Will ‘Outside Activities’ Lead to Security Review?

  • Guideline A: Allegiance to the United States
  • Guideline E: Personal Conduct
  • Guideline G: Alcohol Consumption
  • Guideline H: Drug Involvement and Substance Misuse
  • Guideline J: Criminal Conduct
  • Guideline K: Handling Protected Information
  • Guideline L: Outside Activities
  • Guideline M: Use of Information Technology Systems

Published: March 8, 2022

Not all security clearance concerns are equal. When a large volume of agency Statement of Reasons passes through your office, you begin to recognize trends. Guideline E, Personal Conduct and Guideline J, Criminal Conduct are the jokers of the card deck, often added to underscore character issues and augment guidelines of greater subject-matter specificity. Guideline A, Allegiance to the United States is rarely invoked but has seen a revival following the January 6th attack on the Capitol. The prevalence of bad debt and drug use among Americans broadly makes Guidelines F, Financial Considerations and Guideline H, Drug Use very common in security reviews. Some guidelines show class or generational distinctions. Guideline G, Alcohol Consumption tends to affect older and lower-ranking Federal employees, reflecting possible generational and class differences on drinking. Conversely, Guideline M, Misuse of Information Systems tends to entrap younger employees, as older Feds struggle to access copyrighted material, let alone download the same.

Then there are the two very specific guidelines, Guideline K, Mishandling of Protected Information and Guideline L, Outside Activities. Of the 180 or so Statement of Reasons responses authored by one of this article’s authors, Daniel Meyer, since 2018, only one contained a Guideline L, Outside Activities concern. Mr. Meyer has advised many more employees on reporting Guideline L issues under Security Executive Agent Directive (SEAD) 3. But actual Guideline L Statement of Reasons are rare. Guideline K, Mishandling Protected Information is more common, arising in about seven of Mr. Meyer’s cases since 2018. That makes Outside Activities the second rarest guideline to appear in Statement of Reasons; system-wide throughout the Executive branch, the category ranks right behind Allegiance to the United States.

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