Data Mining: Agencies Have Taken Key Steps to Protect Privacy in 
Selected Efforts, but Significant Compliance Issues Remain	 
(15-AUG-05, GAO-05-866).					 
                                                                 
Data mining--a technique for extracting knowledge from large	 
volumes of data--is being used increasingly by the government and
by the private sector. Many federal data mining efforts involve  
the use of personal information, which can originate from	 
government sources as well as private sector organizations. The  
federal government's increased use of data mining since the	 
terrorist attacks of September 11, 2001, has raised public and	 
congressional concerns. As a result, GAO was asked to describe	 
the characteristics of five federal data mining efforts and to	 
determine whether agencies are providing adequate privacy and	 
security protection for the information systems used in the	 
efforts and for individuals potentially affected by these data	 
mining efforts. 						 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-866 					        
    ACCNO:   A33097						        
  TITLE:     Data Mining: Agencies Have Taken Key Steps to Protect    
Privacy in Selected Efforts, but Significant Compliance Issues	 
Remain								 
     DATE:   08/15/2005 
  SUBJECT:   Data mining					 
	     Federal agencies					 
	     Information security				 
	     Information security management			 
	     Information systems				 
	     Privacy law					 
	     Privacy policies					 
	     Privacy policy violation				 
	     Private sector					 
	     Right of privacy					 
	     Noncompliance					 
	     Data collection					 
	     Personal information				 
	     Federal Crop Insurance Program			 
	     Foreign Terrorist Tracking Task Force		 
	     Government Purchase Card Program			 
	     IRS Reveal System					 
	     SBA Loan Monitoring System 			 

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GAO-05-866

     

     * Report to the Ranking Minority Member, Subcommittee on Oversight of
       Government Management, Committee on Homeland Security and Governmental
       Affairs, U.S. Senate
          * August 2005
     * DATA MINING
          * Agencies Have Taken Key Steps to Protect Privacy in Selected
            Efforts, but Significant Compliance Issues Remain
     * Contents
          * Results in Brief
          * Background
               * Data Mining Poses Privacy Challenge
               * Federal Laws and Guidance Define Steps to Protect Privacy of
                 Personal Information
               * Agencies Are Allowed to Claim Exemptions from Some Privacy
                 Provisions
          * Data Mining Efforts Have a Variety of Characteristics
          * Agencies Addressed Many Required Privacy Provisions, but None
            Addressed All Requirements
               * Agencies Generally Provided Public Notice as Required
               * Two Agencies Allowed Individuals to Access their
                 Information; Others Were Exempt
               * Three Agencies Fulfilled or Partially Fulfilled Requirements
                 Regarding the Notification of Individuals When Personal
                 Information Is Collected
               * Agencies' Actions to Ensure Security of Data Mining Efforts
                 and Quality of Information They Used Were Inconsistent
               * Five Agencies Lacked Comprehensive Privacy Impact
                 Assessments for Their Data Mining Efforts
          * Conclusions
          * Recommendations
          * Agency Comments and Our Evaluation
     * Scope and Methodology
     * Risk Management Agency's Data Mining Effort
          * Purpose and Uses
               * How It Works
          * Inputs
               * Government Data from Systems of Records
               * Government Data Not from Systems of Records
               * Public Data
          * Outputs
     * The Citibank Custom Reporting System Used by the Department of State
          * Purpose and Uses
               * How It Works
          * Inputs
               * Government Data Not from Systems of Records
               * Commercial Data
          * Outputs
     * Internal Revenue Service's Reveal System
          * Purpose and Uses
               * How It Works
          * Inputs
               * Government Data from Systems of Records
          * Outputs
     * FBI's Foreign Terrorist Tracking Task Force Data Mining Effort
          * Purpose and Uses
               * How It Works
          * Inputs
               * Government Data from Systems of Records
               * Government Data Not from Systems of Records
               * Commercial Data
               * Data from International Entities
          * Outputs
     * Small Business Administration's Loan/Lender Monitoring System
          * Purpose and Uses
               * How it Works
          * Inputs
               * Government Data from Systems of Records
               * Commercial Data
          * Outputs
     * Detailed Assessments of Agency Actions to Address Security
       Requirements in Data Mining Efforts
     * Comments from the U.S. Department of Agriculture
     * Comments from the Department of the Treasury
     * Comments from the Department of State
     * Comments from the Small Business Administration
     * GAO Contact and Staff Acknowledgments

