Privacy Impact Assessment – Volunteer Administrative Records
Volunteer Administrative Records System Overview
Volunteer Administrative Records: IRS has developed a plan to increase the level of quality for both return preparation and other services provided to taxpayers who visit Volunteer Income Tax Assistance (VITA) and Tax Counseling for the Elderly (TCE) sites for tax assistance. IRS must communicate internally and externally the role that accurately prepared returns play in the reduction of burden on taxpayers.
IRS will conduct four types of reviews:
o Mandatory and Routine Site Reviews
o Observation Reviews
o Shopping Reviews
o Quality Review of Volunteer Prepared Tax Returns
Site reviews will be conducted to measure the extent to which the volunteer tax preparation sites adhere to standard operating procedures and guidelines when performing their daily activities. Any problems found during the review will be documented and appropriate actions will be taken. No taxpayer information will be retained. The sample selection to determine which sites to be visited for Mandatory site reviews will be made by Statistics of Income (SOI) or Wage & Investment (W&I) Research. The list will be provided to the Area and Territory Offices to conduct these reviews. Routine site review will be selected based on the criteria in IRM 22.30. Site reviews will not be a surprise to the individuals and organizations that volunteer their services. To ensure that the individuals and organizations are available; the assigned tax specialist (reviewer) will work with them to arrange the date and time of review with the site.
Observation reviews will be conducted to measure the quality of service provided by people and organizations that volunteer their services to help taxpayers to file individual federal tax returns at volunteer sites. Any problems found during the review will be documented and appropriate actions will be taken. No taxpayer information will be retained. The sample selection to determine which sites to be visited for Observation reviews will be made by Statistics of Income (SOI) or Wage & Investment (W&I) Research. The list will be provided to the Area and Territory Offices to conduct Observation reviews. Observation reviews will not be a surprise to the individuals and organizations that volunteer their services. To ensure that the individuals and organizations are available; the assigned tax specialist (reviewer) will work with them to arrange the date and time of review with the site.
Shopping visits will be conducted to measure the quality of return preparation provided by people and organizations that volunteer their services to help taxpayers to file individual federal tax returns at volunteer sites. An individual that volunteers their services may conduct shopping visits. Any problems found during the review will be documented and appropriate actions will be taken. No taxpayer information will be retained. Shopping visits will be unannounced and the shoppers may not identify themselves during the review. The Shopper will be provided a list of potential sites to visit along with detailed scenarios and source documents. The scenarios contain a summary statement, identify the tax issues being tested, key information needed by the volunteer shopper and a copy of a correctly prepared tax return. Volunteer shoppers should have basic tax law knowledge, and awareness of how volunteer tax preparation sites operate, and good working knowledge of the scenario used.
Quality Review of Volunteer Prepared Tax Returns will be conducted to measure the quality of service provided by people and organizations that volunteer their services to help taxpayers to file individual federal tax returns at volunteer sites. Completed individual tax returns will be reviewed for accuracy. Any problems found during the review will be documented and appropriate actions will be taken. No taxpayer information will be retained. The sample selection to determine which sites to be visited for Quality Review will be made by Statistics of Income (SOI) or Wage & Investment (W&I) Research. The list will be provided to the Area and Territory Offices to conduct Quality Review of volunteer prepared tax returns. Quality Review of volunteer prepared tax returns will not be a surprise to the individuals and organizations that volunteer their services. To ensure that the individuals and organizations are available; the assigned tax specialist (reviewer) will work with them to arrange the date and time of review with the site.
Form 6729, Volunteer Return Preparation Program Site Review, will be used when conducting a Mandatory or Routine quality site review. Form 6728A, Volunteer Return Preparation Program Observation Review, will be used for Observation reviews and Form 6729B, Volunteer Return Preparation Program Shopping Visit Review, will be used for Shopping visits. Form 6729C, Volunteer Return Preparation Program Return Review will be used for review of volunteer prepared individual income tax returns. Metrics from Forms 6729, 6729A, 6729B, and 6729C will be a part of the IRS Taxpayer Assistance Reporting System (STARS). STARS will be used by SOI, W&I Research and Territory offices to identify sites for Shopping, Observation, Mandatory, and Routine reviews.
System of Records Number(s)
Treasury/IRS 10.007 SPEC Taxpayer Assistance Reporting System (STARS)
Treasury/IRS 34.037 IRS Audit Trail and Security Records System
Treasury/IRS 10.555 IRS Volunteer Records (IN DRAFT)
Data in the System
1. Describe the information (data elements and fields) available in the system in the following categories:
A. Taxpayer
B. Employee
C. Audit Trail Information (including employee log-in info
D. Volunteer
E. Other
A. Taxpayer – No taxpayer data is collected in the system.
B. Employee - Standard Employee Identifier (SEID, management reviews of employees can be notated in files.
C. Audit Trail - Audit trail information has been enabled in STARS as per Treasury/IRS 34.037 safeguards and further defined in TD P 71-10 STARS Access levels and read/write capabilities have been enabled as per management’s determination of need-to-know.
Electronic Filing Identification Number (EFIN) EFINs are used for electronic filing and are issue to Individuals that volunteer their services to help taxpayers through programs such as Volunteer Income Tax Assistance (VITA) and Tax Counseling for
the Elderly (TCE).
D. Volunteer - Volunteers Name, address, and telephone number, Affiliated Volunteer Organization, e-mail address, Electronic Filing Identification Number (EFIN), levels of training, available times to work; language skills; tax law skills; certification levels (CPA, Attorney, Enrolled Agent, etc.), tax law training levels; ability to deliver products and services; contact information; availability for delivery of products and services, geographical coverage; resources; services provided, and inventory of software/hardware provided to the volunteer. Volunteers’ certification of successful completion of tax law training from either the e-learning modules in the Link & Learn Taxes internet application or IRS Publication 678, Volunteer Assistor’s Guide.
