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Home + DISCO + Notice to Contractors Regarding Retention of Standard Forms 86

Notice to Contractors Regarding Retention of Standard Forms 86

In paragraph 2-202b, the February 2006 version of the NISPOM provides new policy and procedures for completing, retaining and ultimately destroying the retained copy of the SF-86. The purpose of the new guidance is to reduce the reject rate for the electronic version of the SF-86 while ensuring that the forms are retained only as long as the contractor has a legitimate purpose for retaining the form.

This policy requires the contractor to retain an original, signed copy of the SF-86 and releases until the clearance process has been completed, and requires that the retained SF-86 and associated documentation be destroyed when a final determination of the employee's eligibility for access to classified information has been made.

However, because the SF-86 is reviewed as part of Special Access Program (SAP) access determinations, members of the SAP community have expressed concern about the premature destruction of the SF-86. Please note that in accordance with paragraph 2-202b of the February 2006 version of the NISPOM, contractors are authorized to retain the most current SF-86 for employees who have been nominated to perform on contracts requiring access to SAP information, for employees who have been approved for accessto SAP informationfor as long as their access remains active, and for employees who the contractor has good reason to believe will be nominated for SAP access within one year of having completed the SF-86. SF-86 forms retained purely for potential SAP access purposes should be placed in a sealed envelope with the notation "To be opened only for a SAP access determination" and secured in a location under the control of designated security personnel. The employee should also be informed that the facility is retaining a copy of the employee's SF-86 for purposes related to prospective SAP access.

Given that more than six months have elapsed since the publication of the current NISPOM, all contractors should now have a process in place to ensure that the SF-86 is destroyed as soon as a final determination of the employee's eligibility for access to classified information has been made, unless the employee is likely to require SAP access.However, given the volume of retained SF-86's in many contractor facilities, some of which have been accumulated over several years, we do not expect that all copies have already been destroyed. Nonetheless, every contractor with a large number of retained SF-86's should have a plan and be making a good faith effort to complete the destruction within a reasonable period of time.

While the contractor is no longer permitted to retain copies of the SF-86 when the employee's access has been granted or denied, the employee is certainly permitted to retain a copy of his or her own SF-86 for personal reasons. It is also entirely appropriate for contractors to encourage their employees to retain their own copies of completed SF-86 forms. One method of disposition that the contractor may employ is to remove the copy of the SF-86 from the security file and hand it over the employee, provided the employee is willing to accept the form. Otherwise, the SF-86's should be destroyed following the same method that the contractor employs for other material in their possession that contains sensitive, personal identifying information.