Privacy Impact Assessment (PIA) – Appeals Centralized Database System (ACDS)
ACDS System Overview
Appeals Centralized Database System (ACDS) is the mission critical system supporting the activities of the Appeals organization. ACDS is web-based and accessible only from the IRS intranet. ACDS supports and captures information on many of the core business activities, including; inventory and statute control, tracking case status; tracking case actions and issues; assigning employees to cases; creating and maintaining employee timesheets; documenting Appeals Officer appraisals. In addition, ACDS is used for all Appeals management information statistics and produces management information reports. The reports generated by ACDS are used to improve the quality of service and to provide IRS executives with timely and accurate metrics on how well the Appeals organization is meeting its strategic goals, and supporting IRS and Treasury goals. Prior to the implementation of ACDS, Appeals cases were tracked and assigned in a system called uniSTAR. UniSTAR, was a local database and lacked information outside the local office. Prior to uniSTAR, inventory control existed only in a paper environment, resulting in poor inventory control, slower response times, and a lengthier appeals process that frustrated taxpayers and employees alike.
The eCase enhancement will allow IRS the ability to electronically transmit case data that has already been input to a database by the supplier organization function. This will eliminate the need for Appeals employees to manually input the data into ACDS, thus reducing the chance for input errors and allowing the Case Processors/Tax Examiners to simply validate the electronic information by comparison to the paper case file that they will continue to receive. This will potentially allow for higher data accuracy, faster assignment of a case and therefore faster case resolution. The initial automated interfaces are with the Examination Returns Control System (ERCS) and Automated Offer in Compromise (AOIC).
System of Record Number(s)
Treasury/IRS 44.003, Unified System for Time and Appeals Records
Treasury/IRS 34.037, the 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 – Tax return information
B. Employee – Personnel information. Employee information, while contained in the ACDS database, is kept separate from taxpayer data. This employee information is accessible only by the employee or his/her manager. The only information kept with the TP record is the employee’s UserID. Accessing the taxpayer record does not allow access to the detailed employee record. Some of the categories of information captured include:
1. user - employee name, user name, user ID, employee number, badge number, SSN, address [office, home, email], phones [business cellular, office, fax, VMS, home, emergency, pagernumber, series ID, group ID.
2. performance appraisal – rating narrative, job elements, position, series, grade
3. employee performance folder
4. training – courses taken, completion date, training desired
5. work experience
6. education
7. user privileges
8. positions held
9. work reviews
C. Audit Trail Information - System will be C2 compliant. ACDS is C2 compliant in accordance with LEM 25.10.7 Windows 2000/XP Security Standards. Audit policies within that manual include:
Audit account logon events (AuditAccountLogon) - Success/Failure
Audit account management (AuditAccountManage) - Success/Failure
Audit directory services access (AuditDSAccess) - Success/Failure
Audit logon events (AuditLogonEvents) - Success/Failure
Audit object access (AuditObjectAcess) - Success/Failure
Audit policy change (AuditPolicyChange) - Success/Failure
Audit privilege use (AuditPrivilegeUse) - Success/Failure
Audit process tracking (AuditProcessTracking) - No auditing
Audit system events (AuditSystemEvents) - Success/Failure
D. Other – N/A
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)
A. IRS – Information from the Admin file/case file is input manually into ACDS.The Admin file/case file contains the returns of the taxpayer, consent to extend the statute if needed, examining officer’s report, and other documents relating to the taxpayer’s liability for the year or years involved, such as protests or petitions, claims for refund or abatement, and other pertinent documents or papers.
The Admin file/case file is a paper document that is received from the relevant Operating Division (i.e., Wage & Investment [W&I], Small Business/Self-Employed [SB/SE], Tax Exempt and Government Entity [TE/GE], or Large & Mid-Size Business [LMSB]) that initially worked the case. Although only some of the information is input into ACDS, all the information in the Admin file/case file is available for Appeals to use to make its ex parte decision (i.e., a complete and independent evaluation of tax liability) on the case. The Case Inventory Screen and Return Information Screen identify what data elements are put into ACDS from the Admin files/case files.
eCase - Data from Examination Return Control System (ERCS) and Automated Offer in Compromise (AOIC) is extracted from those systems only for cases identified to be bound for Appeal. When extracted, this information is stored in a database called eCase within the Appeals eCase server. Data from ERCS and AOIC can be used to automatically populate some of the ACDS (Appeals Centralized Database System) user interface fields if the Case Processor/Tax Examiner chooses to accept the electronic data found in eCase after verification with the Admin file/case file. If the eCase data is not correct, the Appeals case is manually created in ACDS. Attachment 3, eCase ETL Specification document (on CD), identifies the data elements for eCase and the data elements from ERCS and AOIC that are used to determine what data actually goes into eCase.
eCase enables ACDS to electronically receive and store case files from the Databases of ERCS and AOIC. A separate ERCS database called exam 601 was created by the ERCS development team specifically as a means of consolidating the information for all the Appeals-bound case information from the 17 separate databases that make up ERCS. The data copied from the 17 other ERCS databases to exam 601 is electronically copied to eCase to ensure no data is altered within ERCS itself. For AOIC, specific queries have been written by the AOIC development team to push copies of the Appeals-bound data to eCase, to prevent data from being altered in AOIC. ERCS data is provided by SB/SE; AOIC data is provided by W&I and SB/SE. ERCS and AOIC are owned by SB/SE.
