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Electronic Enterprise Fax (EEFAX), Privacy and Civil Liberties Impact Assessment (Date of Approval: 06/05/2025) (IRS)

Summary

A Privacy and Civil Liberties Impact Assessment by the Internal Revenue Service for the Electronic Enterprise Fax (EEFAX) system, Questionnaire Number 1933, with a Date of Approval of 06/05/2025. It describes EEFax as a fax utility that lets IRS employees, taxpayers and taxpayer representatives send, receive, store, review and work fax documents from their computers. It states that the system handles Personally Identifiable Information and Federal Tax Information as image files with no data parsed or extracted, that inbound faxes are delivered to a printer, SharePoint, file storage or a mailbox, and that activity logs sit in a JobTrack database on SQL servers. It answers that the system uses no artificial intelligence or cloud computing, interacts with the public, and relies on the consent individuals give when filing tax returns.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

Date of Approval: 06/05/2025
Questionnaire Number: 1933


Basic Information/Executive Summary
What is the name of your project (system, database, pilot, product, survey, social media
site, etc.)?
      Electronic Enterprise Fax

Acronym:
      EEFAX

Business Unit
      Information Technology

Preparer
      # For Official Use Only

Subject Matter Expert
      # For Official Use Only

Program Manager
      # For Official Use Only

Designated Executive Representative
      # For Official Use Only

Executive Sponsor
      # For Official Use Only

Executive Summary: Provide a clear and concise description of your project and how it
will allow the IRS to achieve its mission.
      The Electronic Enterprise Fax (EEFax) system acts as a “fax utility” or service
      and provides the fax handling infrastructure for the IRS. EEFax allows IRS
      employees, taxpayers and taxpayer representatives (referred to from here on as
      “TP”) to send, receive, store, review and work a “fax document” from their
      computers. It handles faxes inbound to the IRS and outbound to TPs. EEFax may
      use a unique telephone number or barcode provided to the TP for electronic
      delivery to the correct IRS recipient. This service provides many benefits to the
      IRS, including +Increased employee efficiencies through eliminating: --the
      amount of time walking to and from physical printers and fax machines, --
      eliminating an employee sorting through a pile of paper faxes at the physical fax
      machine, which will also reduce disclosure errors, and --reducing reliance on
      paper records. +More efficient use of technology by reducing --the unintentional
       storage of faxes at the machine, --telecommunications costs, and --reliance on
       paper records. +EEFax is projected to provide services for the entire enterprise
       and handle approximately 20M million fax pages per month. This will provide a
       substantial cost savings by eliminating standalone fax hardware and its use of
       consumables such as paper, and ink/toner.


Personally Identifiable Information (PII)
Will this project use, collect, receive, display, store, maintain, or disseminate any type of
Sensitive but Unclassified (SBU), Personally Identifiable Information (PII), or Federal
Tax Information (FTI)?
       Yes

Please explain in detail how this project uses sensitive data from inception to destruction
(data lifecycle).
       EEFax electronically sends and receives facsimiles using the same fax protocols
       as on a traditional facsimile machine. Fax documents are handled as image files,
       and no data is parsed or extracted from the fax files. On the IRS end, EEFax
       traffic is handled through the Microsoft Outlook Exchange environment. When
       faxes are received, they are delivered to 1) High-speed printer, 2) SharePoint
       Uniform Resource Locator (URL), 3) Universal Naming Convention (UNC) File
       Storage, 4) Individual or 5) Organizational mailbox. Inbound faxes are retained
       for one of two periods. First, faxes destined for a high-speed printer are retained
       for a period of five days so faxes may be reprinted in case there is a printer
       malfunction. Second, for the other four destinations, faxes are stored only long
       enough for the system to verify delivery. Outbound faxes are sent unencrypted
       without a digital signature and are also retained only long enough for the system
       to verify delivery. EEFax will maintain employee Standard Employer IDentifier
       (SEID) and e-mail address information in the activity logs to track provide audit
       trails on all fax activity. No TP PII or sensitive information is contained in the
       audit logs. They are stored in the JobTrack database within SQL servers in
       EEFax. Logs are available to be searched, analyzed and audited. Audit logs are
       also kept for users with administrator level access (Enterprise Operations) to
       EEFax Servers. All audit logs are sent to Splunk.

