Privacy Impact Assessment – Inventory Delivery System (IDS)
IDS System Overview
The Inventory Delivery is a rule based, decision-support system that performs actions as early as possible on potential Collection inventory. It will enhance existing Compliance/Collection systems of the IRS by directing tax-delinquency cases to the point in the collection process where they can be processed optimally. IDS also performs locater services (telephone research and address research) to make cases fit for use.
System of Records Number(s)
Treasury/IRS 23.012 Offers in Compromise
Treasury/IRS 26.016 Returns Compliance Program
Treasury/IRS 26.019 Taxpayer Delinquency Account
Treasury/IRS 26.020 Taxpayer Delinquency Investigation
Treasury/IRS 26.022 Delinquency Prevention Programs
Treasury/IRS 34.037 IRS Audit and Security Records System
Data in the System
1. Generally describe the information to be used in the system in each of the following Categories:
a. Taxpayer:
i. Information Returns Master File (IRMF) documents: Information on income received by the taxpayer as reported to IRS by employers, financial institutions, pass through payers, and other parties.
ii. Individual Returns Transaction Master File (IRTF) documents: Tax return information supplied by the taxpayer.
iii. Integrated Data Retrieval System (IDRS) Taxpayer Information File (TIF): entity, account and related modules.
iv. Individual Master File (IMF): Entity, account and related modules.
v. Business Master File (BMF): Entity, account and related modules.
vi. Address information from the ADR (Address Research) Vendor (Credit Bureau).
vii. Address information from the CBRS (Currency and Banking Retrieval System).
viii. Telephone numbers from the TNR (Telephone Number Research) Vendor.
b. Employee:
i. Name, Social Security Number, location, status (active, furloughed, terminated, etc.),
ii. Role (manager, analyst, CSR (Customer Service Representative), security officer, etc.),
iii. Permitted tasks.
c. Other: Data relating to allowable expenses. Census and demographic data on housing, transportation, and cost of living expenses is gathered for counties within states. Transportation costs include the costs of owning and operating a vehicle or using public transportation. Housing costs include mortgage or rental costs, property taxes and utilities. General expenses include costs for food, clothing, credit cards, and other miscellaneous expenses persons incur in day-to-day life.
2. What are the sources of the information in the system? Sub-items 2.a. – 2.d. cover the sources of data.
a. What IRS files and databases are used? IRTF, IRMF, IDRS tax modules and entity data, IMF and BMF, and CBRS (Currency & Banking Retrieval System). IDS does get ACS (Automated Collection System) data but since those files are a subset of IDRS TDA (Tax Delinquent Account) and TDI (Tax Delinquent Investigation) entities and tax modules, it was already covered. The same is true of ASFR. ASFR is a system that creates substitute return records for non-filers that have been identified at Master File and downloaded to IDRS as TDIs. Employee files reside on the IDS database and describe the roles and tasks employees are permitted. These are tables that house security information and permissions for each employee.
b. What Federal Agencies are providing data for use in the system? IDS receives postal tracers giving address information. Other than that, IDS is a sub file of TDAs and TDIs and does not receive any other federal information directly. However, TDA assessments may derive from non-payment of child support or student loans, information is provided by state or federal agencies. Additionally, IRP data contains information reported by federal agencies such as Social Security payments made to the taxpayer, unemployment compensation received by the taxpayer, W-2 information provided from SSA, and information on refunds to the taxpayer of state income tax.
c. What State and Local Agencies are providing data for use in the system? See b. above.
d. What other third party sources will data be collected from? Choicepoint, Transunion Credit Bureau, and the U.S. Postal Service. These companies are third party vendors that provide public record information on telephone numbers and addresses.
e. What information will be collected from the taxpayer/employee? Taxpayer: Verified address information. Once a potential new address is identified for the taxpayer, a letter is sent to the taxpayer at that address requesting confirmation that the address is correct. Multiple candidate addresses may exist but, in the case of addresses from IRP (Information Returns Processing) information, some of the addresses may no longer be current. If the taxpayer confirms the address, their address on MF is changed to the new address. Employees: Audit trail information about applications and TINs (Taxpayer Identification Number) accessed and actions taken.
