Reporting a nanny as a foreign contact for your clearance depends on citizenship, the continuing relationship, personal ties, and the information exchanged. A paid childcare arrangement does not automatically qualify or create an exemption. If the caregiver lives with you, a separate foreign-national roommate or cohabitant reporting question may also apply.

Start with the actual arrangement. A caregiver who comes to your home regularly, knows private family circumstances, and remains a close family friend after employment ends presents different facts from an occasional sitter who exchanges only ordinary service details. The security office needs those facts to apply the relevant reporting instructions.

When must you report a nanny as a foreign contact for your clearance?

Apply the foreign-contact criteria to the relationship, then confirm your reporting obligation with the FSO or agency security office. DCSA’s clarification addresses continuing relationships involving affection, intimate contact, personal obligation, or qualifying exchanges of personal information; it does not establish a nanny-specific rule.

The DCSA NISPOM reporting questions are especially useful because they explain both the test and its exclusions. For contractors under DoD security cognizance, DCSA directs foreign-contact reports to the company’s FSO. Agency employees should confirm their own reporting channel and any additional requirements.

The wider rules for SEAD 3 foreign-contact reporting provide background. For an in-home worker, the practical question is what the recurring relationship actually involves, rather than whether the contract calls the person a nanny, au pair, caregiver, or household employee.

Does being born abroad make the caregiver a foreign national?

No. The reporting definition turns on whether the person is a U.S. citizen or U.S. national. DCSA states that U.S. citizens with dual citizenship are not foreign nationals for this reporting purpose.

A person’s accent, birthplace, or family history does not establish current citizenship. Likewise, permanent residence is different from U.S. citizenship. Avoid filling a report with assumptions where the information is unknown; tell the security office what you know and ask what details are required.

Other categories can still apply regardless of nationality. The fact that someone is a U.S. citizen does not answer a separate marriage or cohabitation question. Keep the foreign-contact definition distinct from other reporting obligations rather than treating citizenship as the answer to every household change.

How does recurring childcare inside your home affect the analysis?

Repeated in-home contact can satisfy the recurring-contact part of the information-exchange test, but the full test still matters. DCSA’s clarification also considers whether the person’s name and nationality are known and whether the information shared is nonpublic and personal.

Describe the pattern: how the caregiver interacts with you, whether the contact is expected to continue, and whether the relationship extends beyond arranging childcare. A label such as “weekly employee” is less informative than an explanation of what is discussed and what personal connection exists.

Consider a hypothetical caregiver who regularly receives private information about a parent’s health problem and household finances, then maintains a personal relationship with the family outside work. Those facts warrant a different discussion with the FSO from an arrangement limited to a pickup time and an invoice.

Neither example is a categorical clearance ruling. The distinction is the information and relationship, assessed together with the rules for the covered employee. Give the security office enough detail to determine which facts matter in your case.

Does sharing a home address or paying wages automatically trigger a report?

Not by itself under DCSA’s commercial-transaction clarification. The guidance excludes information a member of the public would be expected to provide for a legal commercial transaction from this meaning of exchanged personal information.

This exclusion matters in a household employment arrangement. Details needed to arrange lawful services or payment should not automatically be treated as private disclosures establishing a reportable personal relationship. The exclusion also does not settle whether a separate bond of affection or personal obligation has developed.

Compare the nature and purpose of the disclosure. Giving information needed to perform the agreed service may differ from confiding personal vulnerabilities, private financial circumstances, or sensitive family concerns beyond the transaction. If the same detail could serve either purpose, explain the circumstances to the FSO.

DCSA also distinguishes being personable from being personal and excludes certain information exchanged on behalf of an employer for work. Those exceptions deserve attention, but they should not become a blanket rule that any paid relationship is exempt. Paid work and a qualifying personal relationship can coexist.

Is an employment obligation the same as a personal obligation?

The existence of wages or a contract does not, by itself, demonstrate the personal bond described in the foreign-contact test. Examine whether the relationship involves affection, intimacy, or personal obligation beyond its ordinary commercial terms, or independently meets the personal-information branch.

