Privacy Impact Assessment - Enforcement Revenue Information System (ERIS)
The Enforcement Revenue Information System (ERIS) is classified according to FISMA as a Non-major system. ERIS tracks assessments made, revenues collected, direct hours reported, and cost incurred as a result of conducting Internal Revenue Service (IRS) enforcement activities. Until ERIS was implemented, none of the automated tracking systems used by the enforcement functions tracked enforcement cases from first enforcement action to final resolution.
I. DATA IN THE SYSTEM
1. Generally describe the information to be used in each of the following categories: Taxpayer, Employee, and Other.
ERIS receives and combines information from the Master Files (IMF,BMF, and NMF), Audit Information Management System (AIMS), Information Returns Program Case Analysis (IRPCA), Individual Return Transaction File (IRTF), and the Integrated Collection System (ICS), Business Midwest Account Compliance (BMAC), Individual Midwest Account Compliance (IMAC)
* Employee Data: User ids are cross referenced with employee name and social security number to provide information for a system audit trail that is maintained for all User Ids on system.
* Other: None.
2. What are the sources of the information in the system?
ERIS receives and combines information from the Master Files (IMF,BMF, and NMF), Audit Information Management System (AIMS), Information Returns Program Case Analysis (IRPCA), Individual Return Transaction File (IRTF), and the Integrated Collection System (ICS), Business Midwest Account Compliance (BMAC), Individual Midwest Account Compliance (IMAC)
a. What IRS files and databases are used?
IMF: PDIPW.I78093.F011.DYYYYCC
BMF: PDBPW.B78052.F011.DYYYYCC
AIMS: PDJHM.ARP##.DCCCCCC
IRPCA: PDIAM.I40713.F014.GCCCCCC
ICS: ERIPS.ICS.MMYYYY
NMF: ERISP.PDJHM.NMF17.DYYYYCC
ERISP.PDJHM.NMF28.DYYYYCC
BMAC: PDBXM.B180F#.F00#.LYYYYCCC
IMAC: PDIXM.IMAC04DD.F0**.ECCCCCC.
b. What Federal Agencies are providing data for use in the system? None
c. What State and Local Agencies are providing data for use in the system? None, ERIS data is derived from IRS systems only.
d. From what other third party sources will data be collected?
No information is obtained from third-party sources.
e. What information will be collected from the taxpayer/employee?
Employee information, collected from a management endorsed IRS Form 5081 is used to grant access to ERIS. This is a mature repeatable process. This includes:
Employee’s Name
Employee’s Social Security Number
Employee’s Work Location
3. a. How will data collected from sources other than IRS records and the taxpayer be verified for accuracy?
ERIS does not collect data from sources other than IRS records.
b. How will data be checked for completeness?
ERIS does not collect data from sources other than IRS records and therefore does not verify the data. It is the goal of ERIS to provide reports that directly reflect the information provided by the various divisions with very little or no modification.
c. Is the data current? How do you know?
ERIS collects information from IRS records. The timeliness of the data is the responsibility of the data supplier. ERIS has no facility to detect or determine currency of the data.
4. Are the data elements described in detail and documented? If yes, what is the name of the document?
The ERIS dataset structure is documented in the ERIS Data Dictionary, ERIS End-User Data Dictionary (EUDD) and the Computer Programmers Book (CPB)
II. ACCESS TO THE DATA
1. Who will have access to the data in the system (Users, Managers, System Administrators (SAs), Developers, Other)?
Enforcement Revenue Data Chief, Program Analyst, Program Analyst, Information Technology Specialist, and System Administrator(s). The following ERIS contractors have been identified as having access to the ERIS: XXXXXX and XXXXX. IRS employees as well as contractors must re complete an online 5081 and receive managerial approval before accessing the system. In addition contractors must complete a background investigation and sign a non-disclosure agreement before access is granted.
2. How is access to the data by a user determined? Are criteria, procedures, controls, and responsibilities regarding access documented?
Access to the ERIS is established through use of the IRS Form 5081. ERIS analysts control the 5081 forms for employees and contractors through MITS. Specific application and dataset permissions (Read, Write, Execute, and Search) are defined on the 5081 form. The 5081s are electronically maintained by MITS, where permissions are set/activated by MITS pending managerial approval.
3. Will users have access to all data on the system or will the user’s access be restricted? Explain.
ERIS access is restricted as detailed below:
* SAs have full access to the Read, Write, Execute, and Search access . Security controls are monitored by onsite security officers who examine audit trails and provide feedback to managers regarding security violations..
* Developers have access to identified-system and application controls necessary to develop, modify, delete, change and test applications.
* Users have access to those application form(s) and database records as established on the IRS Form 5081 for their assigned responsibilities.
4. What controls are in place to prevent the misuse (e.g. browsing) of data by those having access?
Taxpayer Browsing Protection Act, Unauthorized Access (UNAX), The Privacy Act of 1974.
5. a. Do other systems share data or have access to data in this system? If yes, explain.
ERIS has a uni-directional relationship with its data suppliers. Data sent to ERIS is never returned to its suppliers. ERIS shares summary data with the ERIS/DSS. This summary data is not taxpayer specific and contains no identifying elements that would single out a specific taxpayer or group of taxpayers.
b. Who will be responsible for protecting the privacy rights of the taxpayers and employees affected by the interface?
ERIS Management, SAs and system users are responsible for the protection of information contained in ERIS from unauthorized or unintentional disclosure or modification. Compliance with these guidelines is certified annually through audits of security guidelines and procedures.
6. a. Will other agencies share data or have access to data in this system (International, Federal, State, Local, Other)?
