SORN - SSA's Public Credentialing and Authentication Process

SORN - SSA's Public Credentialing and Authentication Process.pdf

SSA's Public Credentialing and Authentication Process

SORN - SSA's Public Credentialing and Authentication Process

OMB: 0960-0789

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SOCIAL SECURITY ADMINISTRATION
REPORT OF PROPOSED NEW PRIVACY ACT SYSTEM OF RECORDS:
Central Repository of Electronic Authentication Data Master File, (60-0373)

I. Background and Purpose of the System of Records
We provide electronic services, such as our automated telephone and Internet
applications, to persons doing business with us. When users choose our electronic
services, they must provide their personally identifiable information (PII). We
use their PII to verify their identities. Upon successful verification, we are able to
recognize the users’ identities and authorize them to conduct business with us
electronically.
This system of records supports our agency’s objectives to expand electronic
services and to provide strong and secure authentication procedures. For security
reasons, we must be able to determine, with confidence, persons are who they
claim to be each time they choose our electronic services.
II. Compliance with the Paperwork Reduction Act
The Paperwork Reduction Act controls data collection for this system of records.
We are complying with the requirements of this statute.
III. Authority for Maintenance of the System of Records
Section 205(a) of the Social Security Act; the Government Paperwork Elimination
Act (P.L. 105-277); the Internal Revenue Code (26 U.S.C. § 6103(l)(1)(A)); and
the Federal Information Security Management Act of 2002 (Title III) of the
E-Government Act of 2002 (P.L. 107-347).
IV. Routine Use Disclosures of Data Maintained in the System of Records
In accordance with the Privacy Act (5 U.S.C. §§ 552a(a)(7) and (b)(3)) and our
disclosure regulations (20 C.F.R. Part 401), we are proposing to establish routine
use disclosures of data that we will maintain in this system of records. We
discuss the proposed routine uses and provide an explanation of how each one
meets the compatibility requirements of the Privacy Act and our disclosure
regulations in the “Supplementary Information” section of the attached preamble.
V. Evaluation of the Probable or Potential Effects of the System of Records on
the Rights of Individuals
We will adhere to all applicable statutory requirements, including those under the
Social Security Act and the Privacy Act, in carrying out our responsibilities.

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Therefore, we do not anticipate that the system of record will have any
unwarranted adverse effect on the privacy or other rights of persons.
VI. The Reasons for Individual Retrieval of Records
In order to authenticate persons using our electronic services, we must be able to
verify their identities by matching the PII they provide with the data we maintain
in this system of records. Accordingly, we will retrieve information from this
system of records by a person’s name and other associated identifying
information.
VII. A Description of the Steps Taken to Minimize the Risk of Unauthorized
Access to the System of Records
We retain electronic files with personal identifiers in secure storage areas
accessible only to our authorized employees and contractors who have a need for
the information when performing their official duties. Security measures include
the use of access codes (personal identification number (PIN) and password) to
enter our computer systems that house the data. We will maintain audit trails of
all access to this information in accordance with agency security policy and
Federal retention standards.
We annually provide all our employees and contractors with security awareness
and training. This training includes the need to protect PII and the criminal
penalties that apply to the unauthorized access to, or disclosure of, PII.
Employees and contractors with access to databases maintaining PII must also
sign a sanction document annually, acknowledging their accountability for
inappropriately accessing or disclosing such information.
VIII. Supporting Documentation
A. Preamble and Notice of System of Records - We have attached a copy of
the document.
B. Agency Rules – The system of records does not require any changes to
existing agency rules.
C. Exemptions Requested - We are not requesting any exemptions from
specific provisions of the Privacy Act.
D. Matching Reports - The system of records will not involve any computer
matching programs as defined by the Privacy Act.

Social Security Administration
Privacy Act of 1974, as Amended
Proposed System of Records and Routine Use Disclosures

AGENCY: Social Security Administration (SSA)

ACTION: Proposed System of Records and Routine Uses

SUMMARY: In accordance with the Privacy Act (5 U.S.C. § 552a(e)(4) and (e)(11)), we are
issuing public notice of our intent to establish a system of records, the Central Repository of
Electronic Authentication Data Master File (hereinafter referred to as the e-Authentication File)
and its applicable routine uses. The e-Authentication File will maintain personally identifiable
information (PII) we collect and use to verify the identity of persons using our electronic
services. We discuss the e-Authentication File and its routine use disclosures in the
Supplementary Information section below. We invite public comments on the e-Authentication
File.

