Privacy Impact Assessment – Taxpayer Advocate Service Customer Satisfaction Survey

TAS Survey Overview

A transactional customer satisfaction survey is conducted by the Taxpayer Advocate Service on a continuous basis to ensure alignment of its program, policies and procedures with the needs and expectations of its customers, The purpose of the survey, which is voluntary and anonymous, is to determine the satisfaction level of taxpayers and practitioners who have recently received assistance from the Taxpayer Advocate Service (TAS).  The survey is administered by a vendor who is employed under a Blanket Purchase Agreement (long-term contract).  Prior to initiating telephone contact, the vendor sends a “prenotification letter” to approximately 20,000 randomly selected individuals and businesses each year requesting their participation. The vendor subsequently calls the individual/business and conducts a brief, structured interview.  The vendor records answers onto a database and returns the data absent specific identifying characteristics of the respondents. 

The system of records referred to in this document is that maintained by the vendor in the execution of its contractual responsibilities of identifying and interviewing a sample of taxpayers and their representatives.  The data returned by the vendor to IRS is stripped of taxpayer-specific identifying characteristics such that it would not meet the definition of system of records. The operational system from which contractor data is drawn, TAMIS, is covered by an existing systems of record notice, referenced below, and is therefore not further referenced in this document.

System of Records Number(s)

Treasury/IRS 00.003  Customer Feedback and Survey 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. Data elements provided to the vendor fall into two categories: (1) those that are essential for the vendor to perform the task of contacting prospective survey participants (viz., name, address, phone number) or to ensure accountability to the Government Task Manager for the appropriate management of the survey process (viz., case number); and (2) information about the taxpayer’s issue that enable an understanding of the context of survey responses (e.g., the issue resolved for the taxpayer, the name of the office handling the case, the number of days required to resolve the taxpayer’s issue and whether the taxpayer received relief from TAS).  Although the contractor is handling data from a Privacy Act system of records, they are not actually building and/or maintaining the system.

B. No employee information is collected.

C. There is no database maintained to which access may either be given or denied.

D. Data provided to the vendor are used for the purpose of selecting a sample and conducting the survey.  Specific identifying characteristics of taxpayers or their powers of attorney are used only for the purpose of establishing contact for the survey and for ensuring vendor accountability in the event that a taxpayer initiates an inquiry about the conduct of the survey.  All data containing specific identifying characteristics of either the taxpayer or his/her Power of Attorney (POA) responding on behalf of the taxpayer (e.g., name, address, phone number, case number, etc.) are removed by the vendor after the survey is completed and the data are returned to IRS.  The data available to IRS therefore is restricted to: (a) responses to the survey questions; and (b) case characteristics, as described above.

2. Describe/identify which data elements are obtained from files, databases, individuals, or any other sources.
A. IRS
B. Taxpayer Employee
C. Other Federal Agencies (List agency)
D. State and Local Agencies (List agency)
E. Other third party sources (Describe)

A. See response to  1(A), above.

B. The taxpayer provides contact information to IRS (viz., their name, address, phone number or that of their POA), a description of the problem they wish TAS to resolve, and responses to the voluntary survey questions.

C. No data elements are collected on employees.

D/E.  Not applicable

F.  Powers of Attorney (POAs)– the same rules apply to POAs as to taxpayers.

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

Yes.  The data provided to the vendor are required in order to construct the sample and to contact the targeted population.  The data returned by the vendor are applied systemically by TAS in evaluating the extent to which customer survey responses reflect TAS’ efforts to improve customer satisfaction.  Survey responses are applied by TAS in developing systemic improvements to better meet customer expectations.  The data results comprise a basic component of TAS’ organizational performance measurement system which entails holding TAS managers accountable for meeting customer expectations.

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

The vendor is responsible for sanitizing the data provided to IRS, viz., removing all taxpayer-specific identifying characteristics and for ensuring the subsequent validity, accuracy and completeness of the data set that is returned to IRS.

5. Is there another source for the data?  Explain how that source is or is not used.  No.

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

The vendor is responsible for limiting access to the data based on a need to know basis.  Vendor employees who conduct interviews have access only to enough information needed to initiate contact with prospective subjects of the survey (e.g., name and phone number).  Survey respondents are called by a computer’s queuing system.  Access to all case-related data are maintained by the vendor on a secure computer system to which access is restricted to the vendor’s project manager and/or the vendor’s employees (statistician/programmer) who are responsible for selecting the targeted survey population and establishing the queuing system.

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

The data provided to the vendor is retrievable by personal identifiers.  The data provided to the IRS are not retrievable by personal identifiers.

Access to the Data

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

The vendor has access to the taxpayer specific identifying data extracted from TAMIS.  The  vendor employees who have access to the data in the system are cited in the response to 6 above.

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

The vendor will sign and agree to Safeguard and Privacy Act clauses, as provided for in both the underlying IRS Blanket Purchase Agreements (BPAs) as well as in the statement of work proposed by the National Taxpayer Advocate.  The BPAs specifically include all applicable disclosure and privacy safeguard provisions addressed in the Interim Guidance on IRS Acquisition Procedures (IRSAP) dated December 23, 2002, Tax Information Security Guidelines for Federal, State and Local Agencies (Enclosure –URL) Safeguards for Protecting Federal Tax Returns and Return Information.

These documents ensure that the contractor maintains data safeguarding procedures for all IRS data designated as Federal Taxpayer Information (FTI), or as sensitive, but non-classified.

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.  However, the data returned by the vendor to IRS does not meet the definition of a system of records.  Data returned to IRS is aggregated and statistical in nature and cannot be used to identify individuals. 

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.

Administrative Controls of Data

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

The vendor is responsible for deleting data from their system one year after completion of the survey period.

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.

The data produced by this system will be used by the Taxpayer Advocate Service to identify opportunities for improvement in the services it renders to taxpayers and their representatives.  Data may be analyzed to reflect TAS work categories or specific offices where such opportunities exist. 

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.

TAS will be able to determine whether the service provided to specific groups of taxpayers (by office and work category) has been improved as a result of the collection and analysis of data.

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

The data produced by the system enables TAS to focus its improvement efforts on taxpayers whose experiences indicate relatively higher levels of dissatisfaction based on factors such as the office providing the service or the type of taxpayer issue that was addressed.

18.  Does the system ensure "due process" by allowing affected parties to respond to any negative determination, prior to final action?  Not applicable.

19.  If the system is web-based, does it use persistent cookies or other tracking devices to identify web visitors?  Not applicable.