Privacy and Civil Liberties Impact Assessment

Template version 5.0

Intra-governmental Payment and Collection (IPAC) 

System

June 14, 2021

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 general public via the Fiscal Service Privacy and Civil Liberties Impact Assessment (PCLIA) 

webpage (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 E-Government 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 IPAC is to ensure efficient transfer of funds across Federal Program Agencies (FPAs) –

payment and collection transfers for goods and services (i.e., buy-sell transactions), fiduciary transfers 

(i.e., investment and borrowing transactions), federal employee benefits data, and check aftermath 

activity. 

PII is used to assist the Bureau in granting users the right access to the IPAC application to perform work 

related functions based on least privilege.

It supports the mission of the Bureau by maintaining effective and efficient cash management, payment 

and collections, accounting, and reporting systems for the federal government

1. ☐ A PCLIA is being done 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 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:

• Regulatory code 12 U.S.C. 5018 and 12 U.S.C. 391

Section 2.3: 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.

5. ☐ A SORN was published and no exemptions are taken from any Privacy Act requirements.
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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: 

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.

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 
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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’s or project’s 

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.

f. ☐ Other

2. Current Federal Employees, Interns, and Detailees

☒ Current federal employees providing information in their capacity as federal 

employees (for example, PII collected using Office of Personnel Management (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.
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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

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

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.
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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.

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;

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.
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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).

e) ☐ Other

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

Number

1. ☒ Not Applicable, No SSNs are maintained in the system or by the project.

2. ☐ Full SSNs are collected, 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, 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.
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• 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.

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

1. ☒ None of the information maintained in the system or by the project 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. ☐ All ☐ Some of the PII maintained in the system or by the project is part of a system of 

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

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

3. ☐ The PII maintained in the system or by the project is not: (a) part of a system of records as 

defined in section (e)(5) of the Privacy Act; or (b) used to make adverse determinations about 

individuals (defined in the Privacy Act as U.S. Citizens and legal permanent residents).

4. ☐ None of the information 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, but the information in the system 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 

1. ☒ None of the information maintained in the system or by the project 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.

2. ☐ For all 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, ☐ other) 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

3. ☐ No additional efforts are made to ensure accuracy, relevance, timeliness, and completeness 

to the extent possible because it would interfere with mission requirements.
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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 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.

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

determinations about individuals.

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

about individuals and:

A. ☐ These records were exempted from the Privacy Act provision that requires collection 

directly from the subject individual to the greatest extent practicable.

B. ☐ These records were not exempted 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.

c) ☐ 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.

d) ☐ 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

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 is NOT used to make adverse 

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

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.

a) ☐ 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 (software that validates, updates, and 

standardizes the postal addresses in a database).

e) ☐ Other

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: http://www.treasury.gov/privacy/annual-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 datamining 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.
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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.

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).

Matching programs must be conducted pursuant to a 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 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.

2. ☐ The information 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 matching program.

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 matching program.

Section 4.3(b) Is there a matching agreement?

1. ☒ Not Applicable
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2. ☐ There is a matching agreement in place that contains the information required by Section (o) 

of the Privacy Act.

3. ☐ There is a matching agreement in place, but it does not contain all of the information 

required by Section (o) of the Privacy Act. The following actions are underway to amend the 

agreement to ensure that it is compliant.

Section 4.3(c) What procedures are followed before adverse action is taken against an 

individual who is the subject of a matching agreement search?

1. ☒ Not Applicable

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

the accuracy of the records that are used in the 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 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.

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

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

individuals external to Treasury except as authorized by the 12 exceptions in 5 U.S.C. Section 

552(a)(b)(1) thru (b)(12) (disclosures allowed without first obtaining the consent of the 

individual, including publishing applicable routine uses in the appropriate systems of records 

notices).

2. ☐ All external disclosures are authorized by the Privacy Act (including routine uses in the 

applicable SORN).
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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). 

Check toward the bottom of the 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 at: https://www.justice.gov/usam/eousa-resource-manual-139-routine-uses-andexemptions.

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 
15

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.

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 EGov 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)

1. ☐ 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).

2. ☐ The project or system involves a new collection of information in identifiable form for 10 or 

more persons from outside the federal government.

3. ☐ The project or system completed an Information Collection Request (ICR) and received OMB 

approval.

4. ☒ The project or system did not complete an Information Collection Request (ICR) and receive 

OMB approval because while the system maintains information from federal contractors, no 
16

new collection of information is required because all data are 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 the NARA 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 a SA&A and received an ATO or ATU.

3. ☐ This is a new system 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.

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.
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Section 5.4: Section 508 of the Rehabilitation Act of 1973

When federal agencies develop, procure, maintain, or use Electronic and Information Technology (EIT), 

Section 508 of the Rehabilitation Act of 1973 as amended requires that individuals with disabilities 

(including federal employees) must have access and use (including privacy policies and directives as well 

as redress opportunities) that is comparable to that which is available to individuals who do not have 

disabilities.

Section 5.4(a)

1. ☐ 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?

2. ☒ 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:

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.