DATES: We filed a report of the e-Authentication File and its applicable routine use disclosures
with the Chairman of the Senate Committee on Homeland Security and Governmental Affairs,
the Chairman of the House Committee on Oversight and Government Reform, and the
Administrator, Office of Information and Regulatory Affairs, Office of Management and Budget
(OMB) on November 30, 2010. The e-Authentication File and applicable routine uses will
become effective on January 13, 2010, unless we receive comments before that date that require
further consideration.

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ADDRESSES: Interested persons may comment on this publication by writing to the Executive
Director, Office of Privacy and Disclosure, Office of the General Counsel, Social Security
Administration, 3-A-6 Operations Building, 6401 Security Boulevard, Baltimore, Maryland
21235-6401 or through the Federal e-Rulemaking Portal at http://www.regulations.gov. All
comments we receive will be available for public inspection at the above address and we will
post them to http://www.regulations.gov.

FOR FURTHER INFORMATION CONTACT: Neil Etter, Social Insurance Specialist,
Disclosure Policy Development and Services Division I, Office of Privacy and Disclosure,
Office of the General Counsel, Social Security Administration, 3-A-6 Operations Building, 6401
Security Boulevard, Baltimore, Maryland 21235-6401, telephone: (410) 965-8028, email:
[email protected].

SUPPLEMENTARY INFORMATION:
I.

Background and Purpose of the e-Authentication File

A. General Background

We provide electronic services, such as our automated telephone and Internet
applications, to persons doing business with us. When users choose our electronic
services, they must provide their PII. We use their PII to verify their identities. Upon
successful verification, we are able to recognize the users’ identities and authorize
them to conduct business with us electronically.

3
The e-Authentication File supports our agency’s objectives to expand electronic
services and to provide strong and secure authentication procedures. For security
reasons, we must be able to determine, with confidence, persons are who they claim
to be each time they choose our electronic services. The e-Authentication File will
capture the data we need to verify users’ identities.

B. Collection and Maintenance of the Data Covered by the e-Authentication File

We will collect and maintain the users’ PII in the e-Authentication File. The PII may
include the user’s name, address, date of birth, Social Security number (SSN), phone
number, and other types of identifying information (e.g., address information of
persons from the W-2 and Schedule Self Employed (SE) forms we receive
electronically for our programmatic purposes, as permitted by 26 U.S.C. §
6103(l)(1)(A)). We may also collect knowledge-based authentication data, which is
information users establish with us or that we already maintain in existing Privacy
Act systems of records.

We will keep the data necessary to administer and maintain our e-Authentication
infrastructure. This includes management and profile information, such as blocked
accounts, failed access data, effective date of passwords, and other data that allows us
to evaluate the system’s effectiveness. The data we maintain also may include
archived transaction data and historical data.

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II.

Routine Use Disclosures of Data Covered by the e-Authentication File
A. Routine Use Disclosures

We propose to establish the following routine use disclosures of information from
the e-Authentication File:

1.

To the Office of the President in response to a request the Office of the
President made at the request of the subject of a record or a third party
acting on the subject’s behalf.

We will disclose information under this routine use only when the Office of
the President indicates it is requesting the record on behalf of the subject of
the record or a third party acting on the subject’s behalf.

2.

To a congressional office in response to a request from that office made at
the request of the subject of the record or a third party acting on the
subject’s behalf.

We will disclose information under this routine use only when a Member of
Congress, or member of his or her staff, indicates he or she is requesting the
record on behalf of the subject of the record or a third party acting on the
subject’s behalf.

3.

To the Department of Justice (DOJ), a court or other tribunal, or another
party before such a court or other tribunal when:

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a) SSA or any of our components; or
b) any SSA employee in his or her official capacity; or
c) any SSA employee in his or her individual capacity when DOJ (or
SSA) has agreed to represent the employee; or
d) the United States or any agency thereof when we determine that the
litigation is likely to affect the operations of SSA or any of our
components,
is a party to litigation or has an interest in such litigation, and we
determine that the use of such records by DOJ, a court, other tribunal, or
another party before such tribunal, is relevant and necessary to the
litigation. In each case, however, we must determine that such disclosure
is compatible with the purpose for which we collected the records.

