Privacy Impact Assessment – Employee Tax Compliance (ETC)
ETC System Overview
ETC is a database application designed to manage IRS employee tax compliance case inventory. ETC users will track and process employee tax compliance related cases in addition to, posting some of the cases to the Automated Labor and Employee Tracking System (ALERTS). ETC processes approximately 12,000 cases annually. Users may add, update, query, close, and maintain cases depending on their user access levels. Some cases will be disciplinary and adverse action cases. ETC provides several pre-formatted reports, customized reports, and summary or detailed listings for open cases, closed cases, and cases posted to ALERTS. Other features offered by ETC include statistical data analysis and the ability to search for specific information.
System of Records Number(s)
Treasury/IRS 34.037 IRS Audit Trail and Security Records System
Treasury/IRS 36.003 General Personnel and Payroll Records
Treasury/IRS 42.014 Internal Revenue Service Employees’ Returns Control Files
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. None.
B. The only taxpayer information used for the purpose of ETC is IRS employee tax data. These are the employees who are selected for possible non-compliance with IRS employee tax filing requirements.
Sensitive employee data contained in this system for the purpose of ETC consists of all personnel data, including:
* Employee Name (First, Middle Initial, Last)
* Employee Identification Number
* Address
* Tax period and year
* Rank code (identifies the senior employee in the case of an employee couple)
* Date of Birth (DOB)
* Enter of Duty (EOD)
* Supervisory Status (SUPV)
* Pay Plan (PP)
* Grade
* Job Series (SER)
In addition, the annual extract contains information on employee tax returns and in the case of employee couples, their spouse. The information consists of the following:
* Taxpayer’s Name
* Taxpayer’s Address
* Taxpayer’s Phone Number
* Taxpayer’s Social Security Account Number (SSAN)
* Tax Owed
* Taxpayer’s Income
IRS employees working the ETC cases.
* This data consists of Identification and Authentication (I&A) data of ETC users with access to the system. This information includes the user’s last name, first name, middle initial, social security number, job title, telephone number, Host Site name and code, IRS mailing address, mail stop, organization symbol, e-mail address, manager’s name and telephone number.
C. The system will provide audit trails that will provide the capability to identify and monitor the administrative actions within the system.
D. Other data in the system consists of the case description and/or comments from employees working the cases.
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)
The data collected includes the data items listed in 1A and 1B above.
A. The ETC System database is populated via File Transfer Protocol (FTP) tape downloads from the following IRS systems:
* TAPS – Totally Automated Personnel System (Used for personnel actions)
* TIMIS – Treasury Integrated Management Information System
* IMF – Individual Master Files
B. None
C. Information collected from the employee includes statements and/or testimony on his/her behalf.
D. National Finance Center (NFC) provides the biweekly Employee Activity Report, employee roster data and address file.
E. None.
F. No information is obtained from other third-party sources.
3. Is each data item required for the business purpose of the system? Explain.
Yes. The data used is both relevant and necessary to the purpose for which the system has been designed. IRC 6011(e)(2)(A) mandates the usage of ETC for the exact purpose in which it is used.
4. How will each data item be verified for accuracy, timeliness, and completeness?
ETC receives data from NFC biweekly. Data is received on a CD delivered by a courier. TIMIS and TAPS data is updated weekly. Records from the NFC are trusted and accepted as is.
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?
Users can retrieve data on an individual employee through use of the employee’s SSN. System controls limit access to the data within the Host Site responsible for the employee’s case. Data access is limited to those IRS employees previously granted access to the ETC System via the IRS online Form 5081.
7. Is the data retrievable by a personal identifier such as name, SSN, or other unique identifier?
Yes. ETC data is retrievable by the employee’s SSN, which is used as a unique identifier by the system. Retrieval of cases using SSN is necessary since personnel records and tax records use the SSN as the principle identifier for accounting purposes. It is the only way we can guarantee the proper identification of the employee account and that the account has been credited properly.
Access to the Data
8. Who will have access to the data in the system (Users, Managers, System Administrators, Developers, Others)?
The ETC system has identified the following users:
* Modern Information Technology Services, Corporate Local Area Network (CLAN) System Administrators and Functional Security Coordinators.
