Privacy Impact Assessment - Modernized Paper Pipeline Processing System (MP3)
MP3 System Overview
The Modernized Paper Pipeline Processing (MP3) System will be a stand alone, paper tax form processing system. MP3 is not a system of records and data will not be maintained or researched except to facilitate the processing of a submission.
MP3 is the modernization investment that will replace the current labor-intensive outdated paper submission processing technology and replace three existing processing hardware and software applications that currently processes paper tax-reporting forms, Federal Tax Deposits (FTD), and Information Returns:
* The Service Center Recognition Image Processing System (SCRIPS),
* The Integrated Submission and Remittance Processing (ISRP) System, and
* The Batch Block Tracking System (BBTS).
This replacement is currently planned for FY 2010.
The IRS’s MP3 project is currently in Milestone 1 of its developmental processes. The requested FY 2006 funding will be used to further the development of the concepts and foundation documents for the future MP3 system. During this funding period of system design there will be no system Releases or Pilots and no processing of any live taxpayer data or paper tax forms.
The MP3 investment will provide a modernized state-of-the-art efficient image and data extraction system through the use of commercial-off-the-shelf (COTS) integrated hardware and software. It will be certified as complying with all Federal, Treasury, and IRS rules, regulations, and standards. The MP3 investment will employ the latest Optical Character Recognition (OCR), Intelligent Character Recognition (ICR), and 2-Dimensional (2D) barcode recognition technology to capture information from over 300 different IRS tax and information submissions. MP3 will scan and create images of the paper submissions and convert that information into electronic format and extract data for efficient access by IRS users.
At this point in the system development process, the approach to the design of MP3 is to basically continue the requirements used currently by IRS, but apply modern technology to make paper processing less labor intensive and more efficient. Some manual transcription capabilities would be retained for data perfection and for limited use forms. The future standard process, however, would be that each accepted return would be:
* Scanned
* OCR/ICR’ed
* Assigned a Document Locator Number (DLN)
* Indexed by the Taxpayer Identification Number (TIN),
* Systemically “Code-and-edited”
* Converted into existing IRS proprietary Input records
* Inserted into the Return Transaction File (RTF), or its replacement
* Forwarded to General Mainframe Framework (GMF) for Pipeline processing
MP3 will eventually provide reports and data retrieval viewing for authorized IRS personnel.
Beyond this general approach, the MP3 system has yet to be designed. The MP3 processes will be more fully described in future PIAs, when system specifics become determined and detailed.
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)
No data will be collected for this funding period (FY 2006) because during FY 2006 the MP3 system will still be in its design stage and therefore will not use any real data.
In the future it is currently estimated that the MP3 system will have information available in each of the following categories:
A. Taxpayer:
The MP3 system will create images of every taxpayer paper submission. The system will extract the taxpayer data using OCR/ICR and 2D Bar Coding, then perfect the data, and prepare it for processing. MP3 will temporarily retain images of taxpayer paper tax and informational submissions (approximately 300 forms) including schedules, statements, and attachments required by law. Once the taxpayer data has been perfected, this data and images will be transferred to the appropriate IRS infrastructure system and deleted from the MP3 system.
MP3 will utilize retained taxpayer data, i.e. taxpayer entity information to support return validation. Taxpayer data would be retained to support IRS personnel in their data perfection functions, including the IRS Help Desk Personnel, Error Resolution Tax Examiners, Customer Service Representatives, and managers who require access to this data.
In alignment with current IRS practice, MP3 would eventually collect the following types of statistical and summary data:
(1) Total volume of filed paper returns for any type
(2) Volumes by District Office and Service Center
(3) Volumes of each form and schedule by submission type
(4) Number of accepted and rejected returns by District Office and Service Center
(5) Number of rejected returns by error category
(6) Number of rejected returns by form and schedule type.
Beyond this point the MP3 system has yet to be designed. This process will be described in future PIAs, when system specifics are determined and detailed.
B. Employee:
The employee’s unique identification number and audit trail information will be stored temporarily on the MP3 system. The general IRS computer system validates each employee’s login and password against the employee’s valid login and password stored by IRS. To enter the MP3 system the employee’s login would be linked to their authorized access areas, as determined by their approved form 5081. Once the employee’s authorizations are established then the employee would select an MP3 application from a list of applications he/she would be authorized to access and an audit trail would be temporarily established. Current approaches for accessing this information would be maintained.
