Privacy Impact Assessment – Contact Recording Milestone 4
Contact Recording System Overview
Contact Recording System for TACs is a desktop recording tool that captures audio conversations between the Taxpayer and the Tax Resolution Representative (TRR) as well as screen views of the corresponding computer research and input. This tool will allow Wage and Investment and Field Assistance managers and quality reviewers a resource for monitoring contacts that will result in more thorough, efficient and effective reviews. Quality customer service depends on the Service’s ability to provide correct answers to customer inquiries, timely correction of errors, and identification of trends for strategic planning purposes. An essential element is the ability to assure management and other stakeholders that employees are providing correct answers in a courteous and professional manner. A Privacy Impact Assessment has already been approved for the Contact Recording System for Telephone Call Centers. A Privacy Impact Assessment was approved on June 14th, 2004, for the pilot program for Contract Recording for TAC along with a new Systems of Records Notice for Contact Recording at Taxpayer Assistance Centers. This request updates that PIA for Milestone 4. No major or significant changes were made to the system since the pilot program proved a success.
System of Records Number(s)
Treasury/IRS 00.009 IRS Taxpayer Assistance Center (TAC) Recorded Quality Review Records
Treasury/IRS 34.037 IRS Audit Trail and Security Records System
Data in the System
1. Describe the information (data elements and fields) available in the system in the following categories:
A. Taxpayer
B. Employee
C. Audit Trail Information
D. Other
A. Audio recordings of communication between a taxpayer/representative and an IRS employee concerning the taxpayer’s tax account and screen views that an employee accesses on a computer system. Although intended for the purpose of improving employee performance, the recording may capture certain taxpayer information such as: Social Security Number (SSN), Employer Identification Number (EIN), date of birth (DOB), name, address or telephone number. Examples: (1) a taxpayer contact as a result of a notice or collection action to make payment arrangements or fully pay an outstanding tax liability; (2) a taxpayer contact requesting clarification of a tax law provision as a result of receiving a CP2000 notice or an EIC audit notice; (3) a taxpayer contact requesting preparation of a tax return; (4) a taxpayer contact requesting assistance with the completion of a W-7 application or form 2290; (5) a taxpayer remitting a monthly payment
B. Audio and/or screen recording of the employee’s name and Q-Matic identification number
C. Audit trail information of all access to the system by users
D. Not applicable
2. Describe/identify which data elements are obtained from files, databases, individuals, or any other sources.
A. IRS
B. Taxpayer
C. Employee
D. Other Federal Agencies
E. State and Local Agencies
F. Other third party sources
A.IDRS/CADE
Integrated Case Processing (ICP)
Integrated Collection System (ICS)
Automated Collection System (ACS)
Report Generation System (RGS)
Desktop Integration (DI)
Employee Personnel Files
Embedded Quality Review System (EQRS)
remote access through passwords for reviewers
B. For account-related contacts, taxpayers/representatives may either speak or write their SSN/EIN, name, address, telephone number and DOB.
C. Employees are required to provide their name or approved pseudonym and badge
D. None
E. None
F. None
3. Is each data item required for the business purpose of the system? Explain.
Yes, to answer account-related contacts, employees must access IDRS/CADE, using their unique log-on and password. Under Restructuring & Reform Act 1998, employees having public contact are required to provide their name or approved pseudonym and unique identification number. To guard against disclosure in account-related contacts, taxpayers are required to provide their SSN/EIN, name, address, telephone number and DOB either in writing or verbally. Managers, on-the-job instructors (OJIs) and quality reviewers must use a unique log-on and password for accessing secure systems (IDRS) in order to observe work processes. With contact recording, access parameters ensure only managers, OJIs or quality reviewers at various levels of the organization have access to recorded information and data captured on screens. A designated systems administrator will apply parameters to individual users in conformance with Security Regulations.
4. How will each data item be verified for accuracy, timeliness, and completeness?
This system contains audio recording of conversations between taxpayers/representatives and IRS employees. If a tax question regarding their own account is in question, a screen capture of the customer’s account can be saved and associated with the voice recording with an electronic time-date stamp. This system assures that what was said is in-fact the actual encounter between the IRS employee and the customer.
5. Is there another source for the data? Explain how that source is or is not used.
Managers could monitor conversations between employees and taxpayers and see the on-line screens the employee is accessing, by standing next to the employee during an encounter. Contact recording creates a more flexible, efficient and effective system by allowing managers and quality reviewers to review contacts for accuracy, timeliness and professionalism at any time of the day regardless of their physical location. This allows more representative, natural and accurate interaction with taxpayers.
6. Generally, how will data be retrieved by the user?
The manager or quality reviewer will access the CR system via a browser interface. Based on their profile and the business rules, they will be able to playback and review the recordings from the server through their browser. All other access to recordings are restricted by standard operating system file protection mechanisms. Business rules are used to randomly select contacts to be reviewed that meet specific criteria. For example, contacts are reviewed by subject matter closing codes assigned for each type of transaction.
7. Is the data retrievable by a personal identifier such as name, SSN, or other unique identifier?
Contact recordings with the associated screen captures, evaluative data specific to the employee, and quality review data will be retrieved by employee name and/or Q-Matic identification number. Non-evaluative data not associated with a specific employee may be retrieved by a unique identifier assigned to each data collection instrument (DCI). DCI and the recording system are separate systems. A number will be assigned to the DCI and recording screen so that a match can be made to the DCI and specific recording by TRR. No taxpayer data is captured or retrieved by taxpayer name or other taxpayer SBU information.
