Privacy and Civil Liberties Impact Assessment

Template version 6.0

Over The Counter Channel Application (OTCnet)

August 25th, 2023

Bureau Certifying Official

David J. Ambrose

Chief Security Officer and Chief Privacy Officer

Bureau of the Fiscal Service

Department of the Treasury

The mission of the Bureau of the Fiscal Service (Fiscal Service) is to promote the financial 

integrity and operational efficiency of the federal government through exceptional accounting, 

financing, collections, payments, and shared services.

This Privacy and Civil Liberties Impact Assessment (PCLIA) is a public document and will be 

made available to the public based on privacy policy. 

See all publicly viewable Fiscal Service PCLIA documents at: 

https://www.fiscal.treasury.gov/pia.html.
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Section 1: Introduction

PCLIAs are required for all systems and projects that collect, maintain, or disseminate personally 

identifiable information (PII). 

The system owner completed this assessment pursuant to Section 208 of the E-Government Act 

of 2002 (“E-Gov Act”), 44 U.S.C. § 3501, Office of the Management and Budget (OMB) 

Memorandum 03-22, “OMB Guidance for Implementing the Privacy Provisions of the EGovernment Act of 2002,” and Treasury Directive 25-07, “Privacy and Civil Liberties Impact 

Assessment (PCLIA),” which requires Treasury Offices and Bureaus to conduct a PCLIA before:

1. developing or procuring information technology (IT) systems or projects that collect, 

maintain, or disseminate PII from or about members of the public, or

2. initiating a new collection of information that: 

(a) will be collected, maintained, or disseminated using IT; and 

(b) includes any PII permitting the physical or online contacting of a specific individual, if 

identical questions have been posed to, or identical reporting requirements imposed on, 10 or 

more persons (not including agencies, instrumentalities, or employees of the federal 

government).

It is the policy of the Department of the Treasury (“Treasury” or “Department”) and its Bureaus 

to conduct a PCLIA when PII is maintained in a system or by a project. This PCLIA provides 

the following information regarding the system or project: 

1. an overview of its purpose and functions.

2. a description of the information collected.

3. a description of how information is maintained, used, and shared.

4. an assessment of whether the system or project is in compliance with federal 

requirements that support information privacy; and 

5. an overview of the redress/complaint procedures available to individuals who may be 

affected by the use or sharing of information by the system or project. 

Section 2: System Overview

Section 2.1: System/Project Description and Purpose

The purpose of the the Counter Channel Application (OTCnet) is to help Fiscal Service achieve 

improvements in cash management operations, collection mechanisms, and systems consolidation. 

PII is used to process check payments and for specific agency reporting requirements.

It supports the mission of the Bureau by collection of revenue.

1. ☐ A PCLIA is being completed for this system for the first time.
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2. ☒ This is an update of a PCLIA previously completed and published under this same 

system or project name. 

3. ☐ This is an update of a PCLIA previously completed and published for a similar system 

or project that is undergoing a substantial modification or migration to a new system or 

project name.

Section 2.2: Authority to Collect

Federal agencies must have proper authority before initiating a collection of information. The 

authority is sometimes granted by a specific statute, by Executive order (EO) of the President or 

other authority. The information may also be collected pursuant to a more general requirement or 

authority.

The following specific authorities authorize Treasury/Bureau of the Fiscal Service to collect the 

information maintained in this system:

The authorities for operating this system or performing this project are:

12 USC 90, 31 USC 321, 31 USC Ch. 33, and 31 USC 3720.

Section 2.3: Privacy Act Applicability; SORN Requirement

Under certain circumstances, federal agencies are allowed to exempt a system of records from 

certain provisions in the Privacy Act. This means that, with respect to information systems and 

papers files that maintain records in that system of records, the agency will not be required to 

comply with the requirements in Privacy Act provisions that are properly exempted. If this 

system or project contains records covered by the Privacy Act, the applicable Privacy Act system 

of records notice(s) (SORNs) (there may be more than one) that cover the records in this system 

or project must list the exemptions claimed for the system of records (it will typically say: 

“Exemptions Claimed for the System” or words to that effect).

Section 2.3(a)

1. ☐ The system or project does not retrieve records about an individual using an 

identifying number, symbol, or other identifying particular assigned to the individual.

A SORN is not required with respect to the records in this system.

2. ☒ The system or project does retrieve records about an individual using an identifying 

number, symbol, or other identifying particular assigned to the individual. 

A SORN is required with respect to the records in this system.

3. ☒ A SORN was identified in the original PCLIA and a determination was made during 

this current PCLIA update that modifications (☐ were ☒ were not) required to that 

SORN

4. ☐ A SORN(s) was not identified or required in the original PCLIA, but a determination 

was made during this current PCLIA update that a SORN(s) is now required.
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5. ☒ A SORN was published and no exemptions are taken from any Privacy Act 

requirements.

