Guide for Mapping Types of Information and Information Systems to Security Categories, Volume 2: Appendices
Section 4.2.3 and 4.4.2. > C.2 Rationale and Factors for Services Delivery Support Information > C.2.8 General Government > C.2.8.11 Representative Payee Information Information Type

C.2.8.11 Representative Payee Information Information Type

Representative payee information includes the information required to determine the need for
representative payees and the data that is gathered to make the determination of who should
serve as the representative payee for all beneficiaries of federal benefits who are unable to
manage their own funds. This also includes accountability information required to provide
reasonable assurance that the funds are being used appropriately for the well being of entitled
individuals. The recommended security categorization for the representative payee information
type is as follows:
Security Category = {(confidentiality, Moderate), (integrity, Moderate), (availability, Moderate)}
The confidentiality impact level is based on the effects of unauthorized disclosure of
representative payee information on the ability of the Federal government to determine that
entitlement funds are being used appropriately for the well being of entitled individuals - and to
protect individuals against identity theft and the Federal government against fraud.
Unauthorized disclosure of data for representative payee operations is likely to violate the
Privacy Act of 1974 and other regulations applicable to the dissemination of personal
information.
Unauthorized disclosure of centrally managed representative payee information can have a
serious adverse effect on agency missions and on large numbers of individuals. Therefore, in the
case of large representative payee information databases, the provisional confidentiality impact
level can be expected to be at least moderate.
Recommended Confidentiality Impact Level: The provisional confidentiality impact level
recommended for representative payee information is moderate.
The integrity impact level is based on the specific use of the payee information and not on the
time required to detect the modification or destruction of information. In the case of very large
databases containing representative payee information relating to the general public, there is a
significant probability that erroneous actions will be taken affecting the benefits payments to
large numbers of individuals. This can result in at least short-term financial hardship for our
most vulnerable citizens. Loss of integrity can result in serious disruption of the agency
operations. In such cases, the integrity impact level would be at least moderate.
Special Factors Affecting Integrity Impact Determination: In the case of fraudulent diversion of
payments intended for particularly dependent individuals, there can be life-threatening
consequences. In such cases, a high integrity impact rating may be justified.
Recommended Integrity Impact Level: The provisional integrity impact level recommended for
representative payee information is moderate.
The availability impact level is based on the specific use of the representative payee information
and not on the time required to re-establish access to the representative payee information.
Benefits payment processes are not necessarily tolerant of delays. In many cases, disruption of
access to representative payee information can be expected to have a very serious adverse effect
on individuals.
Special Factors Affecting Availability Impact Determination: In the case of very large data bases
containing representative payee information relating to the general public, there is a significant
probability that processing delays will affect the benefits payments to large numbers of
individuals. The larger the number of records affected, the longer the delays that can be
expected to result. This can result in financial hardship for some individuals and in serious
disruption of agency operations. In such cases, the availability impact level would be at least
moderate. In the case of permanent loss of records, the impact might even be high.
Recommended Availability Impact Level: The provisional availability impact level recommended for
representative payee information is moderate.