PRIVACY IMPACT ANALYSIS - PAGE 1 OF 6 G-514 (7-09)

PRIVACY IMPACT ASSESSMENT

SYSTEM OR APPLICATION NAME: Financial Interchange System

DATE: March 21, 2012

SYSTEM OWNER & TITLE: Carl E. May

Chief, Financial Interchange Division

CONTACT POINT Carl E. May

Chief, Financial Interchange Division

ORGANIZATION: Bureau of the Actuary

U.S. Railroad Retirement Board

844 North Rush Street

Chicago, IL 60611-2092

REVIEWING OFFICIAL NAME & TITLE Charles Mierzwa

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 2 OF 6 G-514 (7-09)

SYSTEM OR APPLICATION NAME: Financial Interchange System

DATE: MARCH 21, 2012

Overview

The Railroad Retirement Board’s (RRB) Financial Interchange System estimates additional benefits and 

administrative expenses that would have been paid by the trust funds (Social Security and Railroad 

Retirement) as well as the additional payroll and income taxes. The difference between these two 

amounts is transferred, with interest, to the trust fund which is owed the larger credits. 

The Financial Interchange System consists of a 1-percent sample of present and former railroad 

employees and members of their families. Information is maintained on the earnings history of covered 

individuals, the actual payments made to them from the trust funds and the payments which would have 

been made by the trust funds if railroad employment had always been covered by the social security 

system.

The agency’s mainframe and several personal computers are used to maintain portions of the Financial 

Interchange System. Personnel in the Bureau of the Actuary are the only users of the system. The 

Financial Interchange System consists of four separate subsystems – the gross earnings subsystem, the 

employment data management subsystem, the benefit payment subsystem, and the personal computer 

subsystem.

Section 1.0 - The Nature of the Information in the Financial Interchange system and Its Source.

The Financial Interchange System uses personal and wage information from a 1% sample of present and 

former railroad workers and their families. This information is collected from existing RRB information 

systems and wage data provided by employers. Railroad workers whose social security number ends in 

“30” make up the 1% sample.

We use the following information:

• Employees: Name, Social Security Number, RRB Claim number, date of birth, wage, RRB and 

Social Security Benefit information.

• Employee family members: Name, Social Security Number, date of birth, RRB and Social 

Security Benefit payment information.

Section 2.0 - The Uses of the Information.

We collect the information so we can estimate the additional benefits and administrative expenses that 

would have been paid by the trust funds as well as the additional payroll and income taxes. The 

difference between these two amounts is transferred, with interest, to the trust fund which is owed the 

larger credits. 

Our authority to collect and use this information for each of these programs comes from United States 

Code and our agency regulations:

United States Code:

• 45 U.S.C § 231f(b)(1), Railroad Retirement Act,

• 45 U.S.C § 231f(b)(3), Railroad Retirement Act, and

• 45 U.S.C § 231f(c)(2), Railroad Retirement Act.
PRIVACY IMPACT ANALYSIS - PAGE 3 OF 6 G-514 (7-09)

SYSTEM OR APPLICATION NAME: Financial Interchange System

DATE: MARCH 21, 2012

Railroad Retirement Board Regulations: 20 CFR, Employees’ Benefits, Chapter II, Railroad Retirement 

Board.

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

We share employer provided employee gross earnings information internally with the Audit & Compliance 

Division of the Bureau of Fiscal Operations for compliance reporting purposes upon request. We keep 

our internal spreadsheets and databases saved on a dedicated network share location, with access 

limited to our business unit. We also store some information on our local computers, which have fully 

encrypted hard drives. 

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 share a statistical sample (approximately 3,000 records) with the Association of American Railroads 

(AAR) yearly for their use in wage analysis and trending. The information we provide them does not 

contain personally identifiable information and is releasable under the Privacy Act of 1974 for statistical 

research. (5 U.S.C. § 552a(b)(5)) 

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, and

• 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.

The Financial Interchange major application system uses information that is collected and used as 

outlined in the Privacy Act System of Records Notices (SORN) listed below. 
PRIVACY IMPACT ANALYSIS - PAGE 4 OF 6 G-514 (7-09)

SYSTEM OR APPLICATION NAME: Financial Interchange System

DATE: MARCH 21, 2012

RRB-27: Railroad Retirement Board-Social Security Administration Financial Interchange System,

 RRB-29: Railroad Employees' Annual Gross Earnings Master File

Our Privacy Act Systems of Records Notices list who those parties are and under what routine uses that 

we may disclose that information.

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, before we release that information. 

Send your request to:

• Chief, Financial Interchange Division

Bureau of the Actuary

Railroad Retirement Board

844 North Rush Street

Chicago, IL 60611-2092

Before information about any record will be released, the System Manager may require the individual to 

provide proof of identity or require the requester to furnish an authorization from the individual to permit 

release of information. 

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 

independent contractor evaluated the Financial Interchange system as part of its Certification and 

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

a contractor perform an annual independent security test and review of the Financial Interchange system 

as part of our continuous monitoring policy. 

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

access to the Financial Interchange system, new users receive training on proper use of the system and 

protecting the confidentiality of the data. Our users also are required to receive additional training from 

the Social Security Administration if they are accessing their information.

Before we grant or modify access to the Financial Interchange system 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 our internal agency operating procedures. 
PRIVACY IMPACT ANALYSIS - PAGE 5 OF 6 G-514 (7-09)

SYSTEM OR APPLICATION NAME: Financial Interchange System

DATE: MARCH 21, 2012

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

your information. Some of our safeguards are: 

• Access is limited to those staff members who have a business requirement to that information,

• Complete hard drive encryption on all of our financial interchange computers,

• Encryption of all data on systems that are located outside of RRB facilities,

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

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

staff,

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

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

• Internal policies and training addressing proper handling of sensitive information,

• Logging of local, network, mainframe and database usage,

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

enforcing need to know and least privilege policies,

• Secure disposal of electronic and paper media when it is no longer required,

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

a Federal records holding center,

• Transaction histories are maintained to track any changes to individual records, and

• Vulnerability and Patch management tools to ensure that our system software is kept current.

Section 9.0 - Technologies Used by the Financial Interchange System

The Financial Interchange major application system uses both internally developed applications and 

commercial off the shelf technologies to work. 

We ensured that the Financial Interchange system met all Federal privacy and security requirements. 

We validated that the system meets all current Federal guidelines and directives through the use of an 

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

We use the Financial Interchange major application system to estimate additional benefits and 

administrative expenses that would have been paid by the trust funds (Social Security and Railroad 

Retirement) as well as the additional payroll and income taxes. The difference between these two 

amounts is transferred, with interest, to the trust fund which is owed the larger credits. 

We take our obligation seriously to protect all data that we use for our daily financial operations. 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.
PRIVACY IMPACT ANALYSIS - PAGE 6 OF 6 G-514 (7-09)

SYSTEM OR APPLICATION NAME: Financial Interchange System

DATE: MARCH 21, 2012

Certification of Responsible Officials

Preparer Signature & Title

Carl E. May

Chief, Financial Interchange Division

System Owner Signature

Carl E. May

Chief, Financial Interchange Division

Approved Signature & Title

Charles Mierzwa

Chief of Information Management Resources Center

PTA Control Number

(if a PTA was submitted prior to PIA)

PTA-20110928-001

PIA Control Number PIA-20120321-001