B. Taxpayer – A sample Cases Inventory Screen and a Case Return Screen are provided in IRM Exhibits 8.20.3-9 and 8.20.3.10 respectively. No data elements are received directly from the taxpayer at the time the case is received. The tax return information is input from the Admin file/case file. Throughout the life of the Appeals case, the taxpayer may provide additional information such as power of attorney, statute extension, and/or an agreement (i.e., for tax liability, innocent spouse claim, etc.). Data in ACDS is updated accordingly.
C. Employee – Only the employee’s UserID is attached to the taxpayer record.
D. Other Federal Agencies – N/A
E. State and Local Agencies – N/A
F. Other third party sources – N/A
3. Is each data item required for the business purpose of the system? Explain.
Yes. The identified data elements are needed to control cases during the unassigned period; control and track cases in inventory until final closing; for statute control; to record key actions taken as the case moves through the Appeals process; to record appeals officer/settlement officer and tax computation specialist time applied to cases, status of a case, etc; and to track issues through Cases & Issues Reporting System (CIRS) (a subsystem of ACDS). The purpose of CIRS is to track issues on Coordinated Industry Cases (CICs), and cases which have Industry Specialization Program (ISP) or Appeals Coordinated Issues (ACIs). A CIRS record is automatically generated when a case is input to CASES by Records as CIC, ISP or ACI. The Appeals Officers and Appeals Team Case Leaders (ATCLs) input the five largest issues, Uniform Issue Listings (UIL), adjustment amounts, Estimated Closing Date (ECD), and narratives into CIRS. At closing, the revised adjustment and Reason Code are input. Data from CASES that identifies general information about the case is systemically part of the CIRS record. ACDS users need access to all relevant portions of the tax return and tax related documents to make that independent assessment. The employee information is needed to determine that an employee with the appropriate skills and experience is assigned the case. Managers use the information in ACDS to determine which employee is assigned the case based upon the manager’s knowledge of their employee(s). The skills set tables function as background information for the manager. If an employee changes manager, the new manager uses this skills set information to assess capabilities of the employee and to plan future training. Naturally, once the manager-employee relationship has matured, the manager has no need to refer to this data.
The workload information is needed to ensure the taxpayer’s inquiry can be handled timely and to help IRS assess how well Appeals is meeting business performance measures, and employee and customer satisfaction. Workload information is certain specific information from the case which details the current status of a particular case. See Attachment 6 for a sample workload review form. In addition, the workload information identifies the number of receipts (new cases received) and inventory (cases already received for processing). Specific information is provided on the number of cases in Appeals nationwide, in the group, in individual Appeals Officer/Settlement Officer inventory, and in the work stream (i.e., category, previously called type).
The eCase enhancement electronically provides the information in ACDS if the information is originally found as part of a case coming from ERCS or AOIC. The eCase data elements are needed for the same reasons as the data elements for ACDS. The only difference is that eCase data is input into ACDS electronically from extracts from ERCS and AOIC. ERCS & AOIC are owned by SB/SE.
4. How will each data item be verified for accuracy, timeliness, and completeness?
When the Admin file/case file is sent to Appeals for a new Appeals case, it contains a cover transmittal (Form 3210) that identifies the information that is supposed to be contained in the Admin file/case file. Receipt of the information is verified and the original returned to the supplier organization function (i.e., W&I, SB/SE, TE/GE, LMSB).
Timeliness of the taxpayer record is ensured because the adversarial party to the case in Appeals is the taxpayer him/herself. The taxpayer desires timely conclusion of his actions and Appeals is driven to the same conclusion by the taxpayer’s actions. Statute of limitations for each case also ensures timely action by all parties. In addition, Case Processors/Tax Examiners do not accept into Appeals any case where information is incomplete. Finally, ACDS reports monitor length of time in the Appeals process for cases. These reports drive Appeals Officers/Settlement Officers and management alike to reduce overage cases.
eCase receives notice from ERCS and AOIC on the number of records that will be transmitted/loaded before the transmission begins. eCase has a Load Results Log that time stamps each load and identifies the number of records received. A comparison is done against the initial notification to verify if the load was complete. ERCS and AOIC are notified if there is a discrepancy for resolution.
