Privacy Impact Assessment - Suspense Letter Control System (SLCS)

SLCS System Overview

The Error Resolution System (ERS) Suspense and Code and Edit (C&E) Suspense Letter Control program downloads Integrated Data Retrieval System (IDRS) letter data into a program which allows the clerical function to maintain control of up to 60,000 documents using the Social Security Number (SSN) or Employer Identification Number (EIN).  It allows the clerk to easily research the files for the matching SSN or EIN based on the batch and item number printed on the letter.  The return can be processed expeditiously thus providing better customer service and reducing interest paid to the taxpayer.

When the IDRS “C” letters are input, the typist enters a batch and item number on the letter.  Letters are input in batches of 25.  Batch number ranges differentiate ERS, C&E, Electronic Filing (ELF), and Service Center Replacement System (SCRS) suspense files.  Each night the IDRS data including the batch and item number and the Document Locator Number (DLN) are downloaded from the mainframe into the program.  Three days later batch transmittals, listing all the returns on each batch, are printed by a clerk using the SLCS program.  The batch transmittal along with the returns is filed in batch order.

When a response is returned, it can be sorted quickly by batch number, easily located, and associated with the tax return.  If the batch number is not available, research can be done on the system using the SSN or DLN to identify the batch.  After the return is pulled, the SLCS program must be updated so the return information is placed in a history file where it is kept for 60 days showing the response received date.

The system provides a purge listing when the designated suspense time has expired and no response has been received.  Since all of the documents in a batch were input on the same day, they all expire on the same day.  The batches are used in numerical order; therefore, the batches can be purged and quickly pulled from the files by batch. 

The system automatically generates the expiration date and prints it on the transmittal listing that is placed with each batch.  They are stamped NO REPLY and sent to ERS to be worked.  The system automatically puts all expired return information into the history file on the expiration date; therefore, it is not necessary to update expired returns.

Systems of Records Notice (SORN):  

 Treasury/IRS 24.062 Electronic Filing Records
 Treasury/IRS 36.003 General Personnel and Payroll Records
 Treasury/IRS 34.037 IRS Audit Trail and Security Records

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:  The Document Locator Number (DLN), Taxpayer Identification Number (TIN) (to include SSNs, IRSNs, EINs, etc.)  input date, letter date, batch number, item number, master file code, letter type, and tax period.

B.  Employee:  None.

C.  Audit Trail Information:  None.

D.  Batch number, entry date, item number, IDRS/typing, tax period, name control, letter date, expiration date, type of letter, reply, TIN, tax year, or DLN. 

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.  IRS file CRX0320.

B.  Information can NOT be collected directly from the taxpayer through the letter system.  Other than the tin, no taxpayer info. is in the letter system

C.  Information is taken from the IRS systems such as the Master File and Integrated Data Retrieval System (IDRS).

D.  None – No Federal agency other than IRS provides data for use in the application.

E.  None – No state or local agencies are providing data for use in the application.

F.  None – No third-party sources are providing data for use in the application.

3. Is each data item required for the business purpose of the system?  Explain.
 
Yes. The design of the application is to provide a systematic way to monitor Error Resolution System (ERS) and Code & Edit (C&E) returns waiting for responses from the taxpayer.

The Suspense Letter Control System (SLCS) uses the data to accomplish the following:

• Ability to monitor suspense periods systemically rather than manually.
• Easier control of suspense files by using a batch process versus a document filling system.
• Ability to file and pull returns accurately and quickly.

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

When a response to a “C” letter is returned, it will be sorted quickly by batch number, easily located, and associated with the tax return.  If the batch number is not available or correct, research can be done on the system using the Social Security Number (SSN) or DLN to identify the batch.

Data is retained in the system until a reply is received or for 37 days, but no longer than 37 days.  This ensures the data is sufficiently accurate, relevant, and timely to ensure fairness in making determinations.

The Bad Batch Listing lists all items with an incorrect batch number and/or item number.  The clerk will use the listing to enter the correct batch number and/or item number in the SLCS.

5. Is there another source for the data?  Explain how that source is or is not used.
 
No.  SLCS does not collect data from sources other than IRS records.

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

Data is retrievable by batch number, entry date, item number, IDRS/typing, tax period, name control, letter date, expiration date, type of letter, reply, TIN, tax year, or DLN. 
 
The user can query records by any of the fields mentioned here.  All records default to an “N’ in the reply field – the “N” is changed to a “Y” after a reply has been received & the record is moved from the active suspense file to the history file.

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

Yes.  Data is retrievable by batch number, entry date, item number, IDRS/typing, tax period, name control, letter date, expiration date, type of letter, reply, TIN, tax year, or DLN.

Access to the Data

8. Who will have access to the data in the system (Users, Managers, System Administrators, Developers, Others)?
 
Production users, managers, and user administrators.  These individuals are IRS employees.

Users and managers in the SLCS Units have access to data in the system.  Access to the data is determined by the manager based on a user’s position and need-to-know basis as part of his/her official duties.

Every user of the SLCS application must submit an Online 5081 (OL5081) request for access to SLCS at Enterprise Computing Center – Memphis (ECC- MEM). 

SLCS roles are as follows:

•  A production user or two will input data into the system each day.  
•  A lead will oversee the application (and serve as backup for the clerk). 
•  A manager will review the SLCS reports (and serve as backup for the lead).
• The System Administrators (SA) have access to the data, system files, and functions required to carry out their assigned tasks and responsibilities.  
•  The Treasury Inspector General for Tax Administration (TIGTA) and Government Accountability Office (GAO) in their official capacities.

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

Access to the SLCS is controlled by the SA.  The manager will request a user be given permission to access the SLCS.  They must fill out an OL5081 request to gain access to the system.  The SA determines to which group and menu the user will have access.

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, SLCS does not share data with any other system(s)/applications(s).

11. Have the IRS systems described in Item 10 received an approved Security Certification and Privacy Impact Assessment?  Not applicable.

12.  Will other agencies provide, receive, or share data in any form with this system?
 No.  SLCS does not share data with any other agency (international, federal, state, local).

Administrative Controls of Data

13.  What are the procedures for eliminating the data at the end of the retention period?
 
Records are held on the current file until either a reply is received from the taxpayer or 37 days have passed from the letter sent date and no reply has been received.

SLCS follows the policy detailed within IRM 1.15.29 for data elimination.  The records are moved from the active suspense file to the history file (via cron) if the expiration date has been reached and a reply has not been received.

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, the presence of taxpayer data, searchable by “C” letter information, makes it possible to associate data with groups of people.

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 letter system cannot be used to monitor individuals or groups.  Users are added to the Unix system via OL5081 and database permissions are granted to them based on their manager’s approval.  Access to SLCS is controlled by the SA.  The manager will request a user be added.  They must fill out an OL5081 request to gain access to the system.  The SA determines to which group and menu the user will have access.

17. Can use of the system allow IRS to treat taxpayers, employees, or others differently?  Explain.
 
No, SLCS does not contain any employee information. SLCS contains suspense correspondence data for all letters entered for ERS and C&E through the Correspondex Program.  Treatment of taxpayers will be consistent.

18.  Does the system ensure "due process" by allowing affected parties to respond to any negative determination, prior to final action?
 
No, the letter system has nothing to do with due process for taxpayers.  SLCS automates the monitoring of existing suspense periods and does not change the current due process rights of taxpayers.  Taxpayers will still have the same due process rights as outlined in the Internal Revenue Code (IRC).

19.  If the system is web-based, does it use persistent cookies or other tracking devices to identify web visitors? 

SLCS is not a web-based system.