Privacy Impact Assessment – SS-4 Program

SS-4 System Overview

The system issues Employer Identification Numbers (EIN).  An Employer Identification Number (EIN) is a nine-digit number that IRS assigns in the following format: XX-XXXXXXX. The IRS uses the number to identify taxpayers that are required to file various business tax returns. EINs are used by employers, sole proprietors, corporations, partnerships, nonprofit associations, trusts, estates of decedents, government agencies, certain individuals, and other business entities.

System of Records Number(s) 

Treasury/IRS 34.037 - IRS Audit Trail and Security Records System
Treasury/IRS 24.046 – CASE Business Master File     

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 Identification (TIN), Name Control, First Name Line, Second Name Line, Address, City, State, Zip Code, Filing Requirements, Cross Reference SSN/EIN, and Cross Reference ITIN.
B.  none
C.  none
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)

A.  IRS File XXXXXXX, IRS File XXXXXXXX and descendant files
B.  Taxpayer Identification (TIN), Name Control, First Name Line, Second Name Line, Address, City, State, Zip Code, Filing Requirements, Cross Reference SSN/EIN, and Cross Reference ITIN.
C.  none
D.  none
E.  none
F.  none

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

Each data item is required before an EIN can be assigned.

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

Form SS-4 must be complete before it is transcribed into XXXXX and verified via IDRS.

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

SS-4 Program does not collect data from sources other than IRS records and the taxpayer.

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

Data is generally retrieved by name and/or SSN/EIN.  User access is determined through the Form 5081, Information System User Registration/change Request, for designated employees as part of their official duties.

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

Data is retrievable by employees using Command Codes on IDRS by Name, SSN/EIN.

Access to the Data

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

The programmers and designated employees as part of their official duties.

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

Service Campus Management determines who will have access to SS-4 data based on the user’s position and need to know.  User access is determined through the Form 5081, Information System User Registration/change Request, for designated employees as part of their official duties.

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.  Once the EIN is assigned, data from the SS-4 is used to establish accounts on BMF Master-file if there is a filing requirement. 

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.

Administrative Controls of Data

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

After an EIN is assigned to a taxpayer and the taxpayer does not use the EIN (no activity on the account) for 8 years the account along with the EIN is dropped off the system.  Otherwise, as long as the EIN is being used to pay taxes, there is no retention period for the data.  IRS Records Disposition Handbook, IRM 1.5.29 Item 70 (Job No. NC1–58–85–10, Item 70)

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.

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.

17. Can use of the system allow IRS to treat taxpayers, employees, or others, differently?  Explain.

No.  Employee information is not kept in the system.  Treatment of all taxpayers is consistent.

18.  Does the system ensure "due process" by allowing affected parties to respond to any negative determination, prior to final action?

Yes.  Taxpayers are sent CP Notices describing the action taken or not taken for the application.  They respond by sending back the stub on the notices with the correct information.

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

Not Web-based.