For both ACDS and eCase, the accuracy and timeliness of the data is verified by the Case Processors/Tax Examiners, Appeals Officers/Settlement Officers, or Appeals Collection Specialists (screeners) who are assigned the case. They physically review the data in ACDS and eCase and compare it to the incoming paper documents received in the Admin file/case file. When there are inaccuracies, they advise the Processing Section of the corrections that need to be made to the data in ACDS. In addition, the Appeals Team Managers (ATMs) in workload reviews, further ensure the accuracy of the ACDS data.
5. Is there another source for the data? Explain how that source is or is not used.
No. The Admin file/case file from the supplier organization (i.e., W&I, SB/SE, TE/GE, LMSB) constitutes the basis of the work of Appeals as defined by law.
6. Generally, how will data be retrieved by the user?
In general, a Case Processor/Tax Examiner retrieves cases within a geographical area according to their assignment. Case workers retrieve cases based on those assigned to them by their manager. Once authorized in ACDS, users generally search for each needed taxpayer case by name, TIN, Work Unit Number, or Docket Number. Users who have access to taxpayer data in ACDS will have access to eCase data. It is important to note that users do not have the ability to access eCase data directly. An ACDS user must first access ACDS taxpayer data and then link to the specific eCase data available for that case.
7. Is the data retrievable by a personal identifier such as name, SSN, or other unique identifier?
Yes, ACDS user interface allows search for taxpayer data by name, TIN, Work Unit Number or Docket Number. Taxpayer Name and TIN can both be used as search criteria to ascertain whether a particular case can be found in eCase.
Access to the Data
8. Who will have access to the data in the system (Users, Managers, System Administrators, Developers, Others)?
Only Appeals employees, e.g., Case Processors/Tax Examiners, Appeals Team Managers, Appeals Officers, Settlement Officers, Technical Analysts, System Administrators, and National Office Appeals employees and Staff. Case Processors/Tax Examiners will see and can update all taxpayer information for all cases within that employee’s office. Case workers such as Appeals Officers, Settlement Officers, and Technical Analysts will see and can update all information for cases assigned to them. Case workers, however, cannot update primary case information such as taxpayer name, taxpayer identification number (TIN), and other fields at the case level. Case workers are able to update address and phone number information, status code for the case, and time and action information taken in the course of working the case. All other users will have limited view only access to information in their assigned geographic location. Access permissions are defined for verified ACDS users and are also utilized by eCase.
Developers of ACDS have a completely independent development environment to develop, test, and debug ACDS operations.
9. How is access to the data by a user determined and by whom?
Appeals executives determine the level of access which is documented with Form 5081, via either paper document or the On-line 5081 process. Since the eCase data supplements the current data found in ACDS, it adheres to the same access levels.
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. Operating Divisions (W&I, SB/SE, TE/GE, LMSB) provide Admin files/case files (non electronic) to Appeals in the normal course of business. (See 2 A above for a description) In addition, the eCase enhancement provides electronic data from ERCS and AOIC. See Attachments 8 (tables 10.1 through 10.3) for the data elements these systems provide.
The eCase enhancement allows retrieval of data from ERCS and AOIC to automatically populate ACDS user interface fields if the Case Processor/tax examiner chooses to accept the electronic case found in eCase. See the eCase ETL Specification document for the data retrieved from ERCS and AOIC.
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?
Yes. With the proper business authorization/need to know, data runs, or specific case information can be provided. These agencies/organizations do not have access to the ACDS, or eCase databases. Specific information is provided in accordance with disclosure/privacy provisions. For example TIGTA may request information to determine if an audit should be conducted, or as part of an audit. States receive information on increases and decreases in tax as a part of a reciprocal agreement (memorandum of agreement) between the federal government and state government. The Department of Justice (DOJ) gets a case to work if the taxpayer filed the suit in District Court. DOJ may ask the IRS/Appeals if there are any cases in process on the taxpayer.
Administrative Controls of Data
13. What are the procedures for eliminating the data at the end of the retention period?
At the end of the retention period, a computer procedure is run which identifies obsoletes records that fall outside the retention period. IRM 8.20.8 identifies the retention period for Appeals records maintenance. The computer procedure which removes the records uses a “delete” command in the database engine which permanently removes the affected records. Since eCase is part of the overall ACDS environment eCase will adhere to the procedures defined for ACDS.
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?
These codes enable Appeals quality review personnel to look at cases and assess how well the case was settled based upon the law – i.e., court cases and the individual facts in the cases being reviewed.
