PRIVACY IMPACT ASSESSMENT

SYSTEM OR APPLICATION NAME: Benefit Payment Operations 

DATE: September 24, 2010 

SYSTEM OWNER & TITLE: Ronald Russo 

Director of Policy and Systems 

CONTACT POINT Pauline Coleman-Sutton 

Chief of RRA Application and Calculation 

ORGANIZATION: Office of Programs – Policy and Systems 

U.S. Railroad Retirement Board 

844 North Rush Street 

Chicago, IL 60611-2092 

REVIEWING OFFICIAL NAME & TITLE Patricia Henaghan 

Chief of Information Resources Management 

ORGANIZATION: Bureau of Information Services 

Information Resources Management Center 

U.S. Railroad Retirement Board 

844 North Rush Street 

Chicago, IL 60611-2092 

PRIVACY IMPACT ANALYSIS - PAGE 1 OF 6 G-514 (7-09) 
SYSTEM OR APPLICATION NAME: Benefit Payment Operations 

DATE: SEPTEMBER 24, 2010 

Overview 

The Railroad Retirement Board’s (RRB) Benefit and Payment Operations (BPO) system pays retirement, 

survivor, social security, unemployment, sickness, and disability benefits to railroad employees and their 

families under the Railroad Retirement Act (RRA) and Railroad Unemployment Insurance Act (RUIA). 

Our beneficiaries receive retirement, survivor and social security benefits in compliance with the 

provisions of the Railroad Retirement Act. The system receives data from RRB examiners and claims 

representatives via direct and remote terminal data entry, data exchanges with the Social Security 

Administration (SSA), Department of the Treasury, and computer-generated upload files. We 

electronically transmit a secure file to the Treasury for processing and payment of monthly benefits. 

The BPO system also pays unemployment, sickness, and disability benefits to qualified railroad 

employees under the RUIA Act. Employees are qualified for a benefit year based on earnings in the 

preceding base or calendar year. RRB additionally detects fraud and abuse within the system and 

maintains a central register of unemployed railroad workers seeking referrals for vacancies within the 

railroad industry. 

The BPO system also processes sickness applications, supplemental doctor’s statements, and various 

other record updates as entered by RRB staff. The system provides us with management reports about 

the benefit programs, tax accounting reports, benefit payment files, system referrals and examiner 

activities. It also ensures that Federal income taxes are withheld from benefit payments and that 

payment and deduction data is recorded for preparation of accurate annual tax statements mailed to 

beneficiaries and tax returns transmitted to the Internal Revenue Service. 

The BPO system also establishes and maintains Medicare entitlement records for qualified (and deemed 

qualified) railroad retirement beneficiaries. We send this information by secure electronic transfer to the 

Centers for Medicare and Medicaid Services for use on its Entitlement Database. The CMS entitlement 

database is used for the payment of Medicare claims. The BPO system is also used for managing 

premium deductions for Medicare medical insurance (Part B) from monthly benefit payments, or to 

produce Part B premium due notices. Palmetto GBA, is our contractor who provides Medicare (Part B) 

support to our beneficiaries. Palmetto GBA’s information provides data to the Benefit Payment 

Operations system regarding requests for replacement Medicare cards, address changes and notices of 

beneficiary deaths. 

Section 1.0 – The Nature of the Information in the BPO System and Its Source. 

The Benefit Payment Operations system collects, processes and maintains information in order to make 

determinations to support the payment of retirement, survivor, social security, unemployment, sickness, 

and disability benefits to railroad employees and their families. Personally identifiable information is 

collected to verify the beneficiary and information necessary to submit for and process claims is collected 

and used by this information system. 

We collect earnings, evidential and medical information from railroad employers, railroad workers and 

their spouses/former spouses and dependent children. 

Section 2.0 – The Uses of the Information. 

We collect the information so we can provide railroad retirement, Social Security, survivor, 

PRIVACY IMPACT ANALYSIS - PAGE 2 OF 6 G-514 (7-09) 
SYSTEM OR APPLICATION NAME: Benefit Payment Operations 

DATE: SEPTEMBER 24, 2010 

unemployment, sickness, and disability benefits to railroad employees and their families under the 

Railroad Retirement Act and Railroad Unemployment Insurance Act. 