                 United States Government Accountability Office

Report to the Ranking Minority Member,

Subcommittee on Oversight of Government Management, Committee on Homeland
                 Security and Governmental Affairs, U.S. Senate

August 2005

DATA MINING

Agencies Have Taken Key Steps to Protect Privacy in Selected Efforts, but
                      Significant Compliance Issues Remain

                                       a

GAO-05-866

DATA MINING

Agencies Have Taken Key Steps to Protect Privacy in Selected Efforts, but
Significant Compliance Issues Remain

  What GAO Found

The five data mining efforts we reviewed are used by federal agencies to
fulfill a variety of purposes and use various information sources,
including both information collected on behalf of the agency and
information originally collected by other agencies and commercial sources.
Although the systems differed, the general process each used was basically
the same. Each system incorporates data input, data analysis, and results
output (see figure).

                            The Data Mining Process

                                     Input

Source: GAO, adapted from Vipin Kumar and Mohammed J. Zaki.

While the agencies responsible for these five efforts took many of the key
steps required by federal law and executive branch guidance for the
protection of personal information, they did not comply with all related
laws and guidance. Specifically, most agencies notified the general public
that they were collecting and using personal information and provided
opportunities for individuals to review personal information when required
by the Privacy Act. However, agencies are also required to provide notice
to individual respondents explaining why the information is being
collected; two agencies provided this notice, one did not provide it, and
two claimed an allowable exemption from this requirement because the
systems were used for law enforcement. In addition, agency compliance with
key security requirements was inconsistent. Finally, three of the five
agencies completed privacy impact assessments-important for analyzing the
privacy implications of a system or data collection-but none of the
assessments fully complied with Office of Management and Budget guidance.
Until agencies fully comply with these requirements, they lack assurance
that individual privacy rights are being appropriately protected.

                 United States Government Accountability Office

Contents

  Letter 1

Results in Brief 2 Background 4 Data Mining Efforts Have a Variety of
Characteristics 11 Agencies Addressed Many Required Privacy Provisions,
but None

Addressed All Requirements 14 Conclusions 28 Recommendations 28 Agency
Comments and Our Evaluation 31

  Appendixes

                                       Appendix I: Appendix II: Appendix III:

Appendix IV: Appendix V:

Appendix VI:

    Appendix VII:

           Appendix VIII: Appendix IX: Appendix X: Appendix XI: Appendix XII:

Scope and Methodology 35 Risk Management Agency's Data Mining Effort 38
The Citibank Custom Reporting System Used by the Department of State 44
Internal Revenue Service's Reveal System 50 FBI's Foreign Terrorist
Tracking Task Force Data Mining Effort 54 Small Business Administration's
Loan/Lender Monitoring System 59 Detailed Assessments of Agency Actions to
Address Security Requirements in Data Mining Efforts 63 Comments from the
U.S. Department of Agriculture 65 Comments from the Department of the
Treasury 69 Comments from the Department of State 71 Comments from the
Small Business Administration 74 GAO Contact and Staff Acknowledgments 76

Table 1:

  Tables

Table 2: Table 3:

Key Steps Agencies Are Required to Take to Protect Privacy, with Examples
of Related Detailed Procedures and Sources 9 Examples of Privacy Act
Provisions from Which Systems of Records Used in Law Enforcement May Be
Exempt 10 Characteristics of Information Inputs Used by the Data Mining
Efforts We Reviewed 14

