Privacy Impact Assessment – Correspondence Imaging System (CIS)
CIS System Overview:
The Correspondence Imaging System (CIS) was developed in response to a need for a more efficient approach to processing and handling paper taxpayer correspondence received in the Wage & Investment (W&I) Customer Account Services (CAS) Accounts Management (AM). The CIS system is currently in production in the following W&I CAS AM sites: XXXXXXX. This system was developed for operation within IRS’s standard corporate computing infrastructure, which includes XXXX XX-based workstations, Windows 2000 Servers Tier III environment using XXX Content Manager, XXXXX, XXXXXX, and DB2 database management software (DB2). The imaging application utilizes XXXXXX software on XXXXX high volume and mid-range scanners.
The Customer Applications Development Division (CADD)/Audit Programs & Support Services Branch (APSS)/Information Management Applications Section (IMAS) partnered with XXXXXX contractors and developed the project with Commercial-off-the-Shelf (COTS) software products, supplemented by custom programming for business logic and web interfaces. XXXX XXXXX supports the imaging sub-system and is deployed on the scanner hosts. This software is used to initialize the scanner and is the mechanism by which paper is converted to images. XXX Content Manager (CM) and XX XXXXX, manages images and monitors the flow of the digital documents, respectively. Customer Service Representatives access their cases (images) via Internet Explorer and Java applets. A key capability of the XXX Content Manager software is the scalable and distributed architecture that provides an enterprise-wide catalog. The enterprise catalog provides a centralized repository to manage documents across multiple systems and sites. XXXXX also provides a distributed architecture, allowing for the deployment of scanning, indexing, and quality assurance tasks across multiple workstations per site.
System of Records Number(s):
IRS 00.001 Correspondence Files and Correspondence Control Files
IRS 24.030 CADE Individual Master File (IMF)
IRS 24.046 CADE Business Master File (BMF)
IRS 26.019 Taxpayer Delinquent Account (TDA) Files, including subsystems: (a) Adjustments and Payment Tracers Files, (b) Collateral Files, (c) Seized Property Records, (d) Tax SB/SE, W&I, LMSB Waiver, forms 900, Files, and (e) Accounts on Child Support Obligations
IRS 34.037 IRS Audit Trail and Security Records System
IRS 42.001 Examination Administrative File
IRS 42.008 Audit Information Management System (AIMS)
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 – CIS uses the following index fields to establish a CIS case and an IDRS control base:
Taxpayer Identification Number
Master File Tax code (MFT)
Name Control
Tax Period
IRS Received Date
B. Employee – Name, IRS IDRS employee number, SEID, Mail Stop, Phone number, Roles, Skill sets.
C. Audit Trail Information - CIS logs all activity in database tables, transaction logs and in application logs.
D. Other – Supporting materials, such as worksheets used for tax computations, can be uploaded to the CM repository and associated to case information.
CIS images the paper case load for the WI:CAS:AM Adjustments function which encompasses a number of categories, see Attachment 1.
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 - CIS interfaces with IDRS via a set of IDRS command codes that are executed as server side calls, as well as, through the IDRS terminal emulation session. These commands gather information from TIF, Master File and CFOL Databases. CIS also interfaces with the SACS system to authenticate users and to leverage their security model. Additionally, CIS images IRS internally generated transcripts and notices that ultimately become case work for Adjustments CSRs.
B. Taxpayer – The receipt of taxpayer generated correspondence initiates the gathering of the following index data relative to the CIS processing of cases:
* TIN
* MFT
* NAME CONTROL
* TAXPERIOD
* IRS received date
C. Employee – CIS uses the IRS domain login account to authenticate users into the application. CIS requires a 5081 for access which will contain the following employee information:
* IDRS employee number
* SEID
* Mail stop number[M1]
* Phone number
* Manager name
* Role
CSRs are profiled by their managers within CIS to include availability, skill sets and review levels.
D. Other Federal Agencies - Not Applicable
E. State and Local Agencies - Not Applicable
F. Other third party sources - Not Applicable
3. Is each data item required for the business purpose of the system? Explain.
The data items listed in section 1 and 2 are needed to control all incoming correspondence on IDRS. The stored images of all incoming correspondence are required by CSR’s to work each case file and send the appropriate interim letter or response to the taxpayer.
4. How will each data item be verified for accuracy, timeliness, and completeness?
The CIS system has the capability to recognize and provide error information to a user should there be an error in the attempt to establish an IDRS control base. All scanned images are reviewed at the point of scanning to determine quality of image, completeness of document scanned, number of pages imaged, and all associated information i.e. Taxpayer ID Number (TIN), Tax Period (TXPD), Name Control (NC), Master File Tax Code (MFT), and IRS received date.
5. Is there another source for the data? Explain how that source is or is not used.
No. IDRS is the system available to match TIN, MFT, TXPD, and NC. The paper taxpayer correspondence received in the Adjustment functions is the only source for the imaged data.