6. ☐ Exemptions are claimed from the Privacy Act provisions in the applicable SORN(s).

The following are the Privacy Act systems of records notices (SORN)s that cover the records 

maintained in this system: 

List all applicable SORN(s) here:

TREASURY/Fiscal Service .013—Collections Records

Section 3: Information Collection

Section 3.1: Relevant and Necessary

The Privacy Act requires “each agency that maintains a system of records [to] maintain in its 

records only such information about an individual as is relevant and necessary to accomplish a 

purpose of the agency required to be accomplished by statute or by executive order of the 

President.” 5 U.S.C. § 552a (e)(1). It allows federal agencies to exempt records from certain 

requirements (including the relevant and necessary requirement) under certain conditions. 5 

U.S.C. §552a (k). The proposed exemption must be described in a Notice of Proposed 

Rulemaking (“NPRM”). In the context of the Privacy Act, the purpose of the NPRM is to give 

the public notice of a Privacy Act exemption claimed for a system of records and solicit public 

opinion on the proposed exemption. After addressing any public concerns raised in response to 

the NPRM, the agency must issue a Final Rule. It is possible for some, but not all, of the records 

maintained in the system or by the project to be exempted from the Privacy Act through the 

NPRM/Final Rule process.

Section 3.1(a) Exemption Claimed from this Requirement.

1. ☒ The PII maintained in this system or by this project is not exempt from 5 U.S.C. 

§ 552a(e)(1), the Privacy Act’s requirement that an agency “maintain in its records only 

such information about an individual as is relevant and necessary to accomplish 

a purpose of the agency required to be accomplished by statute or by executive order of 

the President.”

2. ☐ The PII maintained in this system or by this project is exempt from 5 U.S.C. 

§ 552a(e)(1).

Section 3.1(b) Continuously Assessing Relevance and Necessity

1. ☐ The PII in the system is not maintained in a system of records. Therefore, the Privacy 

requirements do not apply.
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2. ☐ The PII in the system is maintained in a system of records, but the agency exempted 

these records from the relevance and necessity requirement.

3. ☒ The system owner conducted an assessment prior to collecting PII for use in the 

system or project to determine which PII data elements and types (reference the PII 

Holdings Survey) were relevant and necessary to meet the system’s or project’s mission 

requirements. In conducting the current “relevance and necessity” analysis that is 

documented in this PCLIA, the system owners reevaluated the necessity and relevance of 

all PII and determined that the data elements currently maintained are still relevant and 

necessary. Every time this PCLIA is updated, this ongoing assessment will be revisited. 

If it is determined at any time that certain PII is no longer relevant or necessary, the 

system owner will cease using the PII and update this PCLIA to discuss how the data 

element was removed from the system and is no longer used or collected.

4. ☒ With respect to PII currently maintained in the system or by the project, the PII (☒ is

☐ is not) limited to only that which is relevant and necessary to meet the system or 

project mission requirements. During the PCLIA process, the system always undergoes a 

review to ensure the continuing relevance and necessity of the PII in the system.

5. ☐ With respect to PII maintained in the system or by the project, there (☐ is ☐ is not) a 

process in place to continuously reevaluate and ensure that the PII remains relevant and 

necessary.

Section 3.2 Sources from which PII is obtained

Focusing on the context in which the data was collected and used (i.e., why it is collected and 

how it is used), check ALL sources from which PII is collected/received and stored in the 

system or used in the project.

1. Members of the Public

☒ Members of the Public (i.e., including individuals who are current federal employees 

who are providing the information in their “personal” capacity (unrelated to federal 

work/employment). All of the following are members of the public. Please check 

relevant boxes (based on the context of collection and use in this system) for 

members of the public whose information is maintained in the system (only check if 

relevant to the purpose for collecting and using the information):

a. ☒ Members of the general public (current association with the federal 

government, if any, is irrelevant to the collection and use of the 

information by the system or project).

b. ☒ Retired federal employees.

c. ☒ Former Fiscal Service employees.

d. ☒ Federal contractors, grantees, interns, detailees etc.

e. ☒ Federal job applicants.
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f. ☐ Other: [Explain here].

2. Current Federal Employees, Interns, and Detailees

☒ Current Federal employees providing information in their capacity as federal 

employees (for example, PII collected using OPM, Treasury, or Fiscal Service

forms related to employment with the federal government) 

a) ☒ Interns. 

b) ☒ Detailees.

c) ☒ Other employment-related positions.

3. Treasury Bureaus (including Departmental Offices)

☐ Other Treasury Bureaus.

4. Other Federal Agencies

☐ Other federal agencies.

5. State and Local Agencies

☐ State and local agencies.

6. Private Sector

☐ Private sector organizations (for example, banks and financial organizations, 

data brokers or other commercial sources).

7. Other Sources

☐ Other sources not covered above (for example, foreign governments).