Contents

Table 4:  Questions Related to Agency Actions to Notify the Public   
                about New or Changed Information Collections or
Efforts                                                                 16 
Table 5:  Questions Related to Agency Actions to Provide             
             Individuals with Access to Their Personal Records             18 
Table 6:  Questions Related to Agency Actions to Notify Individuals  
             at the Time Personal Information Was Collected                20 
Table 7:  Questions Related to Agency Actions Safeguarding and       
Ensuring the Quality of Records Containing Personal                  
Information                                                             22 
Table 8:  Questions Related to Agency Actions to Conduct Privacy     
             Impact Assessments                                            25 
Table 9:  Scenarios Used to Identify Potential Abusers                  40 
Table 10: Questions Related to Agency Actions Safeguarding and       
Ensuring the Quality of Records Containing Personal                  
Information                                                             64 

Figure 1:

  Figures

Figure 2: Figure 3:

Figure 4: Figure 5:

Figure 6: An Overview of the Data Mining Process 6 An Overview of the RMA
System 41 An Overview of the Citibank Custom Reporting System 46 An
Overview of the Reveal Data Mining System 52 An Overview of FBI's Foreign
Terrorist Tracking Task Force Data Mining Effort 56 An Overview of the
Loan/Lender Monitoring System 61

                                 Abbreviations

CIO         chief information officer                        
FBI         Federal Bureau of Investigation                  
FISMA       Federal Information Security Management Act      
GSA         General Services Administration                  
IRS         Internal Revenue Service                         
NIST        National Institute of Standards and Technology   
OMB         Office of Management and Budget                  
RMA         Risk Management Agency                           
SBA         Small Business Administration                    

Contents

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separately.

A

United States Government Accountability Office Washington, D.C. 20548

August 15, 2005

The Honorable Daniel K. Akaka Ranking Minority Member Subcommittee on
Oversight of Government Management Committee on Homeland Security and
Governmental Affairs United States Senate

Dear Senator Akaka:

Data mining-a technique for extracting knowledge from large volumes of
data-is being used increasingly by the government and by the private
sector. Many federal data mining efforts involve the use of personal
information, which can originate from government sources as well as
private sector organizations.1

This report responds to your request that we review federal data mining
efforts that use personal information. Specifically, our objectives were
to describe the characteristics of selected federal data mining efforts,
including each system's data sources, outputs, and uses, and to determine
whether agencies are providing adequate privacy and security protections
for the information systems used in these efforts and for individuals
potentially affected by them.

To address these objectives, we reviewed five data mining efforts at the
Small Business Administration (SBA), the Department of Agriculture's Risk
Management Agency (RMA), the Department of the Treasury's Internal Revenue
Service (IRS), the Department of State (State), and the Department of
Justice's Federal Bureau of Investigation (FBI). These efforts were
selected for review because they met several criteria, including the use
of personal information and data obtained from another agency or a private
sector source, and because they were used for one of

1For purposes of this report, we define "personal information" consistent
with the Privacy Act's definition of a "record," which includes all
information associated with an individual and includes both identifying
information and nonidentifying information. Identifying information, which
can be used to locate or identify an individual, includes name, aliases,
Social Security number, e-mail address, driver's license identification
number, and agency-assigned case number. In this report, we refer to
identifying personal information as personal identifiers. Nonidentifying
personal information includes age, education, finances, criminal history,
physical attributes, and gender.

                                Results in Brief

several specific purposes.2 To address both objectives, we reviewed
agency-provided documents and interviewed agency officials. To evaluate
the agencies' implementation of key privacy protections, we also reviewed
related notices, reports, and other documents. Our scope and methodology
are discussed in more detail in appendix I.

We performed our work from May 2004 to June 2005 in accordance with
generally accepted government auditing standards.

