Privacy Impact Assessment - Public Transportation Subsidy Program (PTSP)

PTSP System Overview

The IRS Public Transportation Subsidy Program (PTSP) was established to encourage employees to use public transportation when commuting to and from work.  This program essentially improves air quality, reduces traffic congestion, and conserves energy by reducing the number of single occupancy vehicles on the road.

Those employees using public transportation to commute to and from work may apply for transit subsidy benefits under the IRS PTSP.  AWSS, Employee Support Services, Travel Services Branch, provides program oversight for the agency’s PTSP and administers the contract with the Dept. of Transportation.  Transit benefits are not taxable to the participant.   

Systems of Records Number(s)

Treasury .005 Public Transportation Incentive Program Records
Treasury/IRS 36.003 General Personnel and Payroll Records
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.  None
B. IRS employee who are eligible, and who voluntarily joined the program:
last name, first name, middle initial, home street address, city, state, zip code, office street address, city, state,zipcode,  SEID; name of transit company/system, and cost of each pass or fare media used. Amount of Subsidy Picked Up, Date of Pick Up, Period (month/quarter) of Pickup, Amount and Date of Returned Subsidy (if applicable)
C.  Read only database used by members of immediate staff of the PTSP using employee name or SEID.  Members of staff authorized to read the content will have logged in with password.
D.  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)

IRS:  None
Taxpayer:    None
Employee:   Eligible employees initiate the original request to join the program by completing IRS Form 11664-A (see data listed in question 1.)  Employee information is voluntarily supplied by the employee wishing to take part and is assumed correct.  Employees certify that the information is true and correct.  Employee’s manager of record approves the form before employee faxes to DOT.
Other Federal Agencies: DOT receives Form 11664-A  and processes the data; they forward the subsidy data to the PTSP manager in the IRS Travel Services Branch.  All data comes from the IRS form that the IRS employee completed, and their manager of record signed.   Downloads to the internal PTSP database comes from this form.
State, Local or Third party data:  None.

3.  Is each data item required for the business purpose of the system?  Explain.

Yes.  Only data elements that support the Public Transportation Subsidy Program are collected.  Executive Order 13150, dated April 21, 2000, and Treasury Directive 74-10, dated November 3, 2000 support PTSP and the collection of the information.

4. How will each data item be verified for accuracy, timeliness, and completeness?

Database maintenance or quality reviews are performed once a month.  The data must be assumed correct because it was submitted by the employees who joined the program.  They have ample opportunities to change information when appropriate and necessary.

5. Is there another source for the data?  Explain how that source is or is not used.

The original applications are the source documents maintained by DOT.  Source documents are reviewed to determine eligibility.

6. Generally, how will data be retrieved by the user? 

Within the internal PTSP staff by Name and/or SEID number.

7. Is the data retrievable by a personal identifier such as name, SSN, or other unique identifier? 

Yes.  Name and/or SEID.  If pulled by SEID, it is matched to the name to assure correct employee.

Access to the Data

8. Who will have access to the data in the system (Users, Managers, System Administrators, Developers, Others)?

The PTSP manager and immediate staff are the gate keepers of the data and only provide information to an employee’s manager with a need-to-know.  No contractors, system administrators, developers or others have access to the PTSP internal database.  This is an Access database created by the PTSP manager to track for reporting purposes. 

9. How is access to the data by a user determined and by whom? 

The PTSP manager receives the data from DOT, converts it into internal Access database and forwards the database to the PTSP staff.

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.  No.

11. Have the IRS systems described in Item 10 received an approved Security Certification and Privacy Impact Assessment?  N/A

12.  Will other agencies provide, receive, or share data in any form with this system?

No, unless TIGTA or GAO contacts DOT directly, they might provide certain information, within the law.  No other agency would have need to see or use data.

Administrative Controls of Data

13.  What are the procedures for eliminating the data at the end of the retention period?

The internal database is overwritten each month with updated information from DOT.  Withdrawals from the program, resignations, retirements, etc. would be removed from the database before the PTSP program receives the data.

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.

Yes.  To ensure participants are only receiving the correct subsidy in the amount they are entitled to, and that they are still eligible to be in the program.

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. The system can provide the dates and amount of subsidy picked up by each participant for the period of one year.

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.  Even when the appearance of abuse is suspected and turned over to TIGTA, TIGTA’s audit procedures include “due process.”

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.