t require a clearance, their clearance is administratively downgraded or withdrawn. In this case, the clearance can be administratively upgraded or reinstated provided the underlying investigation is not out of date. If they terminate their employment, their clearance is terminated. If they are again hired into a position that requires the same or lower level clearance, the clearance can be reinstated provided two years have not elapsed since the clearance was terminated and the underlying investigation is not out of date.

When an individual has had a break in service (i.e. terminated employment where they held a security clearance and subsequently hired for a job that requires a security clearance), there are time limits during which a clearance can be reinstated without an investigation. Any break in service of 24 months or more requires a new initial investigation regardless of the date of the last investigation. If there is a break in service of less than 24 months and the time since the last investigation is not greater than the interval specified for the periodic reinvestigation, the clearance can be reinstated without an investigation. When hired for a position requiring a security clearance of a lower level than previously held, the interval for the lower level clearance applies. Under certain circumstances a person with a break in service of less than 24 months whose prior investigation for a Top Secret or Q clearance occurred more than five years ago, may only have to have an SSBI-PR. In any event the applicant may be required to submit a new SF86, even if a new investigation is not required.
CLEARANCES VERSUS ACCESS

Within DoD there are only three levels of classified material and three clearances—Confidential, Secret, and Top Secret. The Department of Energy (DOE) basically has two levels of security clearances—“Q” clearances and “L” clearances. “L” clearances are comparable to DoD Confidential and Secret clearances, and “Q” clearances are comparable to DoD Top Secret clearances.

Access to classified information is based on having the appropriate security clearance (Confidential, Secret or Top Secret) and a “need to know.” This need-to-know can be either a formal or informal determination. Generally all classified information exists within one of these two “need-to-know” realms. Information that falls into the realm of informal need-to-know determinations is often referred to as “Collateral Classified” information or “GENSER” for general service message traffic. Information that falls into the realm requiring formal access authorizations (just another term for need-to-know) is controlled within Special Access Programs (SAP) and Sensitive Compartmented Information (SCI). Access to SCI is regulated by the Central Intelligence Agency (CIA) under Director of Central Intelligence Directive (DCID) 6/4.

Acronyms such as SAP, SCI, CNWDI (Critical Nuclear Weapons Design Information), SIOP-ESI (Single Integrated Operations Plan—Exceptionally Sensitive Information), RD (Restricted Data), FRD (Formerly Restricted Data), ATOMAL (NATO Atomic Material), COSMIC Top Secret, SPECAT, CRYPTO, COMSEC, etc., are not clearances. They refer to categories of classified information, some of which involve extra need-to-know restrictions or special access authorizations. For instance, the term COSMIC stands for “Control of Secret Material in an International Command.” COSMIC Top Secret is merely the term used for NATO Top Secret Information. There are many caveats stamped or printed on classified documents with exotic sounding words, but most are only acronyms or short titles for special administrative handling procedures.