The data mining efforts we reviewed have a variety of purposes and uses
and employ different data inputs and outputs. In addition to information
collected directly from individuals, the efforts use information provided
by other agencies (such as the National Oceanic and Atmospheric
Administration) and private sector sources (such as credit card
companies). These efforts include the following:

     o The RMA effort is used to detect fraud, waste, and abuse in the
       Federal Crop Insurance Program.
     o The Citibank Custom Reporting System, an offering of the General
       Service Administration's Government-wide Purchase Card program, is
       used by State to analyze government charge card spending patterns by
       its employees.
     o The data mining effort of the FBI Foreign Terrorist Tracking Task
       Force helps federal law enforcement and intelligence agencies locate
       foreign terrorists and their supporters in the United States.
     o The IRS's Reveal system is used to detect evidence of financial
       crimes, fraud, and terrorist activity.
     o The SBA Lender/Loan Monitoring System, provided under contract by Dun
       & Bradstreet, is designed to identify, measure, and manage risk in two
       SBA loan programs.

2We selected efforts that were intended to meet at least one of the
following purposes: improving service or performance; detecting fraud,
waste, and abuse; detecting criminal activities or patterns; or analyzing
intelligence and detecting terrorist activities.

Page 2 GAO-05-866 Data Mining

While the agencies responsible for these five efforts took many of the key
steps required by federal law and executive branch guidance for the
protection of personal information, none followed all key procedures.
Specifically, most agencies notified the general public that they were
collecting and using personal information and provided opportunities for
individuals to review personal information, when required by the Privacy
Act. However, agencies are also required to provide notice to individual
respondents explaining why information is being collected: two agencies
provided this notice, one did not provide it, and two claimed an allowable
exemption from this requirement because the systems were used for law
enforcement. Agencies' compliance with key security requirements that are
intended to protect the confidentiality and integrity of personal
information was inconsistent. Finally, three of the five agencies had
prepared a privacy impact assessment-an important tool for analyzing the
privacy implications of a system or data collection-of their data mining
efforts, but none of the assessments fully complied with Office of
Management and Budget (OMB) guidance. Until agencies fully comply with
these requirements, they lack assurance that individual privacy rights are
appropriately protected.

We are making recommendations to the agencies responsible for the five
data mining efforts to ensure that their efforts include adequate privacy
and security protections.

In providing comments on a draft of this report, the agencies generally
agreed with the majority of our recommendations, but disagreed with
others. USDA agreed with the majority of our recommendations, and stated
that it plans to take the necessary steps to address them. The General
Service Administration's (GSA) Assistant Commissioner for Acquisition (who
provided comments via e-mail) generally disagreed with our
recommendations, stating that the Privacy Act does not apply to its system
and that it had taken appropriate security measures. However, in our view,
GSA's system is subject to the Privacy Act. Additionally, while we
acknowledge GSA's efforts to secure its system, it is nonetheless required
to comply with the specific requirements of the Federal Information
Security Management Act of 2002 and with related guidance. State and SBA
generally agreed with our recommendations and provided information on
their planned actions. Treasury generally agreed with the recommendation
to conduct a new privacy impact assessment, but in response to our
recommendation on security, Treasury stated that it believes it already
has adequate security measures in place. We acknowledge that while
Treasury has applied several security measures, required regular testing
and

                                   Background

evaluation was not yet in place and we have clarified our recommendation
to reflect this. Justice stated that it had no comments on our draft.

In our May 2004 report on federal data mining efforts,3 we defined data
mining as the application of database technology and techniques-such as
statistical analysis and modeling-to uncover hidden patterns and subtle
relationships in data and to infer rules that allow for the prediction of
future results. We based this definition on the most commonly used terms
found in a survey of the technical literature. For the purposes of this
report, we are using the same definition.