Our authority to collect and use information in order to administer benefits comes from the Railroad 

Retirement Act (45 U.S.C. § 231), Railroad Unemployment Insurance Act (45 U.S.C. § 351), Title 18 of 

the Social Security Act (Medicare) (42 U.S.C. § 1395), RRB’s Privacy regulations (20 C.F.R. § 200.5) and 

SSA’s Privacy regulations (20 C.F.R. § 401.) 

Section 3.0 – Retention of Information 

We base our need to retain information on what is required to provide the service for which it is collected. 

The National Records and Archives Administration reviews and approves our retention schedules. When 

the information is no longer required, we securely dispose of it. 

Section 4.0 – Internal Sharing and Disclosure of Information 

Sensitive information that we store and process on the Benefit Payment Operations major application is 

shared internally only to those authorized RRB staff members that have a valid business requirement for 

it. We have established security and privacy policies and procedures, awareness training programs and 

rules that our staff must follow when using our systems and accessing sensitive data. Our rules also 

cover what is required to disclose information and the penalties for improper disclosure. 

Section 5.0 – External Sharing and Disclosure 

We only share information as required to provide for the timely and accurate payment of benefits, debt 

recovery, reporting of employee and railroad industry earnings and service data, Medicare, child support 

and law enforcement activities. Our Privacy Act Systems of Records Notices outline what information we 

routinely share with other agencies or organizations. We have approved computer-matching agreements 

with other Federal agencies for coordinating beneficiary payments and with individual States for 

unemployment compensation benefits coordination. 

Section 6.0 – Notice 

We publish our Privacy Act Systems of Records Notices both in the Federal Register and on our web site 

(http://www.rrb.gov/bis/privacy_act/SORNList.asp). 

These notices explain: 

• What system collects and uses the information; 

• What information is collected; 

• Under what routine uses we may release that information; 

• How we store, retrieve, retain and safeguard that information; 

• What RRB official is the manager of that system; 

• The procedures to follow if you want to see or request corrections made to any information that 

system may have about you. 

We also publish a Privacy Act Notice and a Paperwork Reduction Act Notice on any form that we use to 

collect personal information from you. 

PRIVACY IMPACT ANALYSIS - PAGE 3 OF 6 G-514 (7-09) 
SYSTEM OR APPLICATION NAME: Benefit Payment Operations 

DATE: SEPTEMBER 24, 2010 

The Benefit Payments Operation system uses information that is collected and used as outlined in the 

Privacy Act System of Records Notices (SORN) listed here: 

RRB-1....Social Security Benefit Vouchering System 

RRB-3....Medicare, Part B 

RRB-4....Estimated Annuity, Total Compensation and Residual 

 Amount File 

RRB-5....Master File of Railroad Employees’ Creditable 

 Compensation 

RRB-6....Unemployment Insurance Record File 

RRB-7.... Applications for Unemployment Benefits and Placement Service Under the Railroad 

 Unemployment Insurance Act 

RRB-12...Railroad Employees' Registration File 

RRB-16...Social Security Administration Master Earnings File 

RRB-20...Health Insurance and Supplementary Medical Insurance 

 Enrollment and Premium Payment System (Medicare) 

RRB-21...Railroad Unemployment and Sickness Insurance 

 Benefit System 

RRB-22...Railroad Retirement, Survivor, and Pensioner Benefit 

 System 

RRB-51...Railroad Retirement Board's Customer PIN/Password 

 (PPW) Master File System 

RRB-55...Contact Log 

We only share that information needed to provide and manage your benefits with those RRB staff 

members or other organizations that we listed under our routine disclosures in our Privacy Act Systems 

of Records Notice on a strict need-to-know basis. We have management, operational and technical 

control safeguards in place to mitigate risks to information you provide us. 

Section 7.0 – Individual Access and Redress 

If you wish to review or request a change to the records and benefits that we maintain on you, please 

contact the nearest RRB field office for assistance. 

You may also file a request for information regarding your records in writing, including your full name, 

social security number and railroad retirement claim number (if any). Before information about any 

records will be released, you will be required to provide proof of identity, or authorization from the 

individual you are requesting records for. Send your request to Office of Programs—Director of 

Operations, Railroad Retirement Board, 844 Rush Street, Chicago, Illinois 60611-2092. 