Section 3.3: Privacy and/or civil liberties risks related to collection

When Federal agencies request information from an individual that will be maintained in a 

system of records, they must inform the individual of the following: “(A) the authority (whether 

granted by statute, or by executive order of the President) which authorizes the solicitation of the 

information and whether disclosure of such information is mandatory or voluntary; (B) the 

principal purpose or purposes for which the information is intended to be used; (C) the routine 

uses which may be made of the information, as published pursuant to paragraph (4)(D) of this 

subsection; and (D) the effects on [the individual], if any, of not providing all or any part of the 

requested information.” 5 U.S.C § 522a(e)(3). This is commonly called a Privacy Act 

Statement. The OMB Guidelines also note that subsection (e)(3) is applicable to both written 

and oral (i.e., interview) solicitations of personal information. Therefore, even if a federal 

employee or contractor has a fixed list of questions that they orally ask the individual in order to 

collect their information, this requirement applies.

Section 3.3(a) Privacy Act Statements
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1. ☒ None of the PII in the system was collected directly from the individuals to whom it 

pertains. Therefore, a Privacy Act Statement is not required.

2. ☐ Some ☐ All of the PII in the system was collected directly from the individual to 

whom it pertains. Therefore, a Privacy Act Statement was posted at the point where the 

PII was collected directly from the individual.

The Privacy Act Statement was provided to the individual:

a) ☐ on the form in which the PII was collected

b) ☐ on a separate sheet of paper that the individual could retain; or

c) ☐ in an audio recording or verbally at the point where the information was collected 

(e.g., on the phone) or

d) ☐ other: [While OTCnet does not require, nor collect, PII directly from individuals, 

by design the application stores information collected by federal agencies in User 

Defined Fields (UDF), any of which could contain PII collected directly from an 

individual, based on the agencies’ business processes and needs].

3. The Privacy Act Statement contains the following:

a) ☐ The authority (whether granted by statute, or by Executive order of the President) 

which authorizes the solicitation of the information.

b) ☐ Whether disclosure of such information is mandatory or voluntary.

c) ☐ The principal purpose or purposes for which the information is intended to be 

used.

d) ☐ The individuals or organizations outside of Treasury with whom the information 

may be/ will be shared.

e) ☐ The effects on the individual, if any, if they decide not to provide all or any part of 

the requested information.

Section 3.3(b) Use of Full Social Security Numbers

Treasury is committed to eliminating unnecessary collection, use, and display of full Social 

Security numbers (“SSN”) and redacting, truncating, and anonymizing SSNs in systems and 

documents to limit their accessibility to individuals who do not have a need to access the full 

SSN in order to perform their official duties. Moreover, the Privacy Act provides that: “It shall 

be unlawful for any Federal, State or local government agency to deny to any individual any 

right, benefit, or privilege provided by law because of such individual’s refusal to disclose his 

social security account number.” Pub. L. No. 93–579, § 7. This provision does not apply to: (1) 

any disclosure which is required by federal statute; or (2) any disclosure of an SSN to any 

federal, state, or local agency maintaining a system of records in existence and operating before 

January 1, 1975, if such disclosure was required under statute or regulation adopted prior to such 

date to verify the identity of an individual. Id. at § 7(a)(2)(A)-(B).

Section 3.3(c) Justification of Social Security Numbers & Controls implemented to limit 

access to and or improper disclosure of full Social Security Numbers

1. ☐ Full SSNs are not maintained in the system or by the project.
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2. ☒ Full SSNs are maintained in the system or by the project and the following approved 

Fiscal Service uses of SSNs apply:

a) ☐ security background investigations.

b) ☐ interfaces with external entities that require the SSN.

c) ☐ a legal/statutory basis (e.g., where collection is expressly required by statute).

d) ☒ when there is no reasonable, alternative means for meeting business 

requirements.

Note: The OTCnet application does not require collection of PII directly from an 

individual. The system contains numerous User Defined Fields (UDF), any of 

which could contain PII information based each federal agencies’ specific 

payment processing business needs

e) ☐ statistical and other research purposes.

f) ☐ delivery of government benefits, privileges, and services.

g) ☐ for law enforcement and intelligence purposes.

h) ☐ aging systems with technological limitations combined with funding limitations 

render impracticable system modifications or replacements to add privacy risk 

reduction tools (partial/truncated/redacted or masked SSNs); and

i) ☐ as a unique identifier for identity verification purposes.