A family may depend heavily on childcare without having described every relevant fact about the relationship. Explain whether you socialize outside work, maintain private contact, share personal confidences, or continue mutual personal commitments unrelated to the service arrangement. Present what actually happens, rather than choosing a label that seems more convenient.

DCSA’s August 2021 ISL 2021-02, in its linked reporting guidance, provides the contractor contact criteria. Its scope is contractors under DoD security cognizance; your agency or contract may require additional reporting.

The following comparisons organize the questions to raise. They are examples for fact gathering, rather than automatic determinations about a particular caregiver.

Does a live-in nanny automatically count as a cohabitant?

Sharing a residence does not by itself resolve the cohabitant definition. SEAD 3 distinguishes residence with shared bonds of affection, obligation, or other commitment from residence for convenience. A separate foreign-national roommate provision can apply even when the cohabitant definition is not met.

The directive’s living-arrangement provisions include a foreign national co-occupying a residence for more than 30 calendar days. That provision appears in the additional requirements for Top Secret or Q access and critical or special sensitive positions. It is not a universal waiting period for foreign-contact reporting.

DCSA’s industry reporting table likewise distinguishes the living-arrangement requirements from foreign-contact reporting. A Secret-level holder should not infer that the absence of that particular roommate requirement removes an otherwise qualifying foreign relationship. Additional agency or contractual instructions may also matter.

Explain whether lodging is part of compensation, when residence began, whether it continues during time off, and what personal ties exist. These details help the office classify the arrangement. Cohabitation is not limited by the directive’s wording to romantic relationships, but neither should every commercial lodging arrangement automatically be called cohabitation.

What facts should you give the FSO when the answer is uncertain?

Provide a factual description covering known citizenship, frequency of contact, information exchanged, personal ties, and residence. Identify what you do not know and request a determination under your applicable reporting instructions.

A useful request might say: “Our caregiver is a known foreign national, comes to the home regularly, and receives these kinds of family information. The caregiver does or does not live with us. Please confirm whether foreign-contact or living-arrangement reporting applies and what information you need.”

Keep the first inquiry focused. Ask for the approved method before sending sensitive identifiers or private records. Once the office gives instructions, retain the permitted confirmation and a note of the facts on which the answer was based.

What changes when the caregiver leaves or the relationship ends?

Ask whether the changed arrangement requires an update. DCSA says updates to a previously reported continuing unofficial foreign association occur when there is a significant change in the nature of the contact. Ending paid work does not necessarily end personal contact or residence at the same time.

Record each change accurately: employment ended, the caregiver moved out, personal communication continued, or contact ceased. If you later complete the November 2016 SF-86, Section 19 asks about qualifying contact within the last seven years, including relevant relationships of a spouse, partner, or cohabitant. A relationship’s end does not automatically remove it from a form’s lookback period.

The SF-86 close-and-continuing-contact question uses its own wording, so do not substitute a brief ongoing-reporting answer for reading the assigned form. The broader discussion of which foreign contacts need reporting is useful context when preparing those questions.

Frequently Asked Questions

Does hiring through an agency remove my reporting responsibility?

The hiring method does not answer the relationship test. Describe your actual contact with the caregiver, information exchanges, and any residence arrangement. The agency contract may explain employment terms, but the security office needs the personal-contact facts.

Do I report a nanny who is a dual U.S. citizen?

DCSA does not treat a U.S. citizen with another citizenship as a foreign national for foreign-contact reporting. Other living-arrangement or agency reporting requirements can still apply, so confirm those separately if relevant.

Should I report only if the caregiver lives with me?

No. A qualifying foreign relationship can exist without shared residence. Assess the recurring contact, personal ties, and information exchanged, then separately check any roommate or cohabitant requirement if the person moves in.

Can I assume the arrangement is exempt because it is paid work?

No. Ordinary commercial details are excluded from the specified personal-information meaning, but a paid relationship may also involve qualifying private disclosures or personal bonds. Send your FSO a factual description of the arrangement and request the applicable reporting instructions.