In the course of Appeals’ handling of taxpayer appeals of IRS determinations from supplier operating functions (W&I, SB/SE, TE/GE, LMSB)Exam, Collections, Service Centers, ERCS, AOIC, and ACS, supplier systems B-list of codes/A-Businsess purpose(who are these supplier systems), Type codes, what do these type codes represent & how are they used?, Feature codes, Source code/Primary Business Code (PBC), and Project Code what do they represent & how are they used?, and other fields Identify the other fields are entered into ACDS which enable Appeals to identify certain broadly defined groups, e.g., Bankruptcy, Joint Committee, Abatement of Interest, etc. The purpose of these codes is to assist with assignment of cases and inventory management, reporting of performance measures, and projecting future workload. The Type Code is used to determine the type of case for management reports and assignment of cases to the proper Appeals Officer/Settlement Officer (i.e., for inventory management purposes). Feature codes are used for reporting purposes and inventory management.
Source Code/ Primary Business Code (PBC) identifies which supplier operating function the case came from. Source Code linked cases to the previous/historical IRS functions (i.e., Field Exam [FE], Coordinated Exam [CE], Collection [CO], Employee Plans, Exempt Organizations [EP/EO], and Service Center [SC]); it will go away in the future and the data element will just be PBC. Project Code records the Examination Activity Code which identifies the type and condition of a return selected for audit from AIMS (Audit Information Management System) cases.
The ACDS inventory system is taxpayer case-centric. That means ACDS is designed to access cases by case identification information such as taxpayer information identification number (TIN). This record system does not allow general access by employee information or group of employee information.
However, only the employee and his/her manager can produce a timesheet and a workload review report which details cases assigned to the employee. The timesheet is required so that the employee can report time expended information by case, and the workload review report is used by the manager to review employee progress and for management oversight.
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.
Type codes, Feature codes, and other fields are present in order to render reports. These reports are prepared in the normal course of business and are used to ensure consistent treatment of taxpayers and to monitor Appeals operations of classes of workflow. for inventory management and Appeals (i.e., business) performance management. We monitor the types of cases in order to report on business performance measures. Reports are prepared by authorized employees whose job description is to prepare these reports as part of their normal operating tasks. There are no goals or quotas for an IRS employee.
The ACDS inventory system is taxpayer case-centric. That means ACDS is designed to access cases by case identification information such as taxpayer information identification number (TIN). This record system does not allow general access by employee information or group of employee information.
However, only the employee and his/her manager can produce a timesheet and a workload review report which details cases assigned to the employee. The timesheet is required so that the employee can report time expended information by case, and the workload review report is used by the manager to review employee progress and for management oversight.
17. Can use of the system allow IRS to treat taxpayers, employees, or others, differently? Explain.
No. All taxpayers and employees in a particular code (type/feature/etc.) are treated individually, but the same per regulatory guidance and the law based upon their particular circumstances. To help ensure that taxpayers are not treated differently, IRM 1.5.4 Section 1204/Regulation 801 Guidance for Appeals indicate that there is a “prohibition against using Records Of Tax Enforcement Results (ROTERS) to evaluate or to impose or suggest production quotas or goals for an IRS employee”.
A tax enforcement result is the outcome produced by an IRS employee’s exercise of judgment in recommending or determining whether or how the Internal Revenue Service should pursue enforcement of the tax laws. To further prevent improper use of ROTERS, IRM 1.5.4.3 states, “dollar measures of performance are not part of Balanced Measures and there will be no ranking of offices”. In addition, a document, “Summary of IRS Organizational Performance Division Guidance on Sharing ROTER and Non-Roter Data” states that “under no circumstances should ROTERS be used out of context to circumvent these prohibitions.”
The codes described in the answer to Question 15 and 16 are not of a nature which would lead to disparate treatment of taxpayers. These codes in general, correspond to code sections within the IRC (Internal Revenue Code). For example, type code DPLN describes a Due Process Lien case for which handling under IRC and regulations for DPLN cases is required. For example, feature code BK describes a bankruptcy case requiring handling under bankruptcy rules and regulations. 2 of the codes, DO code and Source code, though identify locations where the case originates. These location codes are used by Appeals for business planning and performance metrics purposes. For example, there are 100 DO code locations throughout the country and are used universally throughout IRS. See IRM Exhibit 8.20.3-3, Historical District Office and Service Center Codes, for a list.
18. Does the system ensure "due process" by allowing affected parties to respond to any negative determination, prior to final action?
Yes. The very nature of the Appeals mission, to resolve taxpayer appeals of IRS determinations, ensures that ACDS will be used to provide the full extent of “due process” accorded by law. eCase will adhere to the same policies since it is a part of the overall ACDS environment.
19. If the system is web-based, does it use persistent cookies or other tracking devices to identify web visitors?
No. Appeals does not store persistent cookies. Access to ACDS is controlled by login and password procedures to ensure only authorized users are allowed in ACDS. ACDS is an internal system and can only be can only be accessed with a web browser from within the IRS Intranet. Access to eCase is only achieved through the ACDS user interface and, therefore, adheres to the mechanisms defined for ACDS since eCase is part of the overall ACDS environment.
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