C. Audit Trail Information (including employee log-in information)
The MP3 system would record an employee’s processing activities and statistics for gain sharing / incentive pay determinations. This data would be then transferred to the IRS organization that makes these determinations.
In Milestone 2 the application will be flagged as a tax administration application and will comply with the Taxpayer Browsing Protection Act.
D. Other
Beyond this general approach the MP3 system has yet to be designed. This process will be described in future PIAs, when system specifics are determined and detailed.
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)
Provided below are the current proposed sources that the MP3 system will obtain data from in the future:
A. IRS - Entity Index File (EIF):
Taxpayer entity information will be provided to MP3 by the EIF system, which is linked to the Social Security Administration (SSA) database. This data would be used to validate entity information on the paper tax returns. MP3 would utilize the following three types of taxpayer identifying data:
* Taxpayer Identification Number (TIN)
* Name Control.
* Address Control
B. Taxpayer – Paper Submissions
* The MP3 system will collect its information directly from paper tax returns and information documents
* A complete image will be made of every paper submission
* Only data elements currently collected will be collected from the submissions using ICR/OCR and 2D Bar Code scanning technology.
* The need for additional data will be determined by Compliance functions at a later date. There is no plan for when that determination will be made. It is expected that eventually the data collected will match that collected by the Modernized electronic filing system.
C. Employee
* In order to use the MP3 system the employee must have competed a form 5081 to obtain their login ID (name), and password
* The MP3 system security requirements will match the security requirement on any IRS system that has taxpayer data within it, including audit trails and production statistics
* Unique system specifics have yet to be designed. These requirements may need to collect additional data from employees using the system. Data details will be described in future PIAs, when system specifics are determined and detailed
D. Other Federal Agencies
* The SSA data will accessed through the EIF to validate taxpayer identifying data
E. State and Local Agencies - None
F. Other third party sources – None
3. Is each data item required for the business purpose of the system? Explain.
* Data perfection requires that each item selected fit into the requirements to determine the validity of the submission
* The data items that will be selected by MP3 will have a business purpose, which is to provide sufficient data capture to help the IRS determine whether the information providers’ and/or taxpayers’ legal obligations have been met.
4. How will each data item be verified for accuracy, timeliness, and completeness?
* MP3 system will run an internal verification check for data perfection using scanned images, OCR/ICR, 2D Bar coding, and manual checking
* The current timeliness of paper submission processing cycles will be maintained
* Beyond this point the MP3 system will allow for earlier control over the paper submission and its contents
* User requirements that will include accuracy, timeliness, and completeness will be determined and detailed in Milestone 2.
5. Is there another source for the data? Explain how that source is or is not used.
No, there is no source for the data other than the taxpayers’ paper return and form submissions
6. Generally, how will data be retrieved by the user?
* It is envisioned that the primary user for the MP3 system will be the IRS employees who will be perfecting data (when necessary) or transcribing data on selected forms. Employees perfecting data will compare the scanned images in the system taken of the paper submission with the OCR/ICR and 2D Bar code data entered in the system for that submission to determine what, if any, data input needs can be corrected without obtaining additional taxpayer-provided information. Manual data entry will continue to occur as currently done for the very low volume forms where it is not economically desirable to automate their data extraction. This system will replace the ISRP and SCRIPS processing systems, and will have limited data retrieval as those systems.
* The MP3 system design process which will specify the data retrieval methodology will be designed in Milestone 2. The current vision is that MP3’s scanned images and extracted data will be temporarily stored in an MP3 image repository and an MP3 database. When data needs to be perfected IRS employees working within the paper processing system will be able to bring up on their screen(s) both the data extracted from a paper form and its scanned image. Whenever possible data extraction errors will be corrected. Data problems needing further attention will be handled outside the MP3 system. The MP3 data and image systems are seen as temporary storage facilities with perfected data and uncorrectable submission data moving to an IRS data system as soon as practical.