3. ☒ Full SSNs are maintained in the system or by the project and the following controls 

are put in place to reduce the risk that the SSN will be seen or used by someone who does 

not have a need to use the SSN in order to perform their official duties (check ALL that 

apply):

a) ☐ The entire SSN data field is capable of suppression (i.e., being turned off) and the 

data field is suppressed when the SSN is not required for particular system users to 

perform their official duties.

b) ☐ Within the system, an alternative number (e.g., an Employee ID) is displayed to 

all system users who do not require the SSN to perform their official duties. The 

SSN is only linked to the alternative number within the system and when reporting 

outside the system (to an agency that requires the full SSN). The SSN is not visible 

to system users (other than administrators).

c) ☐ The SSN is truncated (i.e., shortened to the last 4 digits of the SSN) when 

displayed to all system users for whom the last four digits (but not the full) SSN are 

necessary to perform their official duties.

d) ☐ Full or truncated SSNs are only downloaded to spreadsheets or other documents 

for sharing within the Bureau or agency when disclosed to staff whose official duties 

require access to the full or truncated SSNs for the particular individuals to whom 

they pertain. No SSNs (full or truncated) are included in spreadsheets or documents 

unless required by each recipient to whom it is disclosed in order to perform their 

official duties (e.g., all recipients have a need to see the SSN for each employee in 

the spreadsheet).
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e) ☒ Other: OTCnet implements Role Based security to restrict individual user access 

to agency specific payment information, which may contain SSNs in user defined 

fields based on each federal agencies’ specific payment processing business needs. 

Additionally, the OTCnet DB is encrypted using Oracle Transparent Data Encryption 

(TDE).

Section 3.3(d) Denial of rights, benefits, or privileges for refusing to disclose Social Security 

Number

1. ☐ Not Applicable, No SSNs are collected directly from the individuals to whom it 

pertains by or on behalf of the system or project.

2. ☒ Full SSNs are collected directly from the individuals to whom it pertains, but no 

individual will be denied any right, benefit, or privilege provided by law if the 

individual refuses to disclose their SSN for use in the system or project.

3. ☐ Full SSNs are collected directly from the individuals to whom it pertains, and the 

individual will be denied the benefit, or privilege provided by law if they refuse to 

disclose their SSN. Denial of this right, benefit or privilege does not violate the law 

because: ☐ SSN disclosure is required by Federal statute or Executive Order.

OR

☐ The SSN is disclosed to a Federal, state, or local agency that maintains a system of 

records that was in existence and operating before January 1, 1975, and disclosure 

was required under statute or regulation adopted prior to such date to verify the 

identity of an individual.

Section 3.3(e) Records describing how individuals exercise First Amendment rights 

The Privacy Act requires that Federal agencies “maintain no record describing how any 

individual exercises rights guaranteed by the First Amendment unless expressly authorized by 

statute or by the individual about whom the record is maintained or unless pertinent to and 

within the scope of an authorized law enforcement activity.” 5 U.S.C. § 552a(e)(7).

Although the Department of the Treasury may not keep records describing how any individual 

uses First Amendment rights, in certain instances records describing First Amendment rights 

may be maintained but only if the following conditions are met:

• The law specifically authorizes it. For instance, an individual's religious affiliation is made 

known when verifying contributions above a specified amount on tax returns or describing 

contributions to tax exempt groups of which he or she is a member.

• The individual expressly authorizes it. For example, the individual provides information 

regarding experience as a group leader in a political organization to demonstrate leadership 

skills when applying for a government position.

• The record is pertinent to and within the scope of an authorized law enforcement activity in 

which political or religious activities may be used as a cover for illegal activities.

1. ☒ Not Applicable. The system or project does not maintain information describing how 

individuals exercise their rights guaranteed by the First Amendment.
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2. ☐ The system or project does maintain information describing how individuals exercise 

their rights guaranteed by the First Amendment. If you checked this box, please check

the box below that explains Fiscal Service’s authorization for collecting this information: 

a) ☐ The individual about whom the information was collected or maintained 

expressly authorized its collection/maintenance. 

b) ☐ The information maintained is pertinent to and within the scope of an authorized 

law enforcement activity.

Section 4: Maintenance, use, and sharing of the information

Section 4.1: Ensuring accuracy, completeness, and timeliness of information collected, 

maintained, and shared when it is used to make determinations about individuals

The Privacy Act and Treasury policy require that Treasury Bureaus and Offices take additional 

care when collecting and maintaining information about individuals when it will be used to make 

determinations about those individuals (e.g., whether they will receive a federal benefit). This 

includes collecting information directly from the individual where practicable and ensuring that 

the information is accurate, relevant, timely and complete to assure fairness to the individual 

when making a determination about them. This section addresses the controls/protections put in 

place to address these issues. 

The Privacy Act requires that Federal agencies “maintain all records which are used by the 

agency in making any determination about any individual with such accuracy, relevance, 

timeliness, and completeness as is reasonably necessary to assure fairness to the individual in the 

determination.” 5 U.S.C § 552a(e)(5).

If a particular system of records meets certain requirements (including the NPRM process 

defined in Section 3.1 above), an agency may exempt the system of records (or a portion of the 

records) from this requirement. Exemptions may be found at the bottom of the relevant SORN 

next to the heading: “Exemptions Claimed for this System.”