NOTE: IDS cases are received as data files from IDRS, ACS (Automated Collection System), and ASFR (Automated Substitute for Returns). Additional cases are received by scanning bar codes on undelivered mail.
3. Please answer the following questions:
a. How will data collected from sources other than IRS records and the taxpayer be verified for accuracy? Data files are transferred to and from Credit Bureau, and TNR vendor using FTP (File Transfer Protocol). “R-U-There” letters are sent to the taxpayer to verify the candidate address and request a signature. IDS systematically verifies the consistency/accuracy of data received from other sources. By sending R-U-There letters to taxpayers at the addresses provided by IRS and third party vendors, we confirm the accuracy of those addresses. Telephone number verification is performed when ACS personnel use the telephone numbers to contact the taxpayer. If the telephone number found is incorrect, ACS removes the number from the taxpayer’s record. ACS performs consistency checks that are checks that verify that only numbers are received in a telephone number field or that an area code matches an address region. IDS verifies address information by using an address-standardization COTS (Commercial Off-The-Shelf) product CODE1. A taxpayer signature is required and verifies the address before any update takes place. Telephone numbers are only checked for a valid format and are never updated to the Master File.
b. How will data be checked for completeness? IDS internal testing of each subsystem. IDS performs unit and integration testing on all applications. All data within the application undergo validity and consistency checks as per the specifications. All specifications adhere to security and privacy regulations.
c. Is the data current? Yes. How do you know? The SIA (Standardized IDRS Access) extract pulls the latest IRMF/IRTF files available. For IRMF data, the latest cycle of data is used provided that the files are within the last 2 tax filing years. Otherwise, the data is considered too old to provide useful information. Data currency beyond the extract is the responsibility of the Information Systems function responsible for building the IRMF and CBRS (Currency & Banking Retrieval System). Example: an IDS request gathers information from IDRS, CFOL, ACS, ASFR and Scan (ADR) (Undelivered mail). The SDI (SIA Data Interface) calls IDRS TIF (Taxpayer Information File) using SIA, CFOL (IMF, BMF, IRTF, IRMF), using SCOP (Standardized CFOL Overnight Processing), and IDS. After processing, IDS, IDRS TIF, ACS and ASFR are uploaded with appropriate information.
d. If IDRS data is more than two days old, a refresh of data is requested prior to continued analysis.
4. Are the data elements described in detail and documented? Yes. If yes, what is the name of the document?
The data elements are described and sources listed in the Software Requirements Specifications for the Inventory Delivery System (IDS. In addition, data elements are described in the Data Object Traceability System (DOTS) Report.
Access to the Data
1. Who will have access to taxpayer data in the system (Users, Managers, System Administrators, Developers, Other)?
Developers (IS Programmers and Analysts) through the use of live data waivers, Systems Administrators, Database Administrators, National Office Analyst in charge of the program, CSRs (Customer Service Representatives) Managers, Security Officer and COTR. TIGTA (Treasury Inspector General for Tax Administration) and GAO (Government Accountability Office) audits must be incorporated in their plans, memos sent to IRS Executives indicating planned audit, scope of audit, etc. Forms 5081 (prepared and signed, and approved by appropriate levels) allowing access to the audited systems (access is never at the system administrator level).
2. How is access to the data by a user determined?
On a need to know basis, by case, during testing or development. System access would require a login ID, password, and permissions to access the application.
Are criteria, procedures, controls, and responsibilities regarding access documented? Yes. All system access criteria, procedures and controls and responsibilities are detailed in the Solaris Administration Guide (SunOS 5.8 vol. 1 & 2), SunOS 5.8 User’s Guide and Advanced User’s Guide, Basic Security Module Guide (SunOS 5.8), Oracle Pro*C User’s Guide, and the Trusted Facility Manual.
3. Will users have access to all data on the system or will the user’s access be restricted? Explain.
User’s access to the application will be restricted based on their assigned role code. Developers and programmers are granted access to the system based on standard Form 5081 procedures.