7. Is the data retrievable by a personal identifier such as name, SSN, or other unique identifier?
* It is believed that data will be retrievable by TIN (SSN and EIN) and by DLN.
Access to the Data
8. Who will have access to the data in the system (Users, Managers, System Administrators, Developers, Others)?
The following may have access to data collected by the MP3 system:
IRS Employees in the paper submission processing system: The primary users of the MP3 system will be IRS employees who will use the system to perfect automatically extracted data from paper forms and enter data from very low volume paper forms where it is not economically desirable to automate their data extraction. To access the MP3 system, all employees will need to submit a form 5081. The employee's manager must approve the 5081. The back of the 5081 form lists and describes the 20 “Information Systems Security Rules” with regard to responsibilities accessing, researching, and changing data in the system, password procedures, the use of unauthorized software, disclosure, and reporting of security violations. The employee signs the 5081 indicating he or she has read the security rules and agrees to abide by them.
Contractors who are supporting the paper submission processing system: Contractors will be used to maintain the MP3 system and therefore will have access to data in the system. All contractors will have the same security clearance and security and privacy training as an IRS employee. All contractor training, including privacy awareness training will be scheduled in Milestone 2.
IRS Error Resolution Tax Examiners: IRS Tax Examiners correct errors identified by processing systems like GMF. As an aid to correcting the problem, the tax examiner would access the MP3 system to review at the scanned tax return and extracted data. The tax examiner cannot modify the MP3 return images. All corrections must be entered into the Error Resolution System.
IRS Customer Service Representatives: Customer Service Representatives (CSR) will use data and images (including MeF and MP3 generated items) to review accepted tax returns. CSRs handle taxpayer inquiries that come in over the 800 numbers. Sometimes those inquiries require the CSR to look at the validation results of taxpayer’s tax return. MP3 would be used to review returns still in process.
IRS Managers: Managers of the above types of employees have the same level of access to data as their employees. Managers can also access MP3 report data. There would be no IRS employee information on MP3. Like all employees, managers must prepare and submit a form 5081 to access this data. Like all other employees, their 5081s must be approved by their supervisors and the security officer.
IRS System Administrators: System Administrators will have access to the MP3 system to perform scheduled maintenance and other regular administrator duties. System administrators will have root access to the MP3 system. System architectural features, including system administrator functions, will be defined in Milestone 2.
IRS Security Officers: Access to MP3 data by all users will be auditable events. Each user will have a unique login and password so that all events can be audited and traced back to the source. These events will be stored in audit files and reviewed weekly by the security officer for unauthorized access to data.
IRS Database Administrators: Database Administrators (DA) will have access to the data that resides on the MP3 system to perform regular database maintenance duties. The DA will follow existing IRS standard operating procedures for database administration.
9. How is access to the data by a user determined and by whom?
In the future it is currently estimated that the following may be the procedures used to determine access to data collected by the MP3 system.
* MP3 will use current IRS access standards to set up a Role Based Access Control (RBAC) process, whereby an employee’s role (manager, data transcriber, etc.) would proscribe access to information based on based on job functions, level of responsibility, “need-to-know” and separation of duties. Thus, managers get access to data files used by their staff but a data transcriber will only get access to the data file they are currently working on or assigned. MP3’s system administrator would set up user access controls. This includes setting up the relationships between users and roles. Security Administrators will audit all users’ activities within the infrastructure and the MP3 system. The System Administrators’ managers, the Security Officers, and the MP3 system Project Officer will monitor the administrators’ access and activities.
* In addition to the above access procedures, all employees will need to submit a form 5081 to access the MP3 system. The employee's manager must approve the form 5081. The form 5081 describes the employee's responsibilities accessing, handling, and disclosing data retrieved from the system. The form 5081 provides procedures and consequences for unauthorized disclosure of tax returns or returns information. The employee signs the 5081 indicating he or she has read the security rules and agrees to abide by them.
* The IRS may hire contractors to perform system administrator duties for the MP3 system and the underlying Infrastructure components. All contractors will be required to have an appropriate background investigation. Once they have passed their background investigation, they will follow the same security procedures as an IRS employee system administrator. These procedures are contained in IRM 25.10.5, and 25.10.9.