E. None
2. Describe/identify which data elements are obtained from files, databases, individuals, or any other sources.
A. IRS
B. Taxpayer
C. Employee
D. Volunteer
E. Federal, State, Local
F. Third party sources (Describe)
A. IRS - This application will be a module of SPEC Taxpayer Assistance Reporting System (STARS). STARS is C# (C-Sharp) database that will be used to secure site and volunteer organization information (See attached forms). STARS has a PIA on file dated 12/18/03. STARS was certified 2/10/04.
B. Taxpayer - No taxpayer data
C. Employee – Standard Employee Identifier (SEID) management reviews of employees may be notated in these files.
D. Volunteer - Volunteers Name, address, and telephone number, Affiliated Volunteer Organization, e-mail address, Electronic Filing Identification Number (EFIN), levels of training, available times to work; language skills; tax law skills; certification levels (CPA, Attorney, Enrolled Agent, etc.), tax law training levels; ability to deliver products and services; contact information; availability for delivery of products and services, geographical coverage; resources; services provided, and inventory of software/hardware provided to the volunteer. Volunteers’ certification of successful completion of tax law training from either the e-learning modules in the Link & Learn Taxes internet application or IRS Publication 678, Volunteer Assistor’s Guide
E. None
F. None
3. Is each data item required for the business purpose of the system? Explain.
Yes. To verify volunteer tax preparation site information (i.e. Site name, address, telephone number, hours of operation, services offered), and to have tools to measure and increase the level of quality for both return preparation and other services provide to taxpayers who visit VITA and TCE and other services.
4. How will each data item be verified for accuracy, timeliness, and completeness?
Data items are verified by the person who inputs it into STARS, SERP and E-File reports. The instrument to be used in collecting the data (Forms 6729, 6729A, 6729B, and 6729C) will be scanned or input electronically. Each person collecting the data; Area and Territory employees, Quality Assurance Staff, will verify accuracy of each data item.
5. Is there another source for the data? Explain how that source is or is not used. No.
6. Generally, how will data be retrieved by the user?
A combination of identifiers – Site name, electronic filing identification number (EFIN), site identification number (SIDN), Name of Volunteer organization, site address, zip code, and e-mail address.
7. Is the data retrievable by a personal identifier such as name, SSN, or other unique identifier?
A combination of identifiers – Name of volunteer organization, site name, site address, EFIN, SIDN, zip code, and email address.
Access to the Data
8. Who will have access to the data in the system (Users, Managers, System Administrators, Developers, Others)?
SPEC HQ staff (Field Operations, Communications and Education & Product Development) for the entire database. Area & Territory Office staff would be given an extract of the Mandatory, Routine, Observation, Shopping, and Return review results and comments by geographic region. No names of taxpayers or volunteers, or any other identifiable information will be included in reports.
9. How is access to the data by a user determined and by whom?
SPEC Director authorizes the Chief, Education & Product Development to collect and retain the information. The Chief, E&PD will provide a report to Field Operations of Mandatory, Routine, Observation, and Shopping review results and comments. The report will be organized by Area and Territory. Each Territory will receive a report of Mandatory, Routine, Observation, Shopping, and Return reviews conducted in their Territory.
10. Do other IRS systems provide, receive, or share data in the system? If YES, list the system(s) and describe which data is shared. If NO, continue to Question 12.
Yes. The SPEC Taxpayer Assistance Reporting System (STARS) receives the extracts of the data collected as a module to STARS.
11. Have the IRS systems described in Item 10 received an approved Security Certification and Privacy Impact Assessment?
Yes. STARS has a valid PIA and Security Certification. PIA dated 12/10/03. STARS received its Security Certification and Accreditation on 2/10/04.
12. Will other agencies provide, receive, or share data in any form with this system?
No. No other agencies except as required by law, such as to TIGTA upon request in situations where the individuals conduct warrants it.
Administrative Controls of Data
13. What are the procedures for eliminating the data at the end of the retention period?
Record retention will be established in accordance with IRM 1.15.31-1.10(1)(a) Records Control Schedules For Customer Service which states:
(a) Record Copy.
DESTROY 3 years after close of the reporting year.
(b) All Other Copies.
DESTROY when no longer needed in current operations or after 2 years, whichever is earlier.
14. Will this system use technology in a new way? If "YES" describe. If "NO" go to Question 15. No.
15. Will this system be used to identify or locate individuals or groups? If so, describe the business purpose for this capability.
No. The system will have some capability to locate individuals and organizations that volunteer their services to help taxpayers through programs such as Volunteer Income Tax Assistance (VITA) and Tax Counseling for the Elderly (TCE),. However, the system is necessary to ensure the quality of individuals and organizations that provide free tax assistance to the public. All Volunteer Administration Records collected and maintained will be voluntarily submitted by the individual or organization that provides free tax assistance to the public. Third party information will not be entered into the system.
16. Will this system provide the capability to monitor individuals or groups? If yes, describe the business purpose for this capability and the controls established to prevent unauthorized monitoring. No.
17. Can use of the system allow IRS to treat taxpayers, employees, or others, differently? Explain. No.
18. Does the system ensure "due process" by allowing affected parties to respond to any negative determination, prior to final action?
Not applicable.
19. If the system is web-based, does it use persistent cookies or other tracking devices to identify web visitors?
Not applicable – not web-based.
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