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This management instruction (1) provides procedural instructions for
requesting and approving computer matching programs; and (2)
describes and delineates the membership and responsibilities of the
Postal Service Data Integrity Board.
Computer matching is a term used to describe the automated comparison of databases containing records about individuals. Purposes for
matching include the following:
• Verifying the accuracy of data.
• Uncovering waste, fraud, or abuse in federal programs.
• Locating specific individuals (e.g., absent parents owing child
support or persons indebted to the government).
• Determining eligibility for federal or state benefits.
Most matching programs in which the Postal Service™ participates:
• Originate with an agency that has management responsibility for
a program relating to one of these matching purposes.
• Involve a comparison of employee data from Privacy Act system
USPS 100.400 Personnel Compensation and Payroll Records
(see the Appendix to Handbook AS-353, Guide to Privacy and
Freedom of Information Act).
Disclosure of information is limited to that needed to accomplish the
matching purpose.
A computer matching program compares the following:
1. A Postal Service automated system of records with an automated
system of records of another federal agency, or with nonfederal
records, for the purpose of:
a. Establishing or verifying the eligibility of individuals, or their
continuing compliance with statutory and regulatory
requirements, for cash or in-kind assistance, or payments
under federal benefit programs.
b. Recouping payments or delinquent debts under such federal
benefit programs.
2. A Postal Service automated personnel or payroll system of
records with another automated personnel or payroll system of
records of the Postal Service or another federal agency or with
nonfederal records.
Under the Privacy Act of 1974, the Postal Service must do the following:
1. Publish in the Federal Register and forward to Congress and the
Office of Management and Budget (OMB) adequate advance
notice of any proposal to establish or modify, or alter the uses of,
any system of records that contains information about persons.
2. Comply with certain requirements for the collection, use,
disclosure, and safeguarding of information about individuals.
3. Permit an individual to:
a. Determine which records the Postal Service has filed or
cross-indexed under that individual's name.
b. Gain access to and have a copy made of the pertinent
information in those records.
c. Amend or correct the records.
d. Determine the use and disclosures made of the records.
More specifically, under the procedural requirements of the Privacy Act,
as amended by the Computer Matching and Privacy Protection Act of
1988, agencies that plan to compare their records must do the following:
1. Execute computer matching agreements.
2. Establish a Data Integrity Board to oversee agency computer
matching activities.
3. Publish in the Federal Register and forward to Congress and
OMB advance notice of its intent to establish, substantially revise,
or renew a computer matching program, unless such notice is
published by another participant agency. Agencies must publish
notice in accordance with the Privacy Act of 1974, as amended
prior to:
a. Initiation of any matching activity carried out under a new or
substantially revised program.
b. Expiration of an existing agreement.
Congress and OMB must receive notification of the computer matching
program in advance of its becoming effective in accordance with the
Privacy Act of 1974, as amended.
Records may not be exchanged for a matching program until all of the
following requirements of the Privacy Act and OMB implementing guidelines have been met:
1. Disclosure may occur only if permitted by the Privacy Act or as a
routine use of the system of records. The manager of the
Records Office will advise on the applicability of a routine use.
2. The Postal Service Data Integrity Board has approved a written
agreement specifying the terms under which a matching program
will be accomplished.
3. Advance notice has been published in the Federal Register and
forwarded to Congress and OMB.
Any agency or Postal Service organization that wishes to use records
from a Postal Service automated system of records in a computerized
comparison with other records must submit its proposal to the Postal
Service manager of the Records Office. For proposal specifications, see
below under Concluding and Submitting a Computer Matching Agreement.
The initiating agency or Postal Service organization should submit the
proposal at least three months in advance of the anticipated starting date
to allow time to meet Privacy Act publication and review requirements.
All proposals, whether from Postal Service organizations or other governmental agencies, must be submitted to:
MANAGER RECORDS OFFICE
POSTAL SERVICE
475 L'ENFANT PLAZA SW
WASHINGTON DC 20260-5846
The Postal Inspection Service must submit its proposals for matching
programs to the manager of the Records Office through:
COUNSEL
POSTAL INSPECTION SERVICE
475 L'ENFANT PLAZA SW
WASHINGTON DC 20260-2181
Participants in a computer matching program must conclude a written
agreement specifying the terms under which they will accomplish the
matching program. The participants will then submit this agreement to
the Postal Service Data Integrity Board for review.
The proposal and agreement must specify the following:
1. The purpose and legal authority for conducting the program.
2. The justification for the program and the anticipated results,
including a specific estimate of any savings in terms of expected
costs and benefits, when appropriate. Cost-benefit data must be
in sufficient detail for the Data Integrity Board to make an
informed decision.
3. A description of the records that will be matched, including the
data elements to be used, the approximate number of records,
and the projected starting and completion dates of the matching
program.
