This is why they create a 'nomination', 'verification' and 'implementation' process with their “originators,” “nominators,” “aggregators,” “screeners,” and “encountering agencies.”
But the problem comes down to the actual facts. This document does a terrible job of separating a process design - First a candidate gets originated by an originator, who passes that said candidate on to a nominator, etc - from the basic factual requirements needed to become listed as a suspected (or actual) terrorist. (Though the latter would seem easier to determine.)
What is really needed is a clear set of factually determined checks to show that someone is indeed a suspected terrorist. Not a process design that creates a structure towards watch list inclusion.
In design this is often a problem. It's a very common mistake. Teams, Companies, Professionals design a process, but not the necessary, required steps - and everything just gets lost in that process, especially when everything takes place according to the plan.
Here's what the watch list needs. A list that triggers inclusion.
If a appears to have done x, y or z, a get's "originated." If x, y, and z are verified, a gets nominated. At this point counter rationales for x, y and z must be presented to excuse the suggestion of terrorism when there is none. Etc.
What is important are the verifiable X, Y and Z actions. That's what a document of this type should present.
Now I know that the response is that if people are told how they get onto a watchlist, they will try to avoid those tasks while maintaining their terrorist agenda, thereby avoiding being categorized as a suspect.
But isn't that the point, don't we want people to not engage in pre-terrorist activity, like going to a training camp in Afghanistan, or sending money to organizations who have actively taken responsibility for civilian bombings. Isn't that the point?
Getting people to be classified as suspected terrorists is not what a watchlist should be about. A watchlist should be about commonly agreed upon actions that as a society we do not support, and we can change our minds about what we do and do not support over time.
Then the watchlist can be public, those on the watchlist can be public, their reason for being on the watchlist can be public and we can decide - together- who should and should not be on a watchlist.
We already do it with criminals. Why is this process any different?
Criminals can be just as deadly and corrupting to our society, but yet we've figured out a way (to some degree) to deal with them. We should be able to do the same with Terrorists.
A new process is possible, one that will in fact make us, and everyone safer. This method is not that process. Or at least that is my opinion.