Originally Posted by goalie

Hare splitting time....

Yes, you are 100% correct that the procedure itself is SSI and rightly so. The form itself otoh, "flies" both ways.....

Blank form: If given to a pax to complete is not and cannot be considered SSI as the form not only is blank and contains no information but once a document which is considered (n.b. considered) SSI is given to someone without the proper clearance, SSI for lack of a better term, flies out the window,

Completed form: While still in the possession of the pax, the form is not considered SSI as the sensitive security information (in this case the personal information of the pax) is still in the possession of the pax. Once the completed form has either been turned over to a TSO or sent directly to the TSA, it is then considered SSI as the TSA is duty bound by regulations to protect the information contained on the form. This is no different than a bank employee handing you a blank signature card to be completed in order to open an account. The signature card, like "the form" is part of a confidential bank process to open an account (where the bank must comply with all applicable federal regulations in order to open the account [credit checks, background checks and etc]) but the blank signature card itself is not confidential as it is given to the customer to complete just like "the form". Once the customer returns the completed signature card to the bank, the bank, just like the TSA, is duty bound by regulations to protect the privacy (and dare I say secrecy) of the information.