Please select all types of Sensitive but Unclassified data (SBU)/Personally Identifiable
Information (PII)/Federal Tax Information (FTI) that this project uses.
       Address
       Bar Codes
       Centralized Authorization File (CAF)
       Citizenship or Migration Status
       Credit Card Number
       Document Locator Number (DLN)
       Driver's License Number
       Education Information
       Email Address
       Employer Identification Number
       Employment Information
       Family Members
       Federal Tax Information (FTI)
       Financial Account Number
       Geographical Indicators
       Global Intermediary Identification Number (GIIN)
       Individual Taxpayer Identification Number (ITIN)
       Language
       Medical History/Information
       Name
       Non-Tax Proprietary data
       Official Use Only (OUO) or Limited Office Use (LOU)
       Online Identifiers
       Passport Number
       Patient Number
       Personal Characteristics
       Photograph
       Preparer Taxpayer Identification Number (PTIN)
       Professional License Number
       Protected Information
       Social Security Number (including masked or last four digits)
       Standard Employee Identifier (SEID)
       Tax ID Number
       Telephone Numbers
       Universal Unique Identifier (UUID)
       Vehicle Identification Number (VIN)

Cite the authority for collecting SBU/PII/FTI (including SSN if relevant).
       PII for federal tax administration - generally IRC Sections 6001 6011 or 6012
       PII for personnel administration - 5 USC
       SSN for personnel administration IRS employees - 5 USC and Executive Order
       9397
       SSN for tax returns and return information - IRC section 6109


Product Information (Questions)
1 Is this PCLIA a result of the Inflation Reduction Act (IRA)?
       No

2 What type of project is this (system, project, application, database, pilot/proof of
concept/prototype, power platform/visualization tool)?
       System
3 What Tier designation has been applied to your system?
      2

4 Is this a new system?
      No

4.1 Is there a previous Privacy and Civil Liberties Impact Assessment (PCLIA) for this
project?
      Yes

4.11 What is the previous PCLIA number?
      6791

4.12 What is the previous PCLIA title (system name)?
      Electronic Enterprise Fax, EEFax, EEFAX

4.2 You have indicated this is not a new system; explain what has or will change and
why. (Expiring PCLIA, changes to the PII or use of the PII, etc.)
      Expiring PCLIA

5 Is this system considered a child system/application to another (parent) system?
      No

6 Indicate what OneSDLC State is the system in (Allocation, Readiness, Execution) or
indicate if you go through Information Technology's (IT) Technical Insertion Process and
what stage you have progressed to.
      Execution

7 Is this a change resulting from the OneSDLC process?
      No

8 Please provide the full name and acronym of the governance board or Executive
Steering Committee (ESC) this system reports to.
      User and Network Services (UNS) Executive Steering Committee

9 If the system is on the As-Built-Architecture (ABA), what is the ABA ID number of the
system? If this PCLIA covers multiple applications shown on the ABA, please indicate
the ABA ID number(s) for each application covered separated by a comma. If the system
is not in the ABA, then contact the ABA (https://ea.web.irs.gov/aba/index.html) for
assistance.
      211307
10 If this system discloses any PII to any third party outside the IRS, does the system
have a process in place to account for such disclosures in compliance with IRC
6103(p)(3)(A) or Subsection c of the Privacy Act?
       No

11 Does your project/system involve any use of artificial intelligence (AI), including
virtual assistant, chat bot, and robotic process automation, as defined in Executive Order
13960 and 14110?
       No

12 Does this system use cloud computing?
       No

13 Does this system/application interact with the public?
       Yes

13.1 If the system requires the user to authenticate, was a Digital Identity Risk
Assessment (DIRA) conducted?
       No

13.11 Please upload the approved DIRA report using the Attachments button. Select
"Yes" to indicate that you have or will upload the signed DIRA form.
       No

13.2 If individuals do not have the opportunity to give consent to collect their information
for a particular use, why not?
       Individuals have given consent to collection of their information when filing tax
       returns and/or during tax administration when EEFax would be used.

13.3 If the individual was not notified of the following items prior to the collection of
information, why not? 1) Authority to collect the information 2) If the collection is
mandatory or voluntary 3) The purpose for which their information will be used 4) Who
the information will be shared with 5) The effects, if any, if they don't provide the
requested information.
       All facsimile data is transmitted (to IRS) to address specific taxpayer/entity
       requirements, whether in response to direct IRS request (which details authority,
       mandatory/voluntary nature, purpose, potential dissemination, and potential
       effects), or via IRS published forms and/or directives (also detailing the same).