* ETC Developers, Programmers
* ETC Branch Employees
* ETC System Administrators (SAs)
* ETC Database Administrators (DBAs)
9. How is access to the data by a user determined and by whom?
Each employee’s access to the ETC System is established through use of the IRS online Form 5081. Management determines which employees are selected to work these cases. Specific permissions (Read, Write, Execute, and Search) are defined on the 5081 form and set (activated) by the SA or Functional Security Coordinator prior to the employee being allowed network and ETC system access.
A user’s position and need-to-know determines the level of access to the data. The System Manager and SA grant approval for system access. The system effectively restricts users to the level of data and functionality to which they have been granted the required authorization.
The ETC system identifies, authenticates, and authorizes users and controls appropriate user permissions to perform specific actions. The login modules will enforce access control and authorize users based on the level of access granted to them.
The following mandatory rules are defined for users of all IRS computer and information systems:
* Users are forbidden to access, research, or change any account, file, record, or application that is not required to perform official duties.
* Users are restricted from accessing their individual/spouse accounts, accounts of relatives, friends, neighbors, or any account in which the user has a personal or financial interest.
* If asked to access an account or other sensitive or private information, users are required to verify that the request is authorized and valid. Users will be held accountable if they access an unauthorized account.
* Users are required to protect passwords from disclosure.
* Users are required to log/sign off anytime they leave the computer or terminal.
* Users are required to retrieve all hard copy printouts in a timely manner.
* Users are instructed not to disclose or discuss any IRS related information with unauthorized individuals.
* Users are instructed to protect IRS employee internal work from disclosure.
Note: User’s access is restricted to the case inventory of the individual work group ONLY.
A user’s access to the data terminates when the user no longer requires access to ETC.
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.
ETC receives data from IMF, TIMIS, and HR Connect. The data received is listed in 1A and 1B above.
ETC provides data to the ALERTS. The data provided is listed in 1A and 1B above.
The ETC system can only be accessed by logging on to the IRS site LAN then into ETC. At the time of this assessment, no other systems have been identified that access or share data in the ETC 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?
Internal Revenue Manual 1.15.3.1-1 in the Record Disposition Handbook establishes how long various types of records must be retained.
14. Will this system use technology in a new way? If "YES" describe. If "NO" go to Question 15.
No. ETC is not using technologies in ways that the IRS has not previously employed.
15. Will this system be used to identify or locate individuals or groups? If so, describe the business purpose for this capability.
Yes. The ETC system contains the SSN of the employee under investigation for possible non-compliance. Using the SSN, ETC identifies and updates case files. The ETC System Audit Trails monitor the actions of assigned users working these cases through the use of the User Identification (USERID) function. The system, which houses the ETC application, provides the capability to identify and monitor users of the application.
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.
Yes. The ETC system contains the SSN of the employee under investigation for possible non-compliance. The ETC System Audit Trails monitor the actions of assigned User Groups accessing the ETC system to ensure conformance with UNAX and to monitor performance.
17. Can use of the system allow IRS to treat taxpayers, employees, or others, differently? Explain.
No. The automated system will ensure that treatment of employees is equitable.
18. Does the system ensure "due process" by allowing affected parties to respond to any negative determination, prior to final action?
Under current Tier II architecture within the DCC, the XXXXXXXXXX will also host other Tier II applications. These applications are installed on modules controlled separately from ETC through the XXXXX XXXXX (System Controller). Within the E10K, ETC data is physically partitioned according to the ETC Host Site.
ETC receives input (updates) via tape transfers from IDRS, TAPS, and TIMIS. ETC provides input (updates) via tape transfers to the ALERTS.
ETC case data originates in IMF. ETC cases are identified during an annual analysis using the employee roster data from the NFC and the IMF that resides on the XXX mainframe computer at MCC. ETC cases are identified by matching SSNs from both the IMF and the NFC. The cases that are singled out for management action are forwarded to Labor Relations and an electronic control is entered into ALERTS.
The decision making process performed by ETC must be performed to eliminate a negative impact on the due process rights of the employees. All employees, potentially non-compliant with IRS requirements for employee tax compliance, are identified and selected by the ETC system. This ensures equitable treatment for all IRS employees. Case research is accomplished using IDRS and CFOL applications. Employee letters, issued by the ETC Unit, are created using XXXXX templates and an employee address file from the NFC. After the ETC Unit processes a case, it is analyzed to see if it meets the criteria to be extracted for ALERTS. If it meets the criteria, it is extracted and electronically transmitted via FTP to the ALERTS NO programming staff.
19. If the system is web-based, does it use persistent cookies or other tracking devices to identify web visitors?
The system is not web-based.
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