Section 4.1(a) Exemption from the accuracy, relevance, timeliness, and completeness 

requirements in section (e)(5) of the Privacy Act

Select all that apply:

1. All or some of the PII maintained in the system or by the project is part of a system of 

records as defined in section (e)(5) of the Privacy Act.

a. ☒ The PII that is part of a system of records, is not exempt from the accuracy, 

relevance, timeliness, and completeness requirements in section (e)(5) of the Privacy 

Act.

b. ☐ The PII that is part of a system of records, is exempt from the accuracy, 

relevance, timeliness, and completeness requirements in section (e)(5) of the Privacy 

Act.
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2. The PII maintained in the system or by the project is not part of a system of records as 

defined in section (e)(5) of the Privacy Act.

a. ☐ The information in the system or project is not used to make adverse 

determinations about individuals (defined in the Privacy Act as U.S. Citizens and 

legal permanent residents).

b. ☐ However, the information in the system or project is used to make adverse 

determinations about individuals (defined in the Privacy Act as U.S. Citizens and 

legal permanent residents).

Section 4.1(b) Protections in place despite exemption from the accuracy, relevance, 

timeliness, and completeness requirements

Select all that apply:

1. For information maintained in the system or by the project that is part of a system of 

records that is exempt from the accuracy, relevance, timeliness, and completeness 

requirements in section (e)(5) of the Privacy Act, the following efforts are made to 

ensure accuracy, relevance, timeliness, and completeness to the extent possible without 

interfering with the (law enforcement, intelligence, etc.) mission requirements for which 

the system or project was created:

a) ☒ The exempt information is not actually used to make any adverse determinations 

about individuals.

b) ☐ The exempt information is not actually used to make any adverse determinations 

about individuals without additional research and investigation to ensure accuracy, 

relevance, timeliness, and completeness.

c) ☐ Individuals and organizations to whom PII from the system or project is disclosed 

(as authorized by the Privacy Act) determine its accuracy, relevance, timeliness, and 

completeness in a manner reasonable for their purposes before they use it to make 

adverse determinations about individuals.

d) ☐ Individuals about whom adverse determinations are made using PII from this 

system or project are given an opportunity to explain or modify their information

(before after) the adverse determination is made. 

e) ☐ Other: (please describe):

2. ☐ For information maintained in the system or by the project that is part of a system of 

records that is exempt from the accuracy, relevance, timeliness, and completeness 

requirements in section (e)(5) of the Privacy Act, no additional efforts are made to 

ensure accuracy, relevance, timeliness, and completeness to the extent possible because 

it would interfere with mission requirements.

Section 4.1(c) Collecting information directly from the individual when using it to make 

adverse determinations about them 

Section 552a(e)(2) of the Privacy Act requires that Federal agencies that maintain records in a 

system of records are required to collect information to the greatest extent practicable directly 

from the individual when the information about them may result in adverse determinations about 
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their rights, benefits, and privileges under Federal programs. Agencies may exempt a system of 

records from this requirement under certain circumstances and if certain conditions are met.

Select all that apply:

1. ☒ The records maintained by this system or project are not used to make any adverse 

determinations about individuals’ rights, benefits, and privileges under Federal programs.

☐ The records maintained by this system or project are used to make adverse 

determinations about individuals’ rights, benefits, and privileges under Federal programs 

and:

A. ☐ These records are exempt from the Privacy Act provision that requires collection 

directly from the subject individual to the greatest extent practicable.

B. ☐ These records are not exempt from the requirement to collect information directly 

from the individual to the greatest extent practicable and 

a) ☐ All records used to make an adverse determination are collected directly from 

the individual about whom the decision is made.☐ A combination of records 

collected from third parties and directly from the individual about whom the 

determination is made are used to make the determination.

c) ☐ None of the records used to make adverse determinations are collected directly 

from the individual about whom determinations are made because seeking the 

information directly from the individual might:

1) ☐ alert the individual to the fact that their conduct is being observed or 

investigated, 

2) ☐ cause the individual to alter or modify their activities to avoid detection,

3) ☐ create risks to witnesses or other third parties if the individual is alerted to 

the fact that their conduct is being observed or investigated.

4) ☐ Other: (please describe here).