14 Describe the business process allowing an individual to access or correct their
information. (Due Process)
       "Your Rights as a Taxpayer” explains the rights of the taxpayer, which includes
       the right to challenge the IRS position and be heard; and the right to appeal an
       IRS decision in an independent forum. EEFax is only a transmission method for a
       taxpayer to submit data as requested by the IRS so if they wanted to correct their
       submission, they can re-send the corrected form to the IRS. If the taxpayer wants
       to correct this data, they would need to contact the requesting authority within the
       IRS or use the procedure as described within the original request.

15 Is this system owned and/or operated by a contractor?
       Yes, the contractors maintain the system.

15.1 If a contractor owns or operates the system, does the contractor use subcontractors;
or do you require multiple contractors to operate, test, and/or maintain this system?
       No

16 Identify what role(s) the IRS and/or the contractor(s) performs; indicate what access
level (to this system's PII data) each role is entitled to. (Include details about completion
status and level of access of the contractor's background investigation was approved for.)
       Users - Read Managers - Read
       Administrators - Read & Write
       Contractors - Read & Write / Access level - input Low / Background
       Investigation Complete

17 The Privacy Act of 1974 (5 USC § 552a(e)(3)) requires each agency that maintains a
system of records, to inform each individual requested to supply information about
himself or herself. Please provide the Privacy Act Statement presented by your system or
indicate a Privacy Act Statement is not used and individuals are not given the opportunity
to consent to the collection of their PII.
       The legal right to ask for information is Internal Revenue Code sections 6001,
       6011, and 6012(a), and their regulations. These sections state that individuals
       must file a return or statement with IRS for any tax for which they are liable, and
       response is mandatory. Any privacy statements would be provided by the IRS
       entity that is requesting the information on the applicable tax form.

18 How many records in the system are attributable to IRS Employees? Enter "Under
50,000", "50,000 to 100,000", "More than 100,000" or "Not Applicable".
       More than 100,000

19 How many records in the system are attributable to contractors? Enter "Under 5,000",
"5,000 to 10,000", "More than 10,000" or "Not Applicable".
       Not Applicable

20 How many records in the system are attributable to members of the public? Enter
"Under 100,000", "100,000 to 1,000,000", "More than 1,000,000" or "Not applicable".
       More than 1,000,000

22 How is access to SBU/PII determined and by whom?
       Users are provided access to the EEFax system through use of the Business
       Entitlement Access Request System (BEARS) process. User requests are
       approved by their managers, which are then routed to the EEFax Project
       Management Office (PMO) queue for approval. The EEFax PMO determines
       what resources the user needs access to and is annotated in the BEARS request.
       Once approved by the EEFax PMO, the request is then routed to the EEFax
       System Administrators, who in turn add the user's domain account information to
       the EEFax system. Once a user no longer requires access to the system, the user
       performs a BEARS DELETE request which is approved by the EEFax PMO and
       routed to the EEFax System Administrators and the user’s access privileges are
       removed. EEFax PMO employees and contractors have access to the EEFax
       system database tables for running reports. EEFax PMO employees and
       contractors obtain access by using the BEARS process. Employee and contractor
       requests are approved by the EEFax PMO and then by their managers. When
       access to the database tables is no longer needed, EEFax PMO employees and
       contractors submit a BEARS DELETE request and access rights to the database
       are removed.

23 Is there a data dictionary on file for this system? Note: Selecting "Yes" indicates an
upload to the Attachment Section is required.
       Yes

24 Explain any privacy and civil liberties risks related to privacy controls.
       There are no privacy and civil liberties risks related to privacy controls.

25 Please upload all privacy risk finding documents identified for the system (Audit trail,
RAFT, POA&M, Breach Plan, etc.); click "yes" to confirm upload(s) are complete.
       No

26 Describe this system's audit trail in detail. Provide supporting documents.
       There are advanced audit logs that are saved for each outgoing and incoming fax.
       These audit logs are stored with the Job Track data base that is stored within
       Structured Query Language (SQL) servers on the EEFax infrastructure. This data
       is available to be searched, analyzed and audited but these logs do not contain any
       PII or other sensitive information that would be subject to any other external
       auditing systems as the data is not identifiable. There are user logs for users with
       admin level access for Enterprise Operations (EOps) to the EEFax Servers that are
       sent to Splunk.
       The Job Track data captures all metadata associated with receiving the fax:
       - Job ID - Unique key for the system
       - Computer Name - ID of the Faxcom Server that received the fax
       - Creation Date - The Greenwich Mean Time (GMT) date and time the fax was
       received
       - Status Value - The result of the fax reception
       - Transmitting Station Identifier (TSI) - Phone number passed by the sending fax
       - Caller ID - Phone number from Caller ID service
       - Connect Time - Length of time the call is connected while the fax is sent
       - Transfer Rate - Data transfer rate in baud, or symbols per second
      - Fall Back - Boolean value, a logical data type having one or two values, true if
      the final transfer rate is lower than the one originally negotiated
      - Pages - Number of pages (including the cover) received as part of the fax
      - Fax Port - Port number on which the fax is received
      - Direct Inward Dial (DID) - Dial number that the fax sender dialed
      - bActive - Boolean value, true until the fax has been delivered to its destination
      - bError - Boolean value, true if any route were to fail.