You may also request reconsideration of any adverse determination based on information we used in 

determining your eligibility or payment for claims. We include instructions on how to file a request for 

reconsideration in all of our letters of determination. If you are not satisfied with the results of the review, 

you have the right to pursue a defined appeals process, which we explain in the reconsideration decision 

notice. 

Section 8.0 – Technical Access and Security 

Our greatest privacy risk is unauthorized access or modification of records containing sensitive 

information. We mitigate this risk by following Federal security and privacy guidance and directives. An 

PRIVACY IMPACT ANALYSIS - PAGE 4 OF 6 G-514 (7-09) 
SYSTEM OR APPLICATION NAME: Benefit Payment Operations 

DATE: SEPTEMBER 24, 2010 

independent contractor evaluated the Benefit Payment Operations system as part of its Certification and 

Accreditation process to ensure we are compliant with the appropriate security standards. 

We provide security and privacy awareness training annually to all agency system users. Before granting 

access to the Benefit Payment Operations system, new users receive training on proper use of the 

system and protecting the confidentiality of the data. We also require our users to receive additional 

training from other Federal Agencies (Social Security Administration and Centers for Medicare and 

Medicaid Services) if they are accessing information that is owned by those agencies. 

Before we grant or modify access to the Benefit Payment Operations system, our management reviews 

the request and approves it if the employee or contractor requires that level of access to perform their 

assigned job duties. Once approved by management, they forward the request to our network access 

control staff, which assigns the appropriate roles and security profile for that authorized user. We use 

established role based access control rules and follow the procedures outlined in our internal agency 

operating manual. 

We use extensive technical measures in order to provide both electronic and physical defense-in-depth 

protection for your information. Some of our safeguards are: 

 Internal policies and training addressing proper handling of sensitive information 

 Limiting access to those staff members who have a business requirement to that information 

 Information systems secured in accordance with Federal Law, National Institute of Standards and 

Technology (NIST) and other Executive Agency guidance and directives. 

 Role based access controls used to control access to electronic data records and applications 

enforcing need to know and least privilege policies 

 Transaction histories are maintained to track any changes to an individuals record 

 Encryption of all data on systems that are located outside of RRB facilities, and on our notebook 

computers 

 Encryption of all data that transits to or from the RRB network 

 Secure disposal of electronic media when it is no longer required 

 Logging of local, network, mainframe and database usage 

 In-Depth electronic security monitoring and incident response technologies and dedicated security 

staff 

 Systematic data backups performed with the backup media securely transported to, and stored at a 

Federal records holding center 

Section 9.0 – Technologies Used by the BPO System 

We validated that the Benefit Payment Operations major application meets all current Federal guidelines 

and directives via independent evaluation. Additionally, our Privacy and Security staff review all 

information system proposals in accordance with the E-Government Act of 2002 (Public Law 107-347) 

and Office of Management and Budget directives. 

Conclusion 

Our Benefit and Payment Operations major application system pays retirement, survivor, social security, 

unemployment, sickness, and disability benefits to railroad employees and their families under the 

Railroad Retirement Act (RRA) and Railroad Unemployment Insurance Act (RUIA). 

We take our obligation seriously to protect the data that we use to provide benefit services to our railroad 

PRIVACY IMPACT ANALYSIS - PAGE 5 OF 6 G-514 (7-09) 
SYSTEM OR APPLICATION NAME: Benefit Payment Operations 

DATE: SEPTEMBER 24, 2010 

workers. We do this by complying with Federal information and privacy laws, directives and guidance; by 

providing technical network defenses in depth; and by having established management and operational 

controls in place to manage our information systems. 

Certification of Responsible Officials 

Preparer Signature & Title 

Pauline Coleman-Sutton 

Chief of RRA Application and Calculation 

System Owner Signature 

Ronald Russo 

Director of Policy and Systems 

Approved Signature & Title 

Patricia Henaghan 

Chief of Information Management Resources Center 

PTA Control Number 

(if a PTA was submitted prior to PIA) 

PTA-20100616-001 

PIA Control Number PIA-20100924-001 

PRIVACY IMPACT ANALYSIS - PAGE 6 OF 6 G-514 (7-09)