4. What controls are in place to prevent the misuse (e.g. browsing) of data by those having access?
All TINS accessed by the user are recorded as an audit trail. Users are restricted from accessing their own TIN. The Restructuring and Reform Act of 1998 (RA98) and Privacy Act prohibit browsing by any employee. The Disclosure, Security and TIGTA offices to assure compliance with the law conduct annual reviews.
5. Please answer the following questions:
a. Do other systems share data or have access to data in this system? Yes. If yes, explain.
The “current system” is, in fact, a complex of internal IRS information systems and computer networks that have evolved over many years to support the IRS mission. These systems, in general, automate parts of an IRS business process that is much larger than the collection process for delinquent accounts. The IDS process, therefore, should be seen as part of a larger and more complex business process that supports the IRS mission. Collection and Customer Service units currently obtain case inventories and supporting information from four large mainframe-based systems and several smaller systems. Descriptions of the systems follow:
The Master File (MF) is the principal repository of IRS corporate data, which identifies tax delinquent cases through the computer analysis of tax returns, other associated documents, and tax return filing requirements that have been established for each taxpayer.
The Integrated Data Retrieval System (IDRS) enables employees in the Service Centers and the District Offices to have instantaneous visual access to certain taxpayer accounts. One function of the system is to automatically generate notices, collection documents and letters mailed to taxpayers.
The Automated Collection System (ACS) is used to work tax delinquent cases, primarily by telephone.
The Integrated Collection System (ICS) is designed to assist revenue officers in their collection activities. The ICS is a combination of the IBM mainframe applications in IRS SCs, file servers at posts-of-duty, and laptop/desktop applications to which case work is downloaded from the server/mainframe.
The Automated Lien System (ALS) is designed to process lien request records and determine appropriate lien actions to obtain full payment from the taxpayer.
The Automated Substitute for Return (ASFR) accepts selected Taxpayer Delinquency Investigation (TDI) input on those taxpayers that fail to file tax returns for a given year. It tracks all cases, issues required notices and results, and prepares a Tax Calculation Summary, which is mailed with the ASFR 30-day letter. It also prepares the Notice of Deficiency; which is mailed with the ASFR 90-day letter.
b. Who will be responsible for protecting the privacy rights of the taxpayers and employees affected by the interface? The application analyst, security analyst, privacy analyst, and management.
6. Please answer the following questions:
a. Will other agencies share data or have access to data in this system (International, Federal, State, Local, Other)? No. There are no plans for information exchanges with other agencies.
b. How will the data be used by the agency? N/A. There are no plans for information exchanges with other agencies.
c. Who is responsible for assuring proper use of the data? N/A. There are no plans for information exchanges with other agencies.
d. How will the system ensure that agencies only get the information they are entitled to under IRC 6103? N/A. There are no plans for information exchanges with other agencies.
Attributes of the Data
1. Is the use of the data both relevant and necessary to the purpose for which the system is being designed?
Yes. The use of data is relevant and necessary because the purpose of the IDS system is to automate the current manual processes. The system ensures that the address and/or telephone number is the most up-to-date available. By law, IRS needs to take certain steps to locate taxpayer’s addresses/telephone numbers in order to pursue collection activities using the most cost-effective assignment of cases.
2. Please answer the following questions:
a. Will the system derive new data or create previously unavailable data about an individual through aggregation from the information collected? No. The system compiles information previously gathered through the manual process.
b. Will the new data be placed in the individual’s record (taxpayer or employee)? No.
c. Can the system make determinations about taxpayers or employees that would not be possible without the new data? No.
d. How will the new data be verified for relevance and accuracy? N/A, IDS does not create new data.
3. Please answer the following questions:
a. If data is be consolidated, what controls are in place to protect the data from unauthorized access or use? Audit trails at the system level for all users. Login/password, permission system, and role and task restrictions prevent unauthorized access to applications for which someone is not profiled.
b. If processes are being consolidated, are the proper controls remaining in place to protect the data and prevent unauthorized access? Yes. Explain. See 3.a. above. In addition, annual security, disclosure, and TIGTA reviews will be conducted.
4. How will data be retrieved? Can a personal identifier retrieve it? If yes, explain.
During reviews and testing, data can be retrieved by personal identifiers (TIN, file source, TIN Type, MFT, Tax Period) through a database query. For testing purposes, a waiver was obtained to access live taxpayer data.