NO, aggregated summary information is made available to the Department of the Treasury, the Office of Management and Budget (OMB), and the General Accounting Office (GAO) in the form of reports. Occasionally taxpayer specific data is supplied to validate summary data when unexpected variances show up in the monthly data that may require taxpayer specific evaluation. Direct access to ERIS is not provided to any outside agency federal, state local or other.
b. How will the data be used by the Agency?
Treasury, OMB and GAO use the summary information provided from ERIS to verify the accuracy of IRS reporting from the enforcement functions
c. Who is responsible for assuring proper use of the data?
Director, Research Analysis & Statistics.
d. How will the system ensure that agencies only get the information they are entitled to under IRC 6103?
Not Applicable. No other agencies access the data
III. 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 data is reported to Treasury, OMB and GAO. The system was designed specifically to address the GAO concerns with the accuracy of IRS enforcement revenue estimation and tracking.
2. a. Will the system derive new data or create previously unavailable data about an individual through aggregation from the information collected?
NO, new data derived from ERIS is in aggregate form. No new data is created for individual taxpayers.
b. Will the new data be placed in the individual’s record (taxpayer or employee)?
No, ERIS does not modify the permanent records of any individual or group. ERIS takes in individual data and aggregates it into summary data separate from the taxpayers original tax record.
c. Can the system make determinations about taxpayers or employees that would not be possible without the new data?
No. ERIS does not make determinations about individual taxpayers or employees.
d. How will the new data be verified for relevance and accuracy?
Each version of ERIS is SAT tested to verify that expected results are achieved when controlled data is processed through the system. SAT test are conducted prior to each production run of the ERIS system.
3. a. If data is being consolidated, what controls are in place to protect the data from unauthorized access or use?
Users are restricted to those capabilities for which they have been granted permission via the IRS Form 5081. The action of each user is monitored by the security team at Detroit computing center and their respective sites.
b. If processes are being consolidated, are the proper controls remaining in place to protect the data and prevent unauthorized access? Explain.
Users are restricted to those capabilities for which they have been granted permission via the IRS Form 5081. The action of each user is monitored by the host platform audit functions. Other controls that are in place are: Unauthorized Access (Taxpayer Browsing Protection Act)-(UNAX) and the Office of Management and Budget (OMB) A-130.
4. How will the data be retrieved? Can it be retrieved by personal identifier? If yes, explain.
ERIS data can be retrieved by personal identifier, therefore, all users of ERIS receive RACF entries which are audited and tracked. Access to security and audit information is limited to the IRS Security Coordinators who are authorized such access. The ERIS customer has no access to the ERIS system aggregated summary data is generally provided to the customer.
a. Consolidation and linkage of files and systems:
ERIS is protected by the MITS-II security architecture.
b. Derivation of data:
ERIS receives raw data from its feeder systems the raw data is then aggregated to generate summary reports of IRS enforcement activity. The derived data is not specific to taxpayer or specific groups of taxpayers
c. Accelerated information processing and decision making:
ERIS has not received logical updates that would accelerate information processing. Recent updates to accelerate processing have been hardware based e.g. more powerful CPUs.
d. Use of new technologies:
Production enhancing technologies have not changed logical processing just physical speed.
5. How are the effects to be mitigated?
Mitigation includes test and evaluation of the operating system, and application attributes.
IV. MAINTENANCE OF ADMINISTRATIVE CONTROLS
1. a. Explain how the system and its use will ensure equitable treatment of taxpayers and employees.
ERIS data does not address individual taxpayers or employees.
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 ERIS is only operational within the XXX.
c. Explain any possibility of disparate treatment of individuals or groups.
Because the output data is summary only, the possibility of disparate treatment of individuals or groups does not exist. ERIS is an aggregate reporting system which does not directly affect tax collection procedures for individuals or groups.
2. a. What are the retention periods of data in this system?
To date, ERIS data is being retained since 1991. Data files from feeder systems are retained on the ERIS system for 1 year.
b. What are the procedures for eliminating the data at the end of the retention period? Where are the procedures documented?
There is no intention to eliminate ERIS data at this time.
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?
ERIS data is updated each time the feeder systems send new data
a. Is the system using technologies in ways that the IRS has not previously employed (e.g. Caller-ID)? No
b. How does the use of this technology affect taxpayer/employee privacy?
Not applicable.
3. a. Will this system provide the capability to identify, locate, and monitor individuals? If yes, explain.
Yes, ERIS maintains TIN information and ZIP code information. ERIS can group by zip code but no other grouping capability exist.
Audit Trails are used to monitor the actions of assigned users through the use of the User Identification (UserID) function.
b. What controls will be used to prevent unauthorized monitoring?
The action of each user can be monitored by the audit functions. Audit trails are reviewed by SAs or Security Coordinators. After the security personnel at the DCC have reviewed the audit trails they are sent to the Enforcement Revenue Data Chief for further review. UNAX.
4. a. Under which System of Record Notice (SORN) does the system operate? Provide number and name.
The Privacy Act System of Record Numbers (SORNs) for ERIS feeder systems for ERIS are as follows:
a. Treasury/IRS 24.030, CADE Individual Master File (IMF)
b. Treasury/IRS 24.046, CADE Business Master File (BMF)
c. Treasury/IRS 42.008, Audit Information Management System (AIMS)
d. Treasury/IRS 22.060, Automated Non-Master File (NMF)
e. Treasury/IRS 24.047, Audit Underreporter Case File (IRPCA)
f. Treasury/IRS 26.019, Tax Delinquent Accounts (TDA)
g. Treasury/IRS 26.020, Tax Delinquency Investigation (TDI)
h. Treasury/IRS 26.016, Return Compliance Programs (ICS)
b. If the system is being modified, will the SORN require amendment or revision? Explain. No
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