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Scroll Responsibly: The Realities of Using TikTok as a Cleared Professional
Having TikTok on a government or federal contractor’s device has been banned since 2023, but recent executive orders and headlines about the platform raise fresh questions about using TikTok as a cleared professional.
What’s changed, if anything, for security clearance holders? Should cleared professionals approach platforms like TikTok, LinkedIn, or even retail apps differently?
We sat down with Dan Meyer, Esq., a Partner at Tully Rinckey PLLC’s Washington, D.C. office, to explore what the evolving landscape of social media means for the cleared community. Dan brings over 25 years of expertise in Federal Employment and National Security law, offering valuable insights for cleared professionals navigating the digital world. Here’s a taste of what we cover below with Dan:
- Why does TikTok pose a security concern? Learn about the platform’s data collection risks and how they’ve raised alarms in national security circles.
- Can individuals with security clearances use TikTok on personal devices? Explore agency-specific policies and the implications of using TikTok as a cleared professional.
- Recommendations for using TikTok as a cleared professional. Should you delete the app entirely, or does it depend on your security-cleared career path?
- Are commercial platforms safe? Understand broader concerns with foreign-based retail apps and the security implications.
- How to stay informed and compliant. Proactive steps to align your social media use with the government’s expectations for clearance holders.
- Should you display your clearance on LinkedIn? The risks of publicizing sensitive credentials.
Why does TikTok pose a security concern?
A few years back, concerns were voiced by various federal agencies that TikTok was able to collect a lot of data on individual users. While one person’s data might not be all that important for national security purposes, when you combine the data of 170 million people, that becomes a rich pot for Chinese intelligence to try to get classified information from the United States. The fact that this data sits on servers in the People’s Republic of China and is available for the government’s use became Congress’s big concern.
As TikTok developed to be such a large platform, it scared everybody in Washington. They’ve seen instances of how information warfare has been deployed through federal employees. Now, the thought is this could be done nationwide through 170 million subscribers.
The transfer of technology between borders has been a security problem in the past. It’s only going to get worse because we’re now going to have aggregated data from our washing machines to refrigerators and cars. We’re going to have to figure out how to live in a global world where people may be using commercial platforms for things other than commercial activity.
If TikTok continues to be available to US citizens, can cleared professionals use it on personal devices that are not used in the performance of federal contracts?
Even if you’re using a platform like TikTok on a personal device, it’s an agency-by-agency issue. Ten years ago, if you were at the DoD, EPA, or AG, you could use any social media. But if you were at the NSA, CIA, or even FBI, it was very rare for an employee to be on social media, because you had to report it.
For example, over at the CIA, you could be on Facebook theoretically. But anybody who’s a foreign national on your Facebook account, or who likes your Facebook posting, would then have to be put into the database as a foreign contact. So the general tradition has been for certain categories of federal employees to not go into the social media pond.
But that started changing about five or six years ago. I started getting clients who had social media accounts at NSA that I never would have thought would. So I think the agencies understand these social media platforms have become very important in the same way that cell phones became important.
When cell phones first arrived, the assumption was that people of means would have cell phones. Then, all of a sudden, people realized that everybody was going to have them. That became a problem for a lot of people. I remember discussions with friends who thought it was odd that people of little means would have a cell phone before they secured a house or car. They didn’t realize how liberating that technology would be. You could even bank on a cell phone.
So TikTok does the same thing. It allows people to do things they wouldn’t be able to do otherwise. Once the agencies understood that, they started to let their employees use those platforms on their own time. But it has created a really difficult security problem, because you have to be savvy to not offend security protocols.
What’s your recommendation for clearance holders considering to use TikTok?
My recommendation is harsh because the challenge for the cleared workforce is that they may not stay at the same agency. Your company may have you on a contract with NSA, and suddenly, they say, wow, we can make more money off of you if you’re over at Langley.
In that case, you’ve potentially set up everything for the way you’re allowed to do things at NSA, but your company wants you to move to Langley, which has different rules. So if you’re serious about the high-end of work in the classified workplace, you need to stay off TikTok permanently.
Now, you could be at some other place like DCMA or DCAA that’s not associated with the intelligence community – and everybody has a clearance in the Defense Department. You could be in one of those agencies and probably use TikTok. If you don’t plan to move and your labor isn’t transferable, then it could be fine depending on where you are. You could stay at DCMA for 20 years and not have a problem using TikTok off of government systems.
So it really depends on what your plan is as a cleared worker. Do you want to move around? Do you want to do interesting or different work? If you can stay put, then you’re going to have more liberties.
Should security clearance holders use commercial or retail platforms with caution?
