Privacy Impact Assessment – Integrated Collection System (ICS)
ICS System Overview:
The Integrated Collection System (ICS) is an automated inventory management system that supports the Small Business/Self-Employed (SB/SE) Collection Field Revenue Officers. Case data is received from Integrated Data Retrieval System (IDRS) and assigned to Revenue Officers. ICS allows them to update data, track time on cases, write histories, file liens and levies, post payments, and close cases. Users can work in the office, attached to the local area network (LAN), out of the office in a stand-alone capacity, or out of the office attached to the network via Enterprise Remote Access Project (ERAP). In addition to SB/SE Revenue Officers, Wage and Investment (W&I) Field Assistance and Centralized Case Processing maintain an inventory of cases on ICS.
System of Records Number(s):
Treasury/IRS 26.019 Taxpayer Delinquent Accounts (TDA) Files
Treasury/IRS 34.037 IRS Audit Trail and Security Records System
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. Other (Describe)
A. Taxpayer – The ICS contains information related to a taxpayer delinquent account (TDA) or taxpayer delinquent return (TDI). TDA and TDI information is extracted from the Integrated Data Retrieval System (IDRS) or may be input into the system by users of ICS. Information such as liens, levies, levy sources, assets, seizure activity, address, Power Of Attorney (POA), payments, as well as closing information and history may be added to the case file by users of ICS and then uploaded to IDRS. Information such as name and taxpayer ID are not uploaded, since such information is already contained within IDRS.
B. Employee – Minimal employee information is stored on the system for the purpose of assigning the taxpayer cases to them and generating documents/correspondence. Employee information includes the employee’s name, work address, work telephone number, e-mail address, title, grade and identification number.
C. Audit Trail Information – Audit trail information about each action taken on a case is captured and stored. The ICS application has a Windows XP workstation component and an IBMIAP mainframe component. The ICS end user does not ‘login’ to the IBMIAP mainframe component. Identification and Authentication is done at the local area network (LAN) level using the Active Directory. The end user’s LAN account (Standard Employee Identifier-SEID) must be in the ICS_USERS Active Directory group. The audit logs for ICS access is performed by the Active Directory Domain Controller.
D. Other – None
2. Describe/identify which data elements are obtained from files, databases, individuals, or any other sources.
A. IRS
B. Taxpayer
C. Employee
D. Other Federal Agencies (List agency)
E. State and Local Agencies (List agency)
F. Other third party sources (Describe)
A. IRS – IDRS, Business Master File (BMF) and the Automated Lien System (ALS) are the sources of data relating to a taxpayer on the system. Corporate Authority Directory Service (CADS) is the source of the employee’s email address.
B. Taxpayer – Case information may be gathered from the taxpayer during an investigation. This information may contain taxpayer’s income, expenses, assets and liabilities. Once gathered, it is keyed into the system by ICS users. The information input by ICS does not contain taxpayer Social Security Number (SSN) or ID.
C. Employee – Case information is gathered by IRS employees during field investigations. This information is based on a review of public records or obtained from the taxpayer during personal interviews.
D. Other Federal Agencies – No data is received electronically from a federal agency. Data received during a field visit is keyed into the system by an ICS user.
E. State and Local Agencies – No data is received electronically from a state or local agency. Data received during a field visit to a state or local agency is keyed into the system by an ICS user.
F. Other Third Party Sources – Revenue Officers will contact other third party sources (creditors, neighbors, employers, former employers, etc.) to secure information.
3. Is each data item required for the business purpose of the system? Explain.
Yes. Each data item is required by the system. Each user receives their case inventory electronically and then is able to work the case electronically (i.e., contacting taxpayer, generating correspondence, issuing liens and levies, closing cases and posting payments). Reports are produced using the information in the system.
4. How will each data item be verified for accuracy, timeliness, and completeness?
Information that has significance to a determination of a tax liability or a penalty is verified by looking at bank records, corporate files and other official sources. Information pertaining to the taxpayer’s financial situation is verified by reviewing courthouse records and by contacting creditors to verify balances due. The investigator then keys the information into the ICS. Appropriate validity and consistency checks are built into the automated system.
5. Is there another source for the data? Explain how that source is or is not used.
Yes. When data is verified for accuracy, timeliness and completeness by an investigator, new data, such as new address or spouse name may be obtained from the following sources: bank records, corporate files courthouse records, and creditors. This information is then keyed into the ICS.
6. Generally, how will data be retrieved by the user?
The ICS system makes the data available to users on a need-to-know basis. All SB/SE Collection Field function employees, W&I Field Assistance employees and Centralized Case Processing employees and their managers who work or manage an inventory of cases are allowed access to their inventory.
7. Is the data retrievable by a personal identifier such as name, SSN, or other unique identifier?
Yes. A user’s inventory of data is displayed / presented to them. A given case in their inventory may then be selected from the list of cases. Also, a specific case not part of an employee’s assigned inventory may be requested by Employer Identification Number (EIN) or SSN. An employee’s SEID is used to retrieve his/her e-mail address.
Access to the Data
8. Who will have access to the data in the system (Users, Managers, System Administrators, Developers, Others)?
SB/SE Collection Field function employees, W&I Field Assistance employees and Centralized Case Processing employees and their managers who work or manage an inventory of cases are allowed access to their inventory. System administrators and developers also have access to the data.
9. How is access to the data by a user determined and by whom?
Employees’ personnel folders contain a description of their duties and responsibilities. The Internal Revenue Manual governs the discharge of these duties.
A user is established as an employee on ICS by an On Line (OL) Form 5081 signed by their manager. Once established, they have access to their inventory of cases. These cases are assigned based on assignment rules established in ICS. An ICS user also has access to specific cases via TIN.
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.
ICS receives information from IDRS, BMF, CADS, Embedded Quality Review System (EQRS), Entity and ALS. ICS provides information to Collection Time Reporting System (CTRS), Entity, Servicewide Electronic Research Program (SERP), Enforcement Revenue Information System (ERIS), ALS, IDRS, Automated Trust Fund Recovery (ATFR) program, IDS, Taxpayer Survey and the Third Party Contact database. ICS does not share information with another system.
11. Have the IRS systems described in Item 10 received an approved Security Certification and Privacy Impact Assessment? Yes.
12. Will other agencies provide, receive, or share data in any form with this system? No.
Administrative Controls of Data
13. What are the procedures for eliminating the data at the end of the retention period?
When a taxpayer case is closed, the closing information is made part of the taxpayer records on IDRS and Master File. The case is maintained on the ICS mainframe as a closed case for six months, after which portions of the closed case are archived. The archived files are available for three years and then destroyed. Any backup files maintained by the system are destroyed at the end of their retention period, which is documented in the Computer Programmer Books (CPBs) used at the Computing Centers.
The procedures for disposing of closed cases are contained in the Internal Revenue Manual.
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.
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?
Yes. A taxpayer may claim a payment has been made that is not reflected on the account or the tax liability is not accurate. Research would be conducted and corrections requested as appropriate.
19. If the system is web-based, does it use persistent cookies or other tracking devices to identify web visitors?
Not applicable. The system is not web-based.
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