What are the potential effects on the due process rights of taxpayers and employees of:
a. Consolidation and linkage of files and systems: IDS automates the routing of the existing manual processes and does not change the current due process rights of taxpayers and employees.
b. Derivation of data: See 4.a. above.
c. Accelerated information processing and decision-making: See 4.a. above.
d. Use of new technologies: See 4.a. above.
How are the effects to be mitigated? No mitigation necessary. See 4.a. above.
Maintenance of Administrative Controls
1. Please answer the following questions:
a. Explain how the system and its use will ensure equitable treatment of taxpayers and employees. Treatment of taxpayers would be consistent nationwide. Except for variations in expenses based on census and demographic variations, all processes handle taxpayer records in the same fashion regardless of taxpayer’s location. As an expert system, there are no processes that yield inconsistent taxpayer treatment across the country.
b. If the system is operated in more than one site, how will consistent use of the system and data be maintained in all sites? The production system will be a consolidated site in TCC (Tennessee Computing Center). No other production sites will exist. The Western Development Center (WDC) is doing the development only. All programs are controlled through ClearCase, and there is transmittal control of all software.
c. Explain any possibility of disparate treatment of individuals or groups. There should be no disparate treatment of taxpayers. The System is designed to automate a current manual process, and uses objective criteria to assign or close cases. For Address research, IDS consolidates processing at one site with updated equipment.
2. Please answer the following questions:
a. What are retention periods of data in this system? See attached data retention table.
b. What are the procedures for eliminating the data at the end of the retention period? Where are the procedures documented? Data is deleted using an automated housekeeping routine (Records Disposition Handbook 1.15.2) when the last of the taxpayer’s and related TINs cases have been processed/resolved. This application was developed for IDS according to security handbook 2.10 and uses required retentions periods.
c. While the data is retained in the system, what are the requirements for determining if the data is still sufficiently accurate, relevant, timely, and complete to ensure fairness in making determinations? IDS requirements specify that data must be refreshed (re-extracted from IDRS or Corporate Files On-Line (CFOL)) if the data is more than two days old. This ensures that the data is accurate, timely, and complete before beginning analysis. Individual applications may also be programmed to automatically re-request data based on pre-determined criteria. Program requirements include checks and balances.
3. Please answer the following questions:
a. Is the system using technologies in ways that the IRS has not previously employed (e.g. Caller-ID)? Additional security features are used for transferring files to and from external vendors. The Credit Bureau (address information) and Choicepoint (telephone numbers) are transferred using Secure FTP (File Transfer Protocol) through specially secured and configured firewalls. The requests to the CBRS are secure point-to-point since that system is located within the Treasury Intranet.
b. How does the use of this technology affect taxpayer/employee privacy? Taxpayer/employee privacy is maintained according to accepted security encryption procedures currently in place.
4. Please answer the following questions:
a. Will this system provide the capability to identify, locate, and monitor individuals? Yes. If yes, explain. The presence of taxpayer data with an individual identifier makes it possible to associate data with a given taxpayer. Also the system is able to locate new addresses and telephone numbers not currently shown on IDRS.
b. Will this system provide the capability to identify, locate, and monitor groups of people? No.
c. What controls will be used to prevent unauthorized monitoring? Audit trail (system and application levels) recording all TINs and user accesses, a restriction on access to a user’s TIN, life cycle controls, Section 6103, UNAX, IRS Code of Conduct.
5. Please answer the following questions:
a. Under which Systems of Record (SOR) notice does the system operate? Provide number and name. 23.012 (Offers in Compromise), 26.016(Returns Compliance Program), 26.019 (Taxpayer Delinquency Account), 26.020 (Taxpayer Delinquency Investigation), 26.022(Delinquency Prevention Programs), 34.037 (IRS Audit and Security Records System).
b. If the system is being modified, will the SOR require amendment or revision? Explain. SORs do not require modification. IDS project personnel are working with the 6103 office to review records. This office determined that no additional SORs are required at this time. They need a copy of this PIA to conclude their review. We expect to receive a memo to the effect that no modifications or new SORs will be required.
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