6. Generally, how will data be retrieved by the user?
CIS data is accessible by authorized users in a number of ways. Clerical support staff access imaged cases via a thick client provided by XXXXX. These users’ perfect images and index data (described above). CSRs are assigned cases via business rules and are authorized by XXXXXX check executed at distribution time. They utilize the IRS COE version of Internet Explorer, authenticate into CIS, are required to be logged into IDRS and then can opened their electronic inventories.
Other roles such as Managers, Researchers and supporting functions access CIS in much the same manner as the CSRs in terms of authentication and authorization and do not see taxpayer data until a XXXXXX check is performed on their behalf.
Researcher access may be granted for any non-inventoried user (e.g. CATA PAS, P&A Analysts) with a legitimate business need to view CIS cases. Researchers are allowed to view cases, but can take no actions other than leaving case notes. Researchers may need access in order to quality review actions taken by other authorized users, or to view information that facilitates the resolution of related cases in their functional area.
7. Is the data retrievable by a personal identifier such as name, SSN, or other unique identifier?
Scan Identification
CIS provides the ability to identify each scanned image by a uniquely assigned “image number” and the date scanned in order to facilitate the research and retrieval of the paper document at a later date. Prior to generating a print from the scanned image, the imaging system provides the ability for the user to utilize a system stamp or annotate the image number and the date and time imaged for inclusion in the print.
Query Capabilities
CIS can be primarily queried by CIS case identifier, TIN, DLN, and for specific roles, some can query by CSR number. One of these identifiers is required and results can be further refined by selecting the state of the case, MFT, Tax period, Name Control, IRS received date.
Access to the Data
8. Who will have access to the data in the system (Users, Managers, System Administrators, Developers, Others)?
Users - CIS provides the ability to allow user access based on authorizations. The following criteria will be used:
* CSRs can only view their own work and have the ability to search on specific TINs and CIS Case IDs as they relate to their specific case load.
* Managers and Work Leaders can view and reassign cases.
* ICT clerks view their ICT workload.
* PAS, CSS, CATA, and Statute inventories can only be viewed by those respective functions.
* Researchers can search by Case ID TIN, DLN.
* Super Users can view all queues and are able to remove items from error status, unlock users, unlock cases.
* Management and Correspondence Imaging project staff can have access to reports.
* System Administrators and Developers will have access to the entire system for maintenance of program code and logon/user profile assignment. [M5]System Administrator actions are logged by the system and are available for audit review.
9. How is access to the data by a user determined and by whom?
CIS was designed to meet all IRS requirements for logins and passwords and all IDRS security requirements. Cases are distributed only after a XXXX check is passed. Cases accessed via Search have a XXXXX executed when the user accesses the case. No case data will display until after the XXXXX check is passed.
The Business Unit will determine the level of access of each user, inventory levels, skill sets and distribution levels and indicate on the Form 5081. The Adjustment function management signs each Form 5081. CIS Administrators will assign each user the appropriate profile established per Section 7.
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.
CIS interfaces with the following systems: IDRS, SACS, ICP/DI.
* IDRS – CIS downloads tax modules to check for module status and to validate data. CIS uploads case control activity, interim letters, issues REQ77s and STAUPS to stop erroneous notices.
* SACS – CIS executes XXXX checks to authorize case access.
* ICP/DI – CIS writes to ICP/DI history.
11. Have the IRS systems described in Item 10 received an approved Security Certification and Privacy Impact Assessment? Yes.
12. Will other agencies provide, receive, or share data in any form with this system?
Yes. As the working tool for Customer Service Representatives, CIS may be required to share audit information with TIGTA.
Administrative Controls of Data
13. What are the procedures for eliminating the data at the end of the retention period?
CIS follows the records retention schedule as dictated by IRM 1.15.2. CIS checks daily for cases that have reached the end of their retention period. CIS destroys any case related data stored in the CIS application and COTS databases and its associated image meeting the following IRM defined retention period:
Document Types IRM 1.15.29
Description of Records
Disposition Authorizations
Correspondence
Income Tax Returns Filed by Individuals, Partnerships and Fiduciaries. These records include the Forms 1040 series, with related schedules, correspondence, audit reports, work papers and other documents attached to the return or considered a part of the administrative file, regardless of whether the documents are physically with the return or maintained in an attachment file. Destroy on or after January 16, six years after the end of the processing year unless needed for the Collection Statute Expiration Date (CSED) Extract. *
For CIS, the definition of “six years after the end of the processing year” means: Images and related case data will be purged six years after the calendar year the case was closed on CIS. (For example, the CIS case is closed on 11/19/03; the purge date is January 16, 2010.) Purging is accomplished once a year.
* Operations Assistance Request - Same criteria as “Correspondence” above.
* 1040X - Same criteria as “Correspondence” above.
* CSR Specific - Same criteria as “Correspondence” above.
* CP86 - Same criteria as “Correspondence” above.