Data mining has been used successfully for a number of years in the
private and public sectors in a broad range of applications. In the
private sector, these applications include customer relationship
management, market research, retail and supply chain analysis, medical
analysis and diagnostics, financial analysis, and fraud detection. In the
government, data mining was initially used to detect financial fraud and
abuse. For example, we used data mining techniques in our prior reviews of
federal government purchase and credit card programs.4

Following the terrorist attacks of September 11, 2001, data mining has
been used increasingly as a tool to help detect terrorist threats through
the collection and analysis of public and private sector data. Its use has
also expanded to other purposes. In our May 2004 report,5 we identified
several uses of federal data mining efforts. The most common were

     o improving service or performance;
     o detecting fraud, waste, and abuse;
     o analyzing scientific and research information;

3GAO, Data Mining: Federal Efforts Cover a Wide Range of Uses, GAO-04-548
(Washington, D.C.: May 4, 2004).

4For more information on the uses of data mining in GAO audits, see GAO,
Data Mining: Results and Challenges for Government Programs, Audits, and
Investigations,

G AO-03-591T (Washington, D.C.: Mar. 25, 2003).

5 GAO-04-548.

Page 4 GAO-05-866 Data Mining

     o managing human resources;
     o detecting criminal activities or patterns; and
          * analyzing intelligence and detecting terrorist activities.
          * While the characteristics of each data mining effort can vary
            greatly, data mining generally incorporates three processes: data
            input, data analysis, and results output. In data input, data are
            collected in a central data warehouse, validated, and formatted
            for use in data mining. In the data analysis phase, data are
            typically searched through a query. The two most common types of
            queries are pattern-based queries and subject-based queries.
     o Pattern-based queries search for data elements that match or depart
       from a predetermined pattern (e.g., unusual claim patterns in an
       insurance program).
     o Subject-based queries search for any available information on a
       predetermined subject using a specific identifier. This could be
       personal information such as an individual identifier (e.g., a Social
       Security number or the name of a person) or the identifier of a
       specific thing. For example, the Navy uses subject-based data mining
       to identify trends in the failure rate of parts used in its ships.

The data analysis phase can be iterative, with the results of one query
being used to define criteria for a subsequent query. The output phase can
produce results in printed or electronic format. These reports can be
accessed by agency personnel, and can also be shared with other personnel
from other agencies. Figure 1 depicts a generic data mining process.

Figure 1: An Overview of the Data Mining Process

    Data Mining Poses Privacy Challenge

Source: GAO, adapted from Vipin Kumar and Mohammed J. Zaki.

Note: From Vipin Kumar and Mohammed J. Zaki, High Performance Data Mining,
University of Minnesota, undated;
http://www.cs.rpi.edu/~zaki?PSKDDTUT00.pdf .

The impact of computer systems on the ability of organizations to protect
personal information was recognized as early as 1973, when a federal
advisory committee on automated personal data systems observed that "The
computer enables organizations to enlarge their data processing capacity
substantially, while greatly facilitating access to recorded data, both
within organizations and across boundaries that separate them." In
addition, the committee concluded that "The net effect of computerization
is that it is becoming much easier for record-keeping systems to affect
people than for people to affect record-keeping systems."6

6U.S. Department of Health, Education, and Welfare, Records, Computers and
the Rights of Citizens, Report of the Secretary's Advisory Committee on
Automated Personal Data Systems (July 1973).

Page 6 GAO-05-866 Data Mining

    Federal Laws and Guidance Define Steps to Protect Privacy of Personal
    Information

More recently, the federal government's increased use of data mining has
raised public and congressional concerns. A December 2003 report by a task
force on information sharing and analysis in homeland security noted that
agencies at all levels of government are now interested in collecting and
mining large amounts of data from commercial sources.7 The report noted
that agencies may use such data not only for investigations of specific
individuals, but also to perform large-scale data analysis and pattern
discovery in order to discern potential terrorist activity by unknown
individuals.

As we noted in our May 2004 report, mining government and private
databases containing personal information creates a range of privacy
concerns. Through data mining, agencies can quickly and efficiently obtain
information on individuals or groups by exploiting large databases
containing personal information aggregated from public and private
records. Information can be developed about a specific individual or a
group of individuals whose behavior or characteristics fit a specific
pattern. The ease with which organizations can use automated systems to
gather and analyze large amounts of previously isolated information raises
concerns about the impact on personal privacy. Before data aggregation and
data mining came into use, personal information contained in paper records
stored at widely dispersed locations, such as courthouses or other
government offices, was relatively difficult to gather and analyze.

