Privacy Impact Assessment – Counsel Automated Systems Environment Management Information System (CASE-MIS)
CASE-MIS System Overview:
The Chief Counsel is the chief legal officer of the Internal Revenue Service (IRS) and serves as counsel and legal advisor to the IRS Commissioner on both non-tax legal questions and matters pertaining to the administration and enforcement of the Internal Revenue laws and related statutes. CASE-MIS provides the automated tools the Chief Counsel employees require to accomplish their official duties in the most cost-effective and efficient manner. CASE-MIS consists of a number of core functions that have been implemented on a standard hardware platform nationwide.
Current CASE-MIS functions are documented in the CASE-MIS User Handbook, and include:
CASE-TM (Technical Management Information System) is an automated system used only by National Office Chief Counsel personnel.
CASE-GL (General Litigation Automated Case Tracking System) allows users to open, update and close general litigation cases.
CASE-TR (Time Reporting System) is an administrative system to track time spent on various types of case work and supports resource allocation decisions.
CASE-IL (Uniform Issues List Tracking System) is a comprehensive list of legal issues arising from the Internal Revenue Code. The UIL is an automated tool which is used for storing, researching, and retrieving issues related to internal Revenue Code sections.
CASE-GLS (General Legal Services) is a case control and management information system for all non tax related cases including labor, contracts, ethics, etc.
CASE-CT. (Criminal Tax) is a case control and management information system for all criminal tax cases.
CASE-DL (Disclosure Litigation) is a management information system that tracks assignments and case information for disclosure litigation.
CASE-HR (Counsel Human Resources System) allows user to create or update employees for organizations they own.
CASE-LC (Apollo Large Case) is a program designed to assist Associate and Division Counsel management in collecting, managing, and retrieving large case information.
CASE-UF (User Fees) processes monetary transactions (payment or refund), associated with a “Request for Ruling” by a taxpayer(s).
CASE-AF (Attorney Fees) allows users to enter, update, delete and provide reporting on cases where attorney fees are awarded by settlement and judgement.
Systems 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 90.001 – Chief Counsel Criminal Tax Case Files
Treasury/IRS 90.002 – Chief Counsel Disclosure Litigation Case Files
Treasury/IRS 90.003 – Chief Counsel General Administrative Systems
Treasury/IRS 90.004 – Chief Counsel General Legal Services Case Files
Treasury/IRS 90.005 – Chief Counsel General Litigation Case Files
Treasury/IRS 90.007 – Chief Counsel Legislation and Regulation Division, Employee Plans and Exempt Organizations Division, and Associate Chief Counsel (Technical and International) Correspondence and Private Bill File
Treasury/IRS 90.009 – Chief Counsel Field Services Case Files
Treasury/IRS 90.010 – Digest Room Files Containing Brief, Legal Opinions, and Digests of Documents Generated Internally or by the Department of Justice Relating to the administration of the Revenue Laws.
Treasury/IRS 90.011 – Attorney Recruiting Files
Treasury/IRS 90.013 – Legal Case Files of the Chief Counsel, Deputy Chief Counsel and Associate Chief Counsels
Treasury/IRS 90.015 – Reference Records of the Library in the Office of Chief Counsel
Treasury/IRS 90.016 – Counsel Automated Tracking System (CATS) Records
Treasury/IRS 90.017 – Correspondence Control and Records, Associate Chief Counsel (Technical and International)
Treasury/IRS 90.018 – Expert Witness Library
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. CASE-MIS contains legal case information. Taxpayer data in the application includes: entity, name, SSN/TIN and may contain phone number, address, docket number, amount at issue in litigation, lien, judgment, payments, offense, forfeiture, income, and/or penalty/interest.
B. Employee data in the application includes: name, login ID, standard employee identifier (SEID); public encryption key, email address, and optional badge number and tax court bar number. For CASE-TR employee’s SSN is required.
C. CASE-MIS auditing is handled at the database level and consists of audit records for the following events:
* Logons and Logoffs
* Any action by a DBA role
* All table structure changes
* Insertions, updates, and deletions of Criminal Tax data
Each CASE-MIS audit record contains:
* Timestamp
* Username
* Operation performed or attempted
* Success or failure of the operation
A daily chron job is run to extract the audit logs stored in the database to a flat file, which is then used to create audit reports that are reviewed by the organization for suspicious activity.
D. Contact data includes Judge’s name, Department of Justice Attorney name, names of individuals that will or have testified in a court proceeding.
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. For all CASE-MIS sub-systems IRS data includes, entity, name, SSN/TIN and may contain phone number, address, amount at issue, lien, judgment, payments, offense, forfeiture, income, and/or penalty/interest.
B. For all CASE-MIS sub-systems (except CASE-TR) records can contain name, login ID, standard employee identifier (SEID); public encryption key, email address, and optional badge number and tax court bar number. For CASE-TR employee’s SSN is required.
C. Relevant sub-systems may contain name, login ID, standard employee identifier (SEID); public encryption key, email address, and optional badge number and tax court bar number. For CASE-TR, the employee’s SSN is required.
D. Dept. of Justice, for all sub-systems listed (except for CASE-TR and CASE-TM), include entity, name, SSN/TIN and may contain phone number, address, amount at issue, lien, judgment, payments, offense, forfeiture, income, and/or penalty/interest. CASE-TM may contain name and phone number of Main Treasury personnel, Labor Department, and Pension Guarantee Benefits Corporation. Additionally all CASE-MIS sub-systems (except CASE-TR and CASE-TM) may contain information from U.S. Tax Court, Federal Court or District Court on Case Number/ Docket Number, Lien judgment, payments, forfeiture.