Section 4.1(d) Additional controls designed to ensure accuracy, completeness, timeliness,

and fairness to individuals in making adverse determinations

1. Administrative Controls. Individuals about whom information is collected are given the 

following opportunities to amend/correct/update their information to ensure it is accurate, 

timely and complete to the extent reasonably necessary to assure fairness when it is used 

to make a determination about them. (Treasury has published regulations in place 

describing how individuals may seek access to and amendment of their records under the 

Privacy Act. The Treasury/Bureaus FOIA and Privacy Act disclosure regulations can be 

found at 31 C.F.R. Part 1, Subtitle A, Subparts A and C.)

a) ☒ The PII collected for use in the system or project are not used to make adverse 

determinations about an individual’s rights, benefits, and privileges under federal 

programs.

b) ☐ The records maintained in the system or by the project are used to make adverse 

determinations and (☐ are ☐ are not) exempt from the access provisions in the 

Privacy Act, 5 U.S.C. 552a(d).

c) ☐ Individuals who provide their information directly to Fiscal Service for use in the 

system or by the project are provided notice of the adverse determination and an 
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opportunity to amend/correct/ update their information (☐ before ☐ after) it is used 

to make a final, adverse determination about them.

d) ☐ Individuals who provide their information directly to Fiscal Service for use in the 

system or by the project are expressly told at the point where the information is 

collected that they need to keep their information accurate, current and complete 

because it could be used to make adverse determinations about them.

e) ☐ All manual PII data entered by federal employees/contractors is verified by a 

supervisor or other data entry personnel before it is uploaded to the system (e.g., PII 

entered into the system from paper records is double-checked by someone else before 

it’s uploaded to the system).

f) ☐ Other: [please describe here].

2. Technical controls. The system or project also includes additional technical controls to 

ensure that PII is maintained with such accuracy, relevance, timeliness, and completeness 

as is reasonably necessary to assure fairness to the individual when it is used to make a 

determination about them. The following additional protections are relevant to this 

system or project:☐ No additional technical controls are available to ensure accuracy, 

relevance, timeliness, and completeness.

b) ☐ Automated data feeds are used to refresh/update the information in the system 

(where the system is reliant on updates from another system). 

c) ☐ Technical and/or administrative controls are in place to ensure that when 

information about an individual is acquired from multiple sources for maintenance in 

a single file about a particular individual, it all relates to the same individual.

d) ☐ Address verification and correction software or service is used (software that 

validates, updates, and standardizes the postal addresses in a database).

e) ☐ Other: [please describe here]

Section 4.2 Data Mining

As required by Section 804 of the Implementing Recommendation of the 9/11 Commission Act 

of 2007 (“9/11 Commission Act”), Treasury reports annually to Congress on its data mining 

activities. For a comprehensive overview of Treasury’s data mining activities, please review the 

Department’s Annual Privacy Act and Data Mining reports available at: 

https://home.treasury.gov/footer/privacy-act/privacy-reports

Section 4.2(a) Is the PII maintained in the system used to conduct data mining?

1. ☒ The information maintained in this system or by this project is not used to conduct 

data mining activities as that term is defined in the 9/11 Commission Act. Therefore, no 

privacy or civil liberties issues were identified in responding to this question.

2. ☐ The information maintained in this system or by this project is used to conduct data 

mining activities as that term is defined in the 9/11 Commission Act. This system is 

included in Treasury’s annual report to Congress which can be found on the external 

Treasury privacy website.
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3. ☐ The information maintained in this system or by this project is used to conduct data 

mining activities as that term is defined in the 9/11 Commission Act, but this system is 

not included in Treasury’s annual report to Congress which can be found on the external 

Treasury privacy website. This system will be added to the next Treasury data mining 

report to Congress.

Section 4.3 Computer Matching

The Computer Matching and Privacy Protection Act (CMPPA) of 1988 amended the Privacy Act

by imposing additional requirements when Privacy Act systems of records are used in computer 

matching programs. 

Pursuant to the CMPPA, there are two distinct types of matching programs. The first type of 

matching program involves the computerized comparison of two or more automated federal 

personnel or payroll systems of records or a system of federal personnel or payroll records with 

non-federal records. This type of matching program may be conducted for any purpose. The 

second type of matching program involves the computerized comparison of two or more 

automated systems of records or a system of records with non-federal records. The purpose of 

this type of matching program must be for the purpose of eligibility determinations or 

compliance requirements for applicants, recipients, beneficiaries, participants, or providers of 

services for payments or in-kind assistance under federal benefit programs, or recouping 

payments or delinquent debts under such federal benefit programs. See 5 U.S.C. § 522a(a)(8).

Computer matching programs must be conducted pursuant to a computer matching agreement 

between the source (the agency providing the records) and recipient agency (the agency that 

receives and uses the records to make determinations). The computer matching agreement 

describes the purpose and procedures of the matching and establishes protections for matching 

records.

Section 4.3(a) Records in the system used in a computer matching program

1. ☐ The PII maintained in the system or by the project is not part of a Privacy Act system 

of records. [If selected, Skip the remaining questions below and continue in Section 4.4]

2. ☒ The PII maintained in the system or by the project is part of a Privacy Act system of 

records but is not used as part of a computer matching program.[If selected, Skip the 

remaining questions below and continue in Section 4.4]

3. ☐ The information maintained in the system or by the project is part of a Privacy Act 

system of records and is used as part of a computer matching program.

a. ☐ There is a computer matching agreement in place that contains the information 

required by Section (o) of the Privacy Act.
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b. ☐ There is a computer matching agreement in place, but it does not contain all the 

information required by Section (o) of the Privacy Act. 

