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Subject:
From:
Larry Medina <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Mon, 14 Nov 2011 09:02:15 -0800
Content-Type:
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On Mon, Nov 14, 2011 at 7:34 AM, PeterK <[log in to unmask]> wrote:

> IRS Having Trouble Keeping Taxpayer Files Secure, Watchdog Says | Fox News
> The IRS is having problems securing personal taxpayer data and is not doing
> enough to prevent "unauthorized users" from accessing that information,
> according to a new report.
>
> Source:
>
> http://www.foxnews.com/politics/2011/11/12/irs-having-trouble-keeping-taxpayer-files-secure-watchdog-says/?test=latestnews
>
>

From the report:

"Although levels of electronic filing of tax and information returns have
been steadily increasing, IRS continues to face an ongoing management
challenge due to the millions of hard-copy tax returns it continues to
receive and process each year, along with hundreds of billions of dollars
in associated taxpayer payments it receives. As long as IRS continues to
receive such large volumes of hard-copy taxpayer payments and supporting
data, there will continue to be a significant risk to the government and
taxpayers alike that loss of receipts or inappropriate disclosure or
compromise of taxpayer information may occur during this process.
Safeguarding these taxpayer receipts and associated taxpayer information to
prevent such events are among IRS’s most important and demanding
responsibilities, and congressional and taxpayer expectations in this
regard are justifiably high. During our financial audits, including our
fiscal year 2011 audit, we continue to identify deficiencies in IRS’s
internal control over safeguarding of taxpayer receipts and information
which, while not individually or in the aggregate constituting a
significant deficiency or material weakness, nonetheless are sensitive
matters requiring attention. We have made numerous recommendations to
address these issues,18 to which IRS has been responsive. Nonetheless, it
is critical that IRS maintain effective internal control to mitigate this
risk, including ongoing monitoring of key internal controls to verify that
they do not deteriorate over time."


I find this assertion interesting- that they feel the hard copy returns
present "...a significant risk to the government and taxpayers alike...".
Up until 5 years ago, hard copy federal record returns were all stored at
Federal Record Centers (FRCs) and the policy at an FRC is ONLY the agency
submitting the records into storage is able to remove them from storage.
There had to be limited risk to exposure of their content because the only
parties that had access were FRC workers and IRS employees, and it was only
IRS employees listed on an authorized requester list.

About 5 years ago, there as a severe push by commercial storage providers
to begin providing record storage to Federal Agencies, citing in the FRCs
now charge for services, and they felt they could compete.  One of the
hurdles they had to cross however was their ability to demonstrate they
were able to comply with the requirements for storage of Federal Records
which are contained in 36CFR.  These are very unforgiving, and they include
things like construction requirements, environmental controls, safety,
security, volumes limits, compartment size, etc.  Some providers have been
approved to store records, but there are still questions that should be
asked about how well they are meeting the requirements... in a minimum of
cone case, a provider has multiple facilities within one city, received
approval to store at one and has subsequently begun storing records at
another... which was not individually approved.

It makes me wonder if the issues related to "...a significant risk to the
government and taxpayers alike..." may be in part related to the decision
to open up storage to providers outside of the FRCs? Given the strict
controls imposed there, I can't see where these storage environments could
be putting tax returns and receipts at any risk. If its records being
stored in commercial facilities that are the ones being improperly accessed
or "at risk", maybe it's time to rethink the decision to store in those
facilities... or at minimum, it's time to dust off the Terms and Conditions
and find out if the IRS is receiving what they're paying for.

Larry
[log in to unmask]
-- 
*Lawrence J. Medina
Danville, CA
RIM Professional since 1972*

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