E. No state or Local agency sources.
F. N/A
3. Is each data item required for the business purpose of the system? Explain.
Yes. The data contained in the CASE-MIS network is critical to Counsel's ability to handle taxpayer cases, correspondence, employee training records, employee personnel data and employee work schedule data. An entity may have more than one legal case before the court with different persons associated with each case, the taxpayer data provides the means to identify parties to the legal case and the persons associated with a particular case. Legal addresses, Judge’s and Chief Counsel Attorney names are needed for contacting the parties on a case before the court. Employee ID’s enable the system to identify authorized users and track access. Public Encryption Keys allow system to protect taxpayer data from unauthorized access.
4. How will each data item be verified for accuracy, timeliness, and completeness?
Information is provided by Federal Courts and IRS. Each data item is reviewed by Chief Counsel personnel for accuracy, timeliness and completeness.
5. Is there another source for the data? Explain how that source is or is not used.
No, there is no other source for the data.
6. Generally, how will data be retrieved by the user?
Data is generally accessed on-line from secure locations within the Office of Chief Counsel. Data is accessible on a need-to-know basis.
The user must enter their system identification and password to gain access to the CASE-MIS application. At that point, users can access cases that pertain to their assignments.
7. Is the data retrievable by a personal identifier such as name, SSN, or other unique identifier?
Yes, data is stored and is retrievable by a unique case number assigned by the U.S. Tax Court (for docketed cases) or by a unique system-generated case number (for non-docketed or refund litigation cases), and can also be retrieved by taxpayer name, TIN, and employee name.
Access to the Data
8. Who will have access to the data in the system (Users, Managers, System Administrators, Developers, Others)?
Offices of Chief Counsel personnel have access to CASE-MIS on a need-to-know basis as authorized by immediate managers. Users are assigned roles within each CASE-MIS sub-system. There are generally two main user roles for the sub-systems in CASE-MIS:
* User – allows users with this role to access screens and data specific to an assigned scope within the sub-system
* Coordinator – allows users with this superuser role to access all screens and data within the sub-system and assign access to other users
For certain sub-systems, there are other user roles to further delineate specific tasks and abilities within the sub-system.
Besides users, authorized database administrators also have access to the data. Developers generally only have access to data in a development environment. There are no contractors in a system administrator or database administrator role. Some CASE-MIS development is performed by one contractor who has a Moderate Risk (NACC) background investigation performed. This is the only contractor working with CASE-MIS.
9. How is access to the data by a user determined and by whom?
User access requests are authorized by management and by a select set of management analysts in the Office of Chief Counsel. Access requests are processed using the On-Line 5081 process. These management analysts determine the level of access granted to each user by the application.
Some CASE-MIS development is performed by one contractor who has a Moderate Risk (NACC) background investigation performed. This is the only contractor working with CASE-MIS.
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. Systems outside of CASE-MIS do not have physical access to CASE-MIS data. However, CASE-TYPE, CASE-DATE, Docket Number, TIN, Taxpayer Name and Address and Assigned Attorney are received from TLCATS once a day to update CASE-MIS and ensure consistent data.
11. Have the IRS systems described in Item 10 received an approved Security Certification and Privacy Impact Assessment?
TLCATS does have a current Certification and Accreditation dated March 2006, expiring March 2009.
TLCATS does have a current PIA dated June 23, 2004, expiring June 23, 2007.
12. Will other agencies provide, receive, or share data in any form with this system?
Data is provided by the Department of Justice and Federal Courts for all sub-systems except CASE-TR. CASE-TM may contain information from the Main Treasury, Labor Department, Pension Benefits Corporation, and Federal Courts. No access is given to any other agencies.
Administrative Controls of Data
13. What are the procedures for eliminating the data at the end of the retention period?
IRM 1.15.13 Records Control Schedule for the Chief Counsel
Treasury: TD P 80-05 says the Federal Records Act not only requires every Federal agency to develop and maintain an active, continuing records management program, but to also have all agency records scheduled for disposition.
The following are requirements for the records management program at the Department:
a. all bureaus records must be scheduled, regardless of form or media; b. bureaus are required to use the GRS issued by NARA for administrative records, but can request deviations;
"Permanent: records will transferred off to Washington National Records Center in 5 years blocks 25 years after closure of case
5. Closed Legal Case Files produced 1) In considering and making reports on legislation and case regulations relating to Internal Revenue matters; (2) In interpreting the Internal Revenue Code and decisions and rules promulgated in the Code of Federal Regulations; and Retire to the Washington National Records Center 6 years after the is closed. Destroy 25 years after the case is closed.
14. Will this system use technology in a new way? If "YES" describe. If "NO" go to Question 15.
No. This system does not use technology in a new way.
15. Will this system be used to identify or locate individuals or groups? If so, describe the business purpose for this capability.
Yes. CASE-MIS is used to identify individuals or groups who have filed petitions with the U.S. Tax Court or other federal courts in which the IRS is a respondent. Such cases may be identified by common case elements (i.e. tax shelter involvement, issues, etc.) in order for the Office of Chief Counsel to develop a fair and consistent litigation strategy.
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.
Generally no. CASE-MIS is not used to monitor individuals or groups other than by monitoring the cases docketed with the U.S. Tax Court and other federal courts, and monitor the amount of time employees devote to individual cases.
17. Can use of the system allow IRS to treat taxpayers, employees, or others, differently? Explain.
No. CASE-MIS is a management information system. As a result, it cannot treat taxpayers or employees disparately.
18. Does the system ensure "due process" by allowing affected parties to respond to any negative determination, prior to final action?
Not applicable. CASE-MIS does not make or track negative determinations. Additionally, this system does hinder the standard process, whereby taxpayers maintain due process rights that follow the IRS’s normal appeals process.
19. If the system is web-based, does it use persistent cookies or other tracking devices to identify web visitors? No.
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