Monday, October 13, 2014

Does a secret security clearance fulfill the requirements of a public trust clearance?

As published in

Recently, a reader asked the following question: “If I have a current secret clearance, does that fulfill the requirements of the “public trust” clearance?” Before we answer the question, let’s look at public trust as a whole.

It depends. The security clearance process is part of the Public Trust evaluation. According to Standard Form (SF) 86 and SF 85 instructions and DSS publications some public trust positions require security clearances and some do not. So, the answer depends on the level of the public trust required. If a desired public trust requirement is for a low to moderate risk position or requires a clearance of SECRET or CONFIDENTIAL, then yes, the request for the SECRET clearance (SF 86) adjudication should cover the requirements and the applicant should not have to complete a new SF 85 or 85P. If the public trust position requires a higher security clearance, then the applicant would undergo another investigation and adjudication to cover the requirements of the higher clearance level.

A position of public trust is evaluated to determine the type of impact on the organization based on the sensitivity of the position and the risk of information the employee of the position might work with or otherwise possess. These positions are designated by an authorized manager based on low, medium or high risk.

Sometimes people mistakenly think that public trust and security clearances are two separate events or positions and the terms are often wrongly switched up. Though there are two different processes, both are under the same designation. The mistake is in thinking that there are two categories of clearances with public trust and security clearance topics. However, the term public trust encompasses both classified and unclassified position needs.

Understanding the risk level is fundamental to comprehend the public trust requirements. The public trust positions are designated according to amount of risk assumed.
  • Low risk public trust positions are for duties that have limited potential impact on the organization or mission.
  • Moderate risk public trust positions are designated for those positions with potentially moderate to serious impact on the organization or mission.
  • High risk public trust positions are for positions with exceptionally serious impact on the integrity or efficiency of the mission.


Public trust position investigations are conducted by the Office of Personnel Management (OPM). If a position is designated as being low, moderate or high risk, OPM investigates the employee for suitability to the level of risk. The higher the public trust position risk, the more detailed the investigation.

The process begins with the justification of the position. The authorized manager has already determined this when the position is created. Each employee that fills that position must have had an investigation or will have an investigation to qualify them for the level of public trust required. Once notified by an authorized person, the next step is for the employee to complete the correct Standard Form (SF).

There are different types of adjudications for public trust positions and each type of adjudication requires a different form. The SF 85 is the correct form for the low risk, the SF 85 or SF 85P for the moderate risk, and the SF 86 is for security clearances and high risk public trust positions. Each SF provides a basis of information used for the appropriate investigation for suitability of public trust. Whichever SF is used the applicant should accurately and completely fill each of the fields asking for form unique information. OPM investigators use the completed forms to research the subject and gather information necessary for the adjudicator to make a suitability determination.

Keep this in mind, compromise of SECRET information could cause serious and compromise of TOP SECRET information could cause extremely grave damage to national security. Does this determination sound familiar? The levels of damage described matches key words in the moderate and high risk definitions quoted earlier. Both complement each other and describe levels of risk and impact.

Not all sensitive duties require access to classified information. However, those employees requiring a security clearance fill out the SF that leads to more in-depth and appropriate investigation. For security clearances, it is the SF 86. This is an important distinction as the moderate risk public trust position normally requires the SF 85P. However, when a security clearance is required, the SF 86 is always used. The bottom line is that regardless of the risk level, when the National Security Adjudications grant access to all classification levels; TOP SECRET, SECRET, or CONFIDENTIAL, an SF 86 is required.

For example, if an employee is hired against a moderate risk position that requires a SECRET security clearance, the SF 86 investigation is more detailed and will fulfill all moderate risk adjudication information required of the SF 85P. In other words, the more in-depth investigation requirement will cover all lower level investigation requirements. The applicant will not need to complete both forms.

If an employee is transferred, there is a degree of technical difficulty. When occupying a position of moderate risk where no clearance is required, the employee completed an SF 85P. If the same employee is transferred to a similar position and a SECRET clearance is required, they will have to complete an additional SF86 and undergo a different investigation. If, on the other hand, they transfer from a moderate risk position requiring a security clearance to a moderate risk position not requiring a clearance, the original SF 86 will suffice.

So, back to the original question, “Does a secret security clearance fulfill the requirements of a public trust clearance?” The answer is yes. A SECRET clearance is designated as part of the public trust process. The holder of the SECRET clearance is in a position of moderate risk and they require a security clearance. In this case an SF 86 investigation and security clearance adjudication will cover the requirements of the moderate to low risk positions.

Jeffrey W. Bennett, ISP is the owner of Red Bike Publishing Red Bike Publishing . He regularly consults, presents security training, and recommends export compliance and intellectual property protection countermeasures. He is an accomplished writer of non-fiction books, novels and periodicals. Jeff is an expert in security and has written many security books including: "Insider's Guide to Security Clearances" and "DoD Security Clearances and Contracts Guidebook", "ISP Certification-The Industrial Security Professional Exam Manual", and NISPOM/FSO Training".

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