We will disclose information under this routine use as necessary to enable the
DOJ to defend us, our components, or our employees, in litigation when we
determine the use of information covered by the e-Authentication File is
relevant and necessary to the litigation and compatible with the purpose for
which we collected the information. We will also disclose information to
ensure that courts, other tribunals, and parties before such courts or tribunals,
have appropriate information that we determine is relevant and necessary.

4.

To other Federal agencies and our contractors, including external data
sources, to assist us in efficiently administering our programs.

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We will disclose information under this routine use only in situations where
we have a contractual agreement or similar agreement with a third party to
assist in accomplishing our work relating to information covered by the
e-Authentication File. Under this routine use, we may disclose information
to a contractor to assist us in advancing, testing, and evaluating our
authentication procedures for our electronic services.

5.

To student volunteers, persons working under a personal services
contract, and others when they need access to information in our records
in order to perform their assigned agency duties.

We will disclose information under this routine use only when we use the
services of student volunteers, persons working under a personal services
contract, and others in educational, training, employment, and community
service programs, when they need access to information covered by the
e-Authentication File to perform their assigned agency duties.

6.

To the Department of Justice for:
a)

investigating and prosecuting violations of the Social Security Act to
which criminal penalties attach; and

b)

representing the Commissioner; or

c)

investigating issues of fraud or violation of civil rights by agency
officers or employees.

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We will disclose information under this routine use only as necessary to
enable DOJ to represent us in matters for these purposes.

7.

To the General Services Administration (GSA) and the National Archives
and Records Administration (NARA) under 44 U.S.C. §§ 2904 and 2906,
as amended by the NARA Act of 1984, when the information is for records
management purposes.

We will disclose information under this routine use only when it is
necessary for GSA and NARA to have access to the information covered by
the e-Authentication File. The Administrator of GSA and the Archivist of
NARA are authorized by Title 44 U.S.C. § 2904, as amended, to promulgate
standards, procedures, and guidelines regarding records management, and to
conduct records management studies. Title 44 U.S.C. § 2906, as amended,
provides that agencies are to cooperate with GSA and NARA as GSA and
NARA are authorized to inspect Federal agencies' records for records
management purposes.

8.

To appropriate Federal, State, and local agencies, entities, and
persons when:
a) we suspect or confirm a compromise of security or
confidentiality of information;
b) we determine that, as a result of the suspected or confirmed
compromise, there is a risk of harm to economic or property

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interests, risk of identity theft or fraud, or risk of harm to the
security or integrity of this system or other systems or programs
that rely upon the compromised information; and
c) we determine that disclosing the information to such agencies,
entities, and persons will assist us in our efforts to respond to the
suspected or confirmed compromise and prevent, minimize, or
remedy any harm.

We will disclose information under this routine use specifically in
connection with response and remediation efforts in the event of an
unintentional release of agency information (otherwise known as a data
breach). With this routine use, we can protect the interests of the people
whose information is at risk by responding timely and effectively to a data
breach. The routine use will also help us improve our ability to prevent,
minimize, or remedy any harm that may result from a data breach.

B.

Compatibility of Routine Uses

We can disclose information for routine uses one through six when it is necessary to
carry out our programs or other programs similar to ours or when the disclosure is
supported by a published routine use (20 C.F.R. § 401.150). We can also disclose
information when the disclosure is required by law (20 C.F.R. § 401.120). Federal
law requires the disclosures that we make under routine uses seven and eight, to the
extent another Federal law does not prohibit the disclosure. All routine uses in the

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e-Authentication File are compatible with the relevant statutory and regulatory
criteria.

III.

Records Storage Medium and Safeguards for the Information Covered by the
e-Authentication File

We will maintain, in electronic form, all information covered by the e-Authentication
File. We will safeguard the security of the electronic information covered by the
e-Authentication File by requiring the use of access codes (personal identification
number (PIN) and password) to enter the computer system that will house the data. We
will maintain audit trails of all access to this information in accordance with agency
security policy and Federal retention standards. We will permit access to the information
covered by the e-Authentication File only to our authorized employees and contractors
who require the information to perform their official duties.