I remember being surprised the first time I saw the Amazon app used. I was on the bus from the Pentagon to the Mark Center. I was sitting in the very back and looked over the seat in front of me. A woman did her entire grocery shopping between the Pentagon and Bailey’s Crossroads. So in general, I think the commercial platforms are going to be the easiest for the agencies to accept.
But in the aggregate, the information potential is probably just as valuable as anything that’s coming off of TikTok. So keeping an eye on where the data is stored and located will help you understand whether it’s a good idea to be associated with the app in question.
It’s similar to traveling as a cleared professional. People know which countries they shouldn’t travel to for vacation if they don’t want to get caught up in something security is not happy with. Effectively, you’re doing the same thing whether you’re traveling by plane to China or you’re clicking on an app with its data located in China. Whatever problems security has with China are going to be the same problems security has with the app.
Cleared professionals are going to have to be a lot savvier about their commercial and consumer practices and understand what apps are not safe. And it’s hard because that device in your hand is so easy to manipulate, especially for the younger folks who don’t always think about the possible ramifications of signing on to that new app and where that data might be located.
On the other end, the problem security runs into is that no sooner do they get the rules set for one set of technologies, a new set of technologies develop, and they’re off and running trying to figure out how security works in that environment.
What’s the best thing a clearance holder can do to understand how to safely use social networking and commercial platforms?
You need to take responsibility for your knowledge of security practices and norms. I tell my clients the week of their birthday every year to reread SEAD 3 and SEAD 4 — not your agency directives and instructions. They’re very complicated and the DoD one will put you to sleep in about five minutes — but the DNI’s overarching regulations were written very well and very clearly. And every year, you need to look at those.
You need to remind yourself what the 13 guidelines are. If you don’t hire counsel, get onto DOHA’s website and read decisions about security clearances. You’d be surprised at what your co-workers can get away with and still have a security clearance. You will also be surprised at things you’re doing that would trigger a security review.
If you decide to work in a classified environment, you’ve got to change your life to fit those norms. And you have to refresh yourself every year. So start with SEAD 3 and SEAD 4, and read the DOE and DoD decisions. They’ll give you an idea of whether your behavior is in the general ballpark of what’s acceptable.
Is it okay to publicly display your security clearance on your LinkedIn profile?
Your resume is kind of controlled, so it’s okay there. But when you stick your clearance on your LinkedIn, it makes you a target.
During a security briefing I once attended, the security manager told us that somebody who was filling out their SF-86 got to the foreign contact section and made a flyer to help them answer the question. They put it on the door handle of every storm door in their cul-de-sac, asking their neighbors if they were foreign nationals because they had to report them on an SF-86…which, of course, makes that individual a bullseye for counterintelligence efforts.
So it’s fine on the resume, but you should not post it. That doesn’t dissuade recruiters. They’re going to look for talent and then look to see if you’re cleared. They have plenty of tools to figure that out. They don’t even need to talk to you to figure it out.
What should clearance holders ascertain from the way things end up playing out legally with TikTok in the coming months?
The question you have to ask is, has anything changed in the White House with the TikTok ban? If President Trump decides TikTok is okay and tries to figure out a fix, I caution our federal service members, employees, contractors, and cadre—you shouldn’t take away from that development that the security process is getting more lenient.
One thing that’s very clear is, there are rules for the White House and there are rules for everybody else. Just because it’s done for the White House doesn’t mean you’re going to get the same application of the standard. So federal employees have to be mindful that their security clearance is the easiest way to get at them. If somebody wants them out, they’ll go for the security side, because it’s very easy.
You’re most vulnerable through your security clearance, and the people who control that review are GS-13s, 14s, and 15s in your security chain of command. So unless you are related to the President or related to somebody in his circle, and you think you’re going to get a sweetheart deal, you need to be most attentive to your security office and your adjudicators. And those standards are not changing.
We’re doing things differently with behavioral mental health issues and sexual conduct than we did 15 years ago. But those changes come in waves of 20-25 years. I don’t see anything changing for the vast majority.
The everyday worker needs to focus on SEAD 3 and SEAD 4. Know more about your security status than your security officer and try to develop a relationship with your boss or security officer, so that security is a daily conversation. And if you’re able to develop that, you’ll never run into problems, and you’ll never need to hire me.
Find more articles about your security clearance here.
Dan Meyer, Esq. is a Partner at Tully Rinckey PLLC’s Washington, D.C. office and has dedicated more than 25 years of service to the field of Federal Employment and National Security law as both a practicing attorney and federal investigator and senior executive. He is a lead in advocating for service members, Federal civilian employees, and contractors as they fight to retain their credentialing, suitability and security clearances.