27 Does this system use or plan to use SBU data in a non-production environment?
      No


Interfaces
      Interface Type
             Forms
      Agency Name
             Analog Telephony System
      Incoming/Outgoing
             Both
      Transfer Method
             Enterprise Fax (eFax)

      Interface Type
             IRS Systems, file, or database
      Agency Name
             Enterprise File Storage (EFS)
      Incoming/Outgoing
             Outgoing (Sending)
      Transfer Method
             Electronic File Transfer Utility (EFTU)


Systems of Records Notices (SORNs)
      SORN Number & Name
             IRS 00.001 - Correspondence Files and Correspondence Control
             Files
      Describe the IRS use and relevance of this SORN.
             The legal right to ask for information is Internal Revenue Code
             sections 6001, 6011, and 6012(a), and their regulations. These
             sections state that individuals must file a return or statement with
             IRS for any tax for which they are liable, and response is
             mandatory.
Records Retention
   What is the Record Schedule System?
          Non-Record
   What type of Records is this for?
          Electronic
   Please provide a brief description of the chosen GRS or RCS item.
          The system does not retain records
   What is the disposition schedule?
          Information is only (temporarily) stored for the purpose of
          transmission and receipt.


Data Locations
   What type of site is this?
          System
   What is the name of the System?
          Splunk
   Please provide a brief description of the System.
          Splunk is an IRS system that pulls audit logs as it relates to server
          operations.
   What are the incoming connections to this System?
          Splunk can pull audit logs further analysis
   What are the outgoing connections from this System?
          None

   What type of site is this?
          System
   What is the name of the System?
          JobTrack Database
   Please provide a brief description of the System.
          The JobTrack database collects and stores metadata from fax
          transmissions but does not store any PII
   What are the incoming connections to this System?
          The EEFax system sends fax transmission and receipt metadata to
          this system.

   What type of site is this?
          System
   What is the name of the System?
          Enterprise Electronic Fax
   What is the sensitivity of the System?
          Federal Tax Information (FTI)
Please provide a brief description of the System.
       EEFax electronically sends and receives facsimiles. The
       information that comes in sent and received on a traditional
       facsimile machine is the same information that comes into EEFax
       (i.e. the same fax protocols). No data is parsed or extracted from
       the fax files. Possible information could include (but not limited
       to) taxpayer information in the form of signature documents, tax
       returns, and income verification requests. The files fax messages
       are stored only long enough for the system to verify delivery to the
       final destination. The only exceptions to this rule are faxes sent to
       high-speed printers. Faxes destined for printing are retained for a
       period of five days so faxes can be reprinted in case there is a
       printer malfunction. When faxes are received, they are delivered to
       High-Speed Printer(s), SharePoint Uniform Resource Locator
       (URL), Universal Naming Convention (UNC) File Storage,
       Individual or Organizational Mailbox. The majority of the EEFax
       traffic is to and from the Exchange email environment. EEFax
       messages delivered to Individual or Organizational mailboxes are
       unencrypted. EEFax messages sent from Outlook clients are
       unencrypted and without a digital signature. EEFax is projected to
       provide services for the entire enterprise and handle approximately
       20M fax pages per month. EEFax will maintain employee standard
       employer identifier (SEID) and employee e-mail address
       information in the activity logs to track audit trails on fax activity.
       These audit logs are stored in the JobTrack data base that is stored
       within SQL servers in EEFax. This data is available to be searched,
       analyzed and audited but these logs do not contain any PII or other
       sensitive information that would be subject to any other external
       auditing systems as the data is not identifiable. There are user logs
       for users with admin level access (EOPS) to the EEFax Servers
       that are sent to SPLUNK.
What are the incoming connections to this System?
       Analog Phone (via Public Switch Telephone Network (PSTN))
What are the outgoing connections from this System?
       Analog Phone, VoIP, FoIP via PSTN


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