4. ☐ The Bureau or Office that owns the system or project conducted an assessment 

regarding the accuracy of the records that are used in the computer matching program 

and the following additional protections were put in place:

a. ☐ The results of that assessment were independently verified.

b. ☐ Before any information subject to the computer matching agreement is used to

suspend, terminate, reduce, or make a final denial of any financial assistance or 

payment under a federal benefit program to an individual:

i. ☐ The individual receives notice and an opportunity to contest the findings, OR

ii. ☐ The Data Integrity Board approves the proposed action with respect to the 

financial assistance or payment in accordance with Section (p) of the Privacy 

Act before taking adverse action against the individual.

5. ☐ No assessment was made regarding the accuracy of the records that are used in the 

computer matching program.

Section 4.4: Information sharing with external (i.e., outside Treasury) organizations 

and individuals

Section 4.4(a) PII shared with/disclosed to agencies, organizations, or individuals outside 

Treasury.

Sharing or disclosing PII to agencies, organizations, or individuals outside Treasury is allowed 

by subsection (b) of the Privacy Act, by routine use in the applicable SORN, by Treasury/bureau 

policy, or when required by law.

In the case of the system or project under review:

1. ☒ PII maintained in the system or project is not shared with agencies, organizations, or 

individuals external to Treasury.

2. ☐ PII maintained in the system or project is shared with agencies, organizations, or 

individuals external to Treasury.

Section 4.4(b) Accounting of Disclosures

An accounting of disclosures is a log of all external (outside Treasury) disclosures of records 

made from a system of records that has not been exempted from this accounting requirement. 

This log must either be maintained regularly or be capable of assembly in a reasonable amount of 

time after an individual makes a request. Certain system of records may be exempted from 

releasing an accounting of disclosures (e.g., in law enforcement investigations). 
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Check toward the bottom of the applicable SORN to see whether an exemption was claimed 

from 5 U.S.C. 552a(c). The NPRM and/or Final Rule for the system of records will explain why 

that exemption is appropriate.

Section 4.4(c) Making the Accounting of Disclosures Available 

1. ☐ The records are not maintained in a system of records subject to the Privacy Act, so an 

accounting is not required.

2. ☒ No external disclosures are made from the system to agencies, organizations, or 

individuals external to Treasury.

3. ☐ The Privacy Act system of records maintained in the system or by the project is

exempt from the requirement to make the accounting available to the individual named in 

the record.

4. ☐ The Privacy Act system of records maintained in the system or by the project is not

exempt from the requirement to make the accounting available to the individual named in 

the record and a log is maintained regularly. The log is maintained for at least five years 

and includes the date, nature, and purpose of each disclosure (not including intra-agency 

disclosures and FOIA disclosures) of a record to any person or to another agency (outside 

of Treasury) and the name and address of the person or agency to whom the disclosure is 

made.

5. ☐ The Privacy Act system of records maintained in the system or by the project are not 

exempt from the requirement to make the accounting available to the individual named in 

the record. A log is not maintained regularly but is capable of being constructed in a 

reasonable amount of time upon request. The information necessary to reconstruct the 

log (i.e., date, nature, and purpose of each disclosure) is maintained for at least five years. 

Section 4.4(d) Obtaining Consent Prior to New Disclosures Not Authorized by the 

Privacy Act

Records in a system of records subject to the Privacy Act may not be disclosed by any 

means of communication to any person or to another agency without the prior written 

request or consent of the individuals to whom the records pertain. 5 U.S.C. Sec. 

552a(b). However, the Act also sets forth twelve exceptions to this general restriction. 

These 12 exceptions may be viewed under: 5 U.S. Code § 552a - Records maintained 

on individuals.

Unless one of these 12 exceptions apply, the individual to whom a record pertains must provide 

their consent, where feasible and appropriate, before their records may be disclosed to anyone 

who is not listed in one of the 12 exceptions. One of these 12 exceptions also allow agencies to 

include in a notice published in the Federal Register, a list of routine uses. Routines uses are 

disclosures outside the agency that are compatible with the purpose for which the records were 

collected.
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Section 4.4(e) Obtaining Prior Written Consent

1. ☐ The records maintained in the system of records are only shared in a manner 

consistent with one of the 12 exceptions in the Privacy Act, including the 

routine uses published in the Federal Register.

2. ☐ If a situation arises where disclosure (written, oral, electronic, or mechanical)

must be made to anyone outside of Treasury who is not listed in one of the 12 

exceptions in the Privacy Act (including the published routine uses), the 

individual’s prior written consent will be obtained where feasible and 

appropriate.