Access to the Data
8. Who will have access to the data in the system (Users, Managers, System Administrators, Developers, Others)?
Managers, OJIs, quality reviewers and system administrators will have access to data in the system. Contractors may have access during the development and installation phases, and have signed all required non-disclosure agreements and had background checks.
9. How is access to the data by a user determined and by whom?
The executive owner in charge has approved access parameters. The next-higher level of management determines profiles for each manager and quality reviewer. Senior management and NTEU representatives will have the right to listen to recorded contacts should grievances/disagreements occur regarding content. Territory managers may review and compare managerial documentation in order to evaluate the manager’s performance. Managers may only access their assigned employees’ contact recordings.
10. Do other IRS systems provide, receive, or share data in the system? If YES, list the system(s) and describe which data is shared. If NO, continue to Question 12. Yes.
IDRS/CADE - Taxpayer account information (IDRS PIA 4/27/05)
Automated Collection System (ACS) Taxpayer account information (PIA 7/17/03)
Integrated Collection System (ICS) Taxpayer account information (PIA 5/13/03)
Integrated Case Processing (ICP) - Taxpayer account information with access to Centralized Inventory and Distribution System (CIDS), Automated Information System (AIS), Reasonable Cause for Abatement (RCA) and on-line form preparation, as well as simultaneous presentation of IDRS, Corporate Files On-Line (CFOL), ACS, Inventory Delivery System (IDS), Non-Master File (NMF) and universal ICP history (PIA 12/4/2000) SERP - Research information (PIA 6/1/99)
EQRS - Results of reviews of employees’ work that is measured and reported at all levels (PIA 4/27/05) Field Assistance Queuing Management System (Q-Matic) - Identifies and calls to the counter the next taxpayer to be assisted (No PIA needed)
Enterprise-wide Learning Management System (ELMS) - Contains training information of employees (PIAs 4/21/03)
11. Have the IRS systems described in Item 10 received an approved Security Certification and Privacy Impact Assessment?
See dates or notes in parentheses in question 10 for PIA approval dates or comments.
12. Will other agencies provide, receive, or share data in any form with this system?
No, except as stated: As part of their oversight, TIGTA and GAO may access this data as required by law. Personnel agencies or Courts may access relevant data if records are required in a personnel action or litigation. Other potential agencies that might be given data are provided in the SORN.
Administrative Controls of Data
13. What are the procedures for eliminating the data at the end of the retention period?
Record retention will be in accordance with 36 CFR, Chapter X11, National Archives and Records Administration, Part 1228, Subpart B – Scheduling Records.
Recorded contacts and the associated screen captures will automatically be erased from the system based on the following criteria:
* Evaluative Quality Assurance Data - All recordings are stored on the local TRR PC where the contact originated for up to 10 business days (about 14 calendar days).
* Selected Recordings and Screen Captures are pulled from the TRR PCs and stored on the central server for evaluation until their retention period expires, at which time they are deleted - default retention on the server is 45 days but can be as long as three years in some cases. By exception, the recording will be flagged for indefinite retention (e.g., grievances, arbitration). (IRM)
14. Will this system use technology in a new way? If "YES" describe. If "NO" go to Question 15.
Yes. This technology is new to the IRS and will record in-person contacts (audio) and screen views accessed by the employee while assisting a customer. The recording and screen capture will be combined and presented to the manager to be reviewed at a time convenient to their schedule. Contacts between taxpayers and employees will be recorded and assessed for accuracy of advice, timeliness and professionalism. The national server employs an algorithm to select a statistically valid random sampling of recordings for managers to review of their respective employees. The manager could access the system and apply built-in search criteria based on contact information to identify cases to review. The manager could also conduct a manual search across all recordings for the last 45 days of his/her respective employees.
15. Will this system be used to identify or locate individuals or groups? If so, describe the business purpose for this capability.
This system does not intentionally identify taxpayers (individuals or groups). There is no mechanism to search for or locate any taxpayer specific information. Recordings are identified by employee name not taxpayer name. The system will allow managers and quality reviewers to identify employee information. This process will allow management to identify trends affecting accuracy, timeliness and professionalism. There is no mechanism built into the system to track any taxpayer information.
16. Will this system provide the capability to monitor individuals or groups? If yes, describe the business purpose for this capability and the controls established to prevent unauthorized monitoring.
Employee data is maintained for review and feedback relative to performance. No taxpayer (individuals or groups) will be monitored.
17. Can use of the system allow IRS to treat taxpayers, employees, or others, differently? Explain.
No. This system will ensure a more efficient and fair means of selecting and evaluating contacts.
18. Does the system ensure "due process" by allowing affected parties to respond to any negative determination, prior to final action?
Yes. Employees will have the opportunity to hear and respond to recordings during feedback sessions, and if appropriate dispute,
file a grievance, or pursue litigation as a result of the manager’s evaluation.
19. If the system is web-based, does it use persistent cookies or other tracking devices to identify web visitors?
The system will use a web browser as the interface for access to the recordings, screen images and quality review. Performance data will not be posted to a web site for access. Only managers, OJIs, quality reviewers and systems administrators with specific roles and responsibilities will have access to the information. The portal to this web-based system will be tightly controlled and those employees not authorized will be denied access to the system.
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