We annually provide all our employees and contractors with security awareness and
training. This training includes the need to protect PII and the criminal penalties that
apply to an unauthorized access to, or disclosure of, PII. Employees and contractors with
access to databases maintaining PII must also sign a sanction document annually,
acknowledging their accountability for inappropriately accessing or disclosing such
information.

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IV.

Effects of the e-Authentication File on the Rights of Persons

We will use safeguards to protect the confidentiality of all PII in our possession. We will
ensure that all contractors or others acting on our behalf are obliged to do the same. We
will adhere to the provisions of the Privacy Act and other applicable Federal statutes that
govern our use and disclosure of information that the e-Authentication File covers. We
will disclose information under the routine uses only as necessary to accomplish the
stated purposes. We do not anticipate that the e-Authentication File, or its applicable
routine use disclosures, will have any unwarranted adverse effect on the privacy or other
rights of persons.

DATED: November 30, 2010

_________/s/________________
Michael J. Astrue
Commissioner

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Social Security Administration
Notice of System of Records
Required by the Privacy Act of 1974, as Amended

System number: 60-0373

System name: Central Repository of Electronic Authentication Data Master File

Security classification: None

System Location: Social Security Administration (SSA), Office of Systems, 6401 Security
Boulevard, Baltimore, Maryland 21235.

Categories of persons covered by the system: Persons conducting business with us through
our electronic services.

Categories of records in the system: We will collect and maintain the user’s personally
identifiable information (PII) in this system of records. The PII may include the user’s name,
address, date of birth, Social Security number (SSN), phone number, and other types of identity
information (e.g., address information of persons from the W-2 and Schedule Self Employed
(SE) forms we receive electronically for our programmatic purposes as permitted by 26 U.S.C. §
6103(l)(1)(A)). We may also collect knowledge-based authentication data, which is information
users establish with us or that we already maintain in existing Privacy Act systems of records.
We will maintain the data necessary to administer and maintain our e-Authentication
infrastructure. This includes management and profile information, such as blocked accounts,

12
failed access data, effective date of passwords, and other data that allows us to evaluate the
system’s effectiveness. The data we maintain also may include archived transaction data and
historical data.

Authority for maintenance of the system: Section 205(a) of the Social Security Act; the
Government Paperwork Elimination Act (P.L. 105-277); the Internal Revenue Code (26 U.S.C. §
6103(l)(1)(A)); and the Federal Information Security Management Act of 2002 (Title III) of the
E-Government Act of 2002 (P.L. 107-347).

Purpose(s): This system of records supports our agency’s objectives to expand electronic
services, such as our automated telephone and Internet application. This system of records also
supports our agency’s commitment to strong and secure authentication procedures by properly
maintaining PII we collect from persons to verify their identities. For security reasons, we must
be able to determine, with confidence, persons are who they claim to be each time they choose
our electronic services.

Routine uses of records covered by this system of records, including categories of users and
the purposes of such uses: Routine use disclosures are indicated below; however, we will not
disclose any information defined as “return or return information” under 26 U.S.C. § 6103 of the
Internal Revenue Code (IRC), unless the IRC, the Internal Revenue Service (IRS), or IRS
regulations authorize us to do so.

1. To the Office of the President in response to a request the Office of the President made
at the request of the subject of the record or a third party acting on the subject’s behalf.

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2. To a congressional office in response to a request from that office made at the request
of the subject of the record or a third party acting on the subject’s behalf.

3. To the Department of Justice (DOJ), a court, other tribunal, or another party before
such court or tribunal when:
a) SSA or any of our components; or
b) any SSA employee in his or her official capacity; or
c) any SSA employee in his or her individual capacity when DOJ (or SSA) has agreed
to represent the employee; or
d) the United States or any agency thereof when we determine that the litigation is
likely to affect the operations of SSA or any of our components,
is a party to litigation or has an interest in such litigation, and we determine that the
use of such records by DOJ, a court, other tribunal, or another party before such
tribunal, is relevant and necessary to the litigation. In each case, we must determine
that such disclosures are compatible with the purpose for which we collected the
records.

4. To other Federal agencies and our contractors, including external data sources, to
assist us in administering our programs.

5. To student volunteers, persons working under a personal services contract, and others
when they need access to information in our records in order to perform their assigned
agency duties.