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 system currently shares data with the MP3 system as it is still in its design stage. In the future it is envisioned that the MP3 system will be a part of the modernized electronic paperless government within the IRS. MP3 will efficiently turn paper submissions into electronic images and data and thereby eliminate the need to use costly and cumbersome paper files in the IRS. Specifically, MP3 would interface with the other Modernization assets that would most likely consist of the following:
1. Customer Account Data Engine (CADE): The project builds the modernization database foundation that will overcome barriers inherent in the existing Individual Master File (IMF) and Business Master File (BMF) database.
2. Customer Account Management (CAM): This project allows on-line posting of data in addition to daily batch processing, is the foundation for case management, workload, and case processing in the IRS.
3. Custodial Accounting Project (CAP): CAP is building an IRS integrated enterprise data warehouse that will support IRS wide data needs for performance measurement and tax operations process improvements.
4. Infrastructure Shared Services: (ISS) project provides IRS with the web infrastructure, hardware platforms, operating systems, test environment, systems development environment, and systems management capabilities.
5. Business Rules Engine (BRE): The BRE will create an enterprise-wide business rules engine, related processes, and a governance structure replacing a number of internal business rule processes.
6. The Generalized Maintenance Framework (GMF): MP3 will send transcribed fields to GMF where returns are validated and errors sent to ERS.
11. Have the IRS systems described in Item 10 received an approved Security Certification and Privacy Impact Assessment?
These IRS modernized systems are currently under development. Each has a PIA appropriate to the stage of development. All Modernization projects are being designed to meet all of IRS / Treasury’s Security and Privacy requirements. Each year as these projects’ request funds they must use the OMB Circular Exhibit 300 as their business case to accompany the IRS budget submission. These projects will not be allowed to proceed unless these requirements are met.
12. Will other agencies provide, receive, or share data in any form with this system?
No data will be provided, received, or shared with other agencies from the MP3 system. MP3 is only a processing system that provides information to other downstream systems.
Administrative Controls of Data
13. What are the procedures for eliminating the data at the end of the retention period?
It is envisioned that the MP3 system will eliminate any personally identifiable taxpayer information from its records at the end of the retention period data will be purged from the MP3 system according to standard IRS procedures – IRM 25.10.1.6.4.6 (01-01-2002).
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.
No, the MP3 system will not provide the capability to identify or locate individuals or groups. MP3 is only a processing system that provides information to other downstream systems.
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 MP3 system will not have any capability of monitoring individuals or groups. The MP3 system performs a data extraction and data perfecting function with the perfected data being sent to IRS infrastructure systems and then eventually deleted from the MP3 system.
17. Can use of the system allow IRS to treat taxpayers, employees, or others, differently? Explain.
No, the MP3 system will review all paper tax returns to determine if they adhere to published IRS submission and data requirements for the each return type. The MP3 system will apply standard IRS rules to validate data element formats and specific data requirements for each form and schedule. All returns will be reviewed against the same applicable rules.
18. Does the system ensure "due process" by allowing affected parties to respond to any negative determination, prior to final action?
* As no data will be collected for this funding period (FY 2006), the MP3 system will not make negative determinations.
* In the future, MP3 will incorporate a process to validate submissions and resolve issues found in a paper submission that must be reconciled before an account can be settled. The process will entail the systemic application of business rules to submission data to identify data problems, return processing issues, and payment issues. All identified issues and problems will be logged in tax return and account records.
* Identified issues will be resolved through a combination of manual and automated business activities that may include communicating with submitters, building business cases for IRS action, or manually or systemically correcting taxpayer account and/or return data. Issue resolution is iterative and includes Perform Validation Check, Record Identified Issue, Resolve Issue, and Complete Validation sub-processes.
* Key points for this process include:
o Taxpayers: Submission processing employees will proactively contact taxpayers to resolve certain error conditions. Communication will be performed via taxpayer preferred communication channels where possible.
o Information Providers: IRS will interact to correct errors; providers will send requested information back to IRS. Communication will be performed via information provider preferred communication channels where possible
19. If the system is web-based, does it use persistent cookies or other tracking devices to identify web visitors?
No. The MP3 system is not currently planned to be a web-based system.
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