4. Procedures for providing individualized notice that information
provided by individuals may be subject to verification through
matching programs.
5. Procedures for verifying information produced in a matching
program. (An agency may not take adverse action against an
individual as a result of information produced by a matching
program until the agency has independently verified the
information.)
6. Procedures for ensuring the administrative, technical, and
physical security of the records matched; for the retention and
timely destruction of records created by the matching program;
and for the use and return or destruction of records used in the
program.
7. Prohibitions concerning duplication and redisclosure of records
exchanges, except where required by law or essential to the
conduct of the matching program.
8. Information on assessments that have been made on the
accuracy of records to be used in the matching program.
9. A statement that the Comptroller General may have access to all
records of the participating agencies in order to monitor
compliance with the agreement.
Before the Postal Service may participate in a computer matching program, the Postal Service Data Integrity Board must review the proposed
matching program and unanimously approve the matching agreement.
The Chair executes approved agreements. If the Board disapproves a
matching agreement, any party may appeal within 30 days following the
Board's written disapproval by writing to:
DIRECTOR
OFFICE OF MANAGEMENT AND BUDGET
WASHINGTON DC 20505-0001
The agreement will become effective in accordance with the date in the
matching agreement and as provided to Congress and OMB and published in the Federal Register. The agreement may remain in effect only
as long as necessary to accomplish the specific matching purpose, but
this period may not exceed 18 months. The Postal Service Data Integrity
Board may extend an agreement for one additional year, without further
review, if within 3 months prior to expiration of the 18-month period it
finds that the matching program will be conducted without change and
if each party to the agreement certifies that the program has been conducted in compliance with the matching agreement. Renewal of a
matching program requires execution of a new computer matching
agreement that has received Board review and approval.
If the other agency performs the physical computer comparison, and if
records about all individuals within a system of records are disclosed
outside of the Postal Service, the accounting of disclosure may be in the
form of a memo to the file or other media, but must indicate the following:
• The date of disclosure.
• The data elements disclosed about each individual (e.g., name
and Social Security number).
• The systems of records from which records were disclosed.
• The matching program.
• The name and address of the agency or person to whom the
disclosure was made.
If the Postal Service performs the physical computer comparison, and
if records about specific individuals (e.g., individuals common to both
automated files) within a system of records are disclosed outside of the
Postal Service, an exact copy of the tape or document containing the
disclosed information must be kept with the name and address of the
agency or person to whom disclosure was made.
The Postal Service may participate in computer matches on a cost-reimbursable basis whenever, in its opinion, the level of effort warrants. The
Postal Service will notify the agency to be charged, in writing, of the
approximate costs before they are incurred. The schedule in Chapter 4
of Handbook AS-353 directs how to calculate the costs.
The Postal Service Data Integrity Board oversees and coordinates Postal Service computer matching activities. Its principle function is to review
and approve all written agreements for receipt or disclosure of Postal
Service records for matching programs and to ensure compliance with
the Privacy Act. The Privacy Act requires that the senior official responsible for implementation of Postal Service policy and the Inspector General serve on the Board. The Board's membership consists as follows:
Vice President, Consumer Advocate (Chairman).
Executive Vice President, Chief Human Resources Officer
Chief Postal Inspector.
Inspector General.
General Counsel.
Chief Privacy Officer (Secretary).
The Board:
1. Reviews, approves, and maintains all written agreements for
receipt or disclosure of Postal Service records for matching
programs to ensure compliance with the Privacy Act and with all
relevant statutes, regulations, and guidelines.
2. Reviews all matching programs in which the Postal Service has
participated during the year; determines compliance with
applicable laws, regulations, guidelines, and agency agreements;
and assesses the costs and benefits of such programs.
3. Reviews all recurring matching programs in which the Postal
Service has participated during the year for continued justification
for such disclosures.
4. Compiles a biannual report, to be submitted to the Postmaster
General and the OMB and made available to the public on
request, describing the matching activities of the Postal Service.
This report must include the following:
a. Matching programs in which the Postal Service has
participated.
b. Proposed matching agreements that the Board disapproved.
c. Any changes in membership or structure of the Board in the
preceding year.
d. The reasons for any waiver of the requirement for a
cost-benefit analysis.
e. Any alleged or identified violations of matching agreements
and any corrective action taken.
f. Any other information that the director of the OMB requires to
be included in such report.
5. Serves as a clearinghouse for receiving and providing information
on the accuracy, completeness, and reliability of records used in
matching programs.
6. Provides interpretation and guidance to Postal Service
components and personnel on the requirements of this section for
matching programs.
7. Reviews recordkeeping and disposal policies and practices for
matching programs to assure compliance with this section.
8. Reviews and reports on any matching activities that are not
matching programs.
The Board will meet often enough to ensure that matching programs are
carried out efficiently, expeditiously, and in conformance with statutory
requirements.
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