* Duplicate Filing - Same criteria as “Correspondence” above.
* Injured Spouse Claims - Same criteria as “Correspondence” above.
* Internal Transcripts - Transcripts of Accounts requests and related documents. Destroy 5 years after end of processing year, or when no longer needed in current operations, whichever is sooner.
* NOMERGE - Same criteria as “Internal Transcripts” above.
* Carrybacks - Carryback Adjustment Cases with related schedules, supporting papers and worksheets. Destroy 10 years after end of processing year.
* Campus Specific - Same criteria as “Correspondence” above.
* Form 4442 - Same criteria as “Correspondence” above
* Quick Closures - Same criteria as “Correspondence” above
Collection Statute Expiration Date (CSED) Extract. The Revenue Reconciliation Act, effective November 5, 1990, extended the collection statute of limitations from six to ten years after assessment. Each year, a master file extract generates requests for specific BMF and IMF tax returns with open balance accounts for control DLNs only, which are scheduled to be destroyed January 16 of the following year. These returns are removed from the original accession.
For CIS Information: The master file extract creates Forms 4251 (Return Charge-Out) for documents meeting CSED criteria and sends them to the appropriate service center in late October of each year. Each center pulls these documents and extends the destruction date for the additional time required (see Disposition Authorizations for CSED). Destroy on or after January 16, ten years and nine months after April 15 of the processing year.
For CIS: The purge date for images and related case data will be extended an additional 4 years after receipt of Forms 4251 from the master file extract. (For example, the CIS case is closed on 11/19/03; the original purge date is January 16, 2010; the extended purge date is January 16, 2014.) Purging is accomplished once a year.
14. Will this system use technology in a new way? If "YES" describe. If "NO" go to Question 15.
No. This technology is currently being used in other areas of the IRS.
15. Will this system be used to identify or locate individuals or groups? If so, describe the business purpose for this capability.
CIS can identify or locate correspondence received in the Image Control Team by TIN, MFT, TXPD, Name Control, and IRS received date. The W&I Adjustment function will use this location of taxpayer correspondence in the following ways such as: reply to taxpayer requests, change of address, issuance of notices required by statute, updating of IDRS for balance due and receipt of money for taxpayer.
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.
CIS will monitor the length of time a user is on CIS, the number of cases assigned to a CSR, type of cases assigned to a CSR, status of cases assigned to a CSR, processing time for correspondence in the imaging unit.
Unauthorized monitoring will be prevented by the profile assigned to the user. Managers and Super Users will have access to reports generated by CIS. CSR’s will have access to their inventory for the purposes of working cases.
All reports generated are standard reports already being collected manually by the AM team manager. Only Systems Administrators, DBAs and CIS Application Support have access to the logged accesses. Reports are generated for daily, weekly, plan period and fiscal year periods for team, department, operation, campus and BOD levels.
Closure Report – Tracks number of cases closed/routed. Data elements:
1. Program – OFP code
2. Count Closed – Number of cases closed, by program.
3. Count Rerouted – Number of cases routed to users outside CIS workflow, by program.
4. CSR – IDRS number of CSR who closed/routed the case
5. Age – number of days from IRS received date to closed/routed date.
Controlled Inventory Report – Tracks number of cases open. Data elements:
1. Queue – Location of case within the work flow
2. CSR – IDRS assignment number for the case
3. Inventory – Total number of cases by program within the queue assigned to a given CSR
4. Program – OFP
5. Totals – Sum of the above information by queue and program
Aged Report – Tracks age of cases in a CSR’s inventory. Data elements:
1. Queue – Location of case within the work flow
2. CSR – IDRS assignment number for the case
3. Case ID – Unique Case Identifier
4. IDRS category code of assigned cases
5. IRS Received Date
6. Age – The numerical age based on the IRS received date (e.g. 29 days old)
Distribution Report – Tracks number and type of cases programmatically assigned to CSRs. Data elements:
1. CSR – IDRS assignment number for the case
2. IDRS Category Code of assigned assigned
3. Volume – Total number of cases assigned by program on a daily basis
17. Can use of the system allow IRS to treat taxpayers, employees, or others, differently? Explain.
No. Imaging of taxpayer correspondence will increase the percentage of interim letters sent out. CIS will generate interim letters on any case that meets interim letter criteria. CIS will systemically generate 2645C and 2644C letters using the Correspondex letter system, in accordance with interim letter guidelines. These letters are issued to inform the taxpayer that we have received their correspondence and we are working to resolve it. All taxpayers who seeks assistance or information and whose correspondence is scanned will be treated in the same fashion.
18. Does the system ensure "due process" by allowing affected parties to respond to any negative determination, prior to final action?
Yes. The same process currently available to the taxpayer on the manual system is also available to the taxpayer on CIS.
19. If the system is web-based, does it use persistent cookies or other tracking devices to identify web visitors?
All CIS accesses are logged with the CIS application database, as well as, the CIS application logs stored on the CIS web servers.
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