The 1973 federal advisory committee recommended that the federal
government adopt a set of fair information practices to address what it
termed a poor level of protection afforded to privacy under contemporary
law. These practices formed the basis of the main federal privacy law, the
Privacy Act of 1974.

The Privacy Act places limitations on agencies' collection, disclosure,
and use of personal information maintained in systems of records. The act
describes "records" as any item, collection, or grouping of information
about an individual that is maintained by an agency and contains his name
or another personal identifier. It also describes systems of records as a
group of records under the control of any agency from which information is

7Markle Foundation, Creating a Trusted Network for Homeland Security (New
York: December 2003). h
ttp://www.markletaskforce.org/Report2_Full_Report.pdf (downloaded Mar. 28,
2005).

Page 7 GAO-05-866 Data Mining

retrieved by the name of the individual or by an individual identifier.8
The Privacy Act requires that when agencies establish or make changes to a
system of records, they must notify the public by a notice in the Federal
Register identifying the type of data collected, the types of individuals
that information is collected about, the intended routine uses of the
data, and procedures that individuals can use to review personal
information.

The Federal Information Security Management Act of 2002 (FISMA) also
addresses the protection of personal information. FISMA defines federal
requirements for securing information and information systems that support
federal agency operations and assets; it requires agencies to develop
agencywide information security programs that extend to contractors and
other providers of federal data and systems.9 Under FISMA, information
security includes protecting information and information systems from
unauthorized access, use, disclosure, disruption, modification, or
destruction, including controls for confidentiality-that is, those
controls necessary to preserve authorized restrictions on access and
disclosure to protect personal privacy.

A third federal law with provisions related to privacy, the E-Government
Act of 2002, provides additional protection for personal information in
government information systems or information collections by requiring
that agencies conduct privacy impact assessments.10 A privacy impact
assessment is

"an analysis of how information is handled: (i) to ensure handling
conforms to applicable legal, regulatory, and policy requirements
regarding privacy; (ii) to determine the risks and effects of collecting,
maintaining, and disseminating information in identifiable form in an
electronic information system; and (iii) to examine and evaluate
protections and alternative processes for handling information to mitigate
potential privacy risks."11

Agencies must conduct a privacy assessment (1) before developing or
procuring information technology that collects, maintains, or disseminates

85 U.S.C. S: 552a (a)(5).

9Federal Information Security Management Act of 2002, Title III,
E-Government Act of 2002, Pub. L. No. 107-347 (Dec. 17, 2002).
10E-Government Act of 2002, Pub. L. No. 107-347 (Dec. 17, 2002), sec. 208.
11Office of Management and Budget, Memorandum M-03-22, Guidance for
Implementing

the Privacy Provisions of the E-Government Act of 2002 (Washington, D.C.:
Sept. 26, 2003).

information that is in a personally identifiable form or (2) before
initiating any new electronic data collections containing personal
information on 10 or more individuals. Among other actions that should
require a privacy assessment, according to guidance from OMB, is
significant merging of information in databases, for example, in a linking
that "may aggregate data in ways that create privacy concerns not
previously at issue" or "when agencies systematically incorporate into
existing information systems databases of information in identifiable form
purchased or obtained from commercial or public sources."

These laws, along with OMB guidance that outlines how agencies are to
comply with the laws, lay out a series of steps that agencies should take
to protect the privacy of personal information. Each of the steps includes
detailed procedures agencies are to follow to fully implement the
requirements. Table 1 lists the key steps, with examples of the procedures
agencies are to use to address the step, and the primary statutory source
for the protections.