14
6. To the Department of Justice for:
a) investigating and prosecuting violations of the Social Security Act to which
criminal penalties attach; and
b) representing the Commissioner; or
c) investigating issues of fraud or violation of civil rights by agency officers or
employees.

7. To the General Services Administration and the National Archives and Records
Administration under 44 U.S.C. §§ 2904 and 2906, as amended by the NARA Act of
1984, when the information is for records management purposes.

8. To appropriate Federal, State, and local agencies, entities, and persons when:
a) we suspect or confirm a compromise of security or confidentiality of
information;
b) we determine that as a result of the suspected or confirmed compromise there
is a risk of harm to economic or property interests, risk of identity theft or
fraud, or harm to the security or integrity of this system or other systems or
programs that rely upon the compromised information; and
c) we determine that disclosing the information to such agencies, entities, and
persons will assist us in our efforts to respond to the suspected or confirmed
compromise and prevent, minimize, or remedy such harm.

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Policies and practices for storing, retrieving, accessing, retaining, and disposing of records
in this system of records:

Storage: We will store records in this system of records in electronic form.

Retrievability: We will retrieve records in this system of records by a person’s name and
associated identifying information.

Safeguards: We retain electronic files with personal identifiers in secure storage areas
accessible only to our authorized employees and contractors who have a need for the information
when performing their official duties. Security measures include the use of access codes
(personal identification number (PIN) and password) to enter our computer systems that house
the data.

We annually provide all our employees and contractors with security awareness and training.
This training includes the need to protect PII and the criminal penalties that apply to an
unauthorized access to, or disclosure of, PII. Employees and contractors with access to
databases maintaining PII must also sign a sanction document annually, acknowledging their
accountability for inappropriately accessing or disclosing such information.

Retention and disposal: We maintain records in SSA headquarters within the Office of Open
Government. We will maintain records in this system of records until seven years after the
notification of the death of the account holder. After that time, we will delete the person’s
records from the database.

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System manager(s) and address: Office of the Chief Information Officer, Office of Open
Government, Social Security Administration, 6401 Security Boulevard, Baltimore, MD 21235.

Notification procedures: Persons can determine if this system contains a record about them by
writing to the system manager at the above address and providing their name, SSN, or other
information in this system of records that will identify them. Persons requesting notification by
mail must include a notarized statement to us to verify their identity or must certify in the request
that they are the person they claim to be and that they understand that the knowing and willful
request for, or acquisition of, a record pertaining to another person under false pretenses is a
criminal offense.

Persons requesting notification of records in person must provide the same information, as well
as provide an identity document, preferably with a photograph, such as a driver's license.
Persons lacking identification documents sufficient to establish their identity must certify in
writing that they are the person they claim to be and that they understand that the knowing and
willful request for, or acquisition of, a record pertaining to another person under false pretenses
is a criminal offense.

Persons requesting notification by telephone must verify their identity by providing identifying
information that parallels the information in the record about which they are requesting
notification. If we determine that the identifying information the person provides by telephone is
insufficient, we will require the person to submit a request in writing or in person. If a person
requests information by telephone on behalf of another person, the subject person must be on the
telephone with the requesting person and us in the same phone call. We will establish the subject

17
person’s identity (his or her name, SSN, address, date of birth, and place of birth, along with one
other piece of information, such as mother's maiden name) and ask for his or her consent to
provide information to the requesting person. These procedures are in accordance with our
regulations at 20 C.F.R. §§ 401.40 and 401.45.

Record access procedures: Same as notification procedures. Persons also should reasonably
specify the record contents they are seeking. These procedures are in accordance with our
regulations (20 C.F.R. § 401.40(c)).

Contesting record procedures: Same as notification procedures. Persons also should
reasonably identify the record, specify the information they are contesting, and state the
corrective action sought and the reasons for the correction with supporting justification showing
how the record is incomplete, untimely, inaccurate, or irrelevant. These procedures are in
accordance with our regulations (20 C.F.R. § 401.65(a)).

Record source categories: We obtain information in this system of records primarily from the
person to whom the record pertains. We may also include information from electronic W-2 and
electronic Schedule SE forms for members of the public.

System exempted from certain provisions of the Privacy Act: None.


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