Section 5: Compliance with federal information management 

requirements

Responses to the questions below address the practical, policy, and legal consequences of 

failing to comply with one or more of the following federal information management 

requirements (to the extent required) and how those risks were or are being mitigated: 

(1) the Privacy Act System of Records Notice Requirement,

(2) the Paperwork Reduction Act,

(3) the Federal Records Act,

(4) the E-Gov Act security requirements, and 

(5) Section 508 of the Rehabilitation Act of 1973.

Section 5.1: The Paperwork Reduction Act

The PRA requires OMB approval before a Federal agency may collect standardized data from 10 

or more respondents within a 12-month period. OMB also requires agencies to conduct a PIA (a 

Fiscal Service PCLIA) when initiating, consistent with the PRA, a new electronic collection of 

PII for 10 or more persons (excluding agencies, instrumentalities, or employees of the federal 

government).

Section 5.1(a) Please check ALL statements below that apply to your system or project and 

provide any additional information requested. Please read all possible responses before 

selecting an answer.

1. ☒ The system or project does not maintain information obtained from individuals and 

organizations who are not federal personnel or an agency of the federal government (i.e., 

outside the federal government).

2. ☐ The system or project maintains information obtained from individuals and 

organizations who are not federal personnel or an agency of the federal government (i.e., 

outside the federal government).
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3. ☐ The system or project completed an Information Collection Request (ICR) and 

received OMB approval. (An ICR is a set of documents that describe reporting, record 

keeping, survey, or other information collection requirements imposed on the public by a 

federal agency. The Paperwork Reduction Act stipulates that every federal agency must 

obtain approval from the Office of Management and Budget (OMB) before collecting the 

same or similar information from 10 or more members of the public.)

4. ☐ The project or system did not complete an ICR and receive OMB approval:

a. ☐ Because the PRA doesn’t apply to basic contact information such as mailing 

lists.

b. ☐ Because all data is acquired from an existing source within Treasury.

Section 5.2: Records Management - NARA/Federal Records Act Requirements

Records retention schedules determine the maximum amount of time necessary to retain 

information in order to meet the needs of the project or system. Information is generally either 

disposed of or sent to the National Archives and Records Administration (NARA) for permanent 

retention upon expiration of this period. If the system has an applicable SORN(s), check the 

“Policies and Practices for Retention and Disposal of Records” section.

Section 5.2(a)

1. ☐ The records used in the system or by the project are covered by a NARA’s 

General Records Schedule (GRS).

2. ☒ The records used in the system or by the project are covered by a NARA 

approved Treasury bureau Specific Records Schedule (SRS).

Section 5.3: E-Government Act/NIST Compliance

The completion of Federal Information Security Management Act (FISMA) Security Assessment 

& Authorization (SA&A) process is required before a federal information system may receive 

Authority to Operate (ATO) or Acceptable to Use (ATU). 

Section 5.3(a)

1. ☒ The system is a federal information system subject to FISMA requirements.

2. ☒ The system completed an SA&A and received an ATO or ATU.

3. ☐This is a new system that has not yet been authorized to operate. 

4. ☒The system or project maintains access controls to ensure that access to PII maintained 

is limited to individuals who have a need to know the information in order to perform 

their official Fiscal Service duties.
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5. ☒All Treasury/Fiscal Service security requirements are met when disclosing and 

transferring information (e.g., bulk transfer, direct access by recipient, portable disk, 

paper) from the Treasury system or project to internal or external parties.

6. ☒This system or project maintains an audit log of system users to ensure they do not 

violate the system and/or Treasury/Fiscal Service rules of behavior.

7. ☐This system or project has the capability to identify, locate, and monitor individuals or 

groups of people other than the monitoring of system users to ensure that they do not 

violate the system’s rules of behavior.

Section 5.4: Section 508 of the Rehabilitation Act of 1973

In 1998, Congress amended the Rehabilitation Act of 1973 to require Federal agencies to make 

their electronic and information technology (EIT) accessible to people with disabilities. The law 

(29 U.S.C § 794 (d)) applies to all Federal agencies when they develop, procure, maintain, or use 

electronic and information technology. Under Section 508, agencies must give disabled 

employees and members of the public access to information comparable to the access available 

to others.

Section 5.4(a)

1. ☒ The project or system will involve the development, procurement, maintenance or use 

of EIT as that term is defined in Section 508 of the Rehabilitation Act of 1973 as 

amended. If checked, select (a or b) below.

a) ☐ The system or project complies with all Section 508 requirements, thus ensuring 

that individuals with disabilities (including federal employees) have access and use 

(including access to privacy and civil liberties policies) that is comparable to that 

which is available to individuals who do not have disabilities.

b) ☒ The system or project is not in compliance with all Section 508 requirements. 

2. ☐ The project or system will not involve the development, procurement, maintenance or 

use of EIT as that term is defined in Section 508 of the Rehabilitation Act of 1973 as 

amended.