Table 1: Key Steps Agencies Are Required to Take to Protect Privacy, with
Examples of Related Detailed Procedures and Sources

Key steps to protect privacy of Primary statutory personal information
Examples of procedures source

Publish notice in the Federal  o  Specify the routine uses for the system 
o Privacy Act Register when creating or modifying  o  Identify the
individual responsible for the system system of records  o  Outline
procedures individuals can use to gain access to their

records

Provide individuals with access to  o  Permit individuals to review
records about themselves  o Privacy Act their records  o  Permit
individuals to request corrections to their records

Notify individuals of the purpose and  o  Notify individuals of the
authority that authorized the agency to  o Privacy Act authority for the
requested collect the information information when it is collected  o 
Notify individuals of the principal purposes for which the information

is to be used

Implement guidance on system  o  Perform a risk assessment to determine
the information system  o FISMA security and data quality vulnerabilities,
identify threats, and develop countermeasures to  o Privacy Act those
threats

     o Have the system certified and accredited by management
     o Ensure the accuracy, relevance, timeliness, and completeness of
       information

Conduct a privacy impact  o  Describe and analyze how information is
secured  o  E-Government Act assessment  o  Describe and analyze intended
use of information

     o Have assessment reviewed by chief information officer or equivalent
     o Make assessment publicly available, if practicable

Source: GAO analysis of the Privacy Act, E-Government Act, FISMA, and
related guidance.

    Agencies Are Allowed to Claim Exemptions from Some Privacy Provisions

While the federal laws and guidance previously outlined provide a wide
range of privacy protections, agencies are allowed to claim exemptions
from some of these provisions if the records are used for certain
purposes. For example, records compiled for criminal law enforcement
purposes can be exempt from a number of provisions of the Privacy Act,
including the requirement to notify individuals of the purposes and uses
of the information at the time of collection and the requirement to ensure
the accuracy, relevance, timeliness, and completeness of records. A
broader category of investigative records compiled for criminal or civil
law enforcement purposes can also be exempted from a somewhat smaller
number of Privacy Act provisions, including the requirement to provide
individuals with access to their records and to inform the public of the
categories of sources of records. In general, the exemptions for law
enforcement purposes are intended to prevent the disclosure of information
collected as part of an ongoing investigation that could impair the
investigation or allow those under investigation to change their behavior
or take other actions to escape prosecution.

The Privacy Act allows, but does not require, agencies to claim an
exemption for certain designated purposes. If the agency decides to claim
an exemption, the act requires the agencies to do so through a rule that
provides the reason behind its decision. Table 2 shows provisions of the
Privacy Act from which systems of records used for law enforcement may be
exempt.

 Table 2: Examples of Privacy Act Provisions from Which Systems of Records Used
                        in Law Enforcement May Be Exempt

                 Law enforcement exemptions in the Privacy Act

Information used for criminal law Information used in law Provision
enforcement enforcement investigations

Providing individuals with access to their information Can be exempt Can
be exempt and the ability to request corrections

Notifying individuals of the purposes and uses of the Can be exempt Not
exempt information at the time of collection

Maintaining records with the necessary accuracy, Can be exempt Not exempt
relevance, timeliness, and completeness

               Source: GAO analysis of federal laws and guidance.

  Data Mining Efforts Have a Variety of Characteristics

Similarly, the requirement to conduct a privacy impact assessment does not
apply to all systems. For example, no assessment is required when the
information collected relates to internal government operations, the
information has been previously assessed under an evaluation similar to a
privacy impact assessment, or when privacy issues are unchanged.
Nonetheless, OMB encourages agencies to conduct privacy impact assessments
on systems that contain personal information in identifiable form about
government personnel, when appropriate. In addition, individual agencies
have adopted policies that require assessments for all systems, including
those used for government operations.

In June 2003, we reported on our assessment of agencies' compliance with
the Privacy Act and related OMB guidance.12 At that time, we determined
that the agencies' compliance was high in many areas, but uneven across
the federal government. Agency officials attributed the areas of
noncompliance in part to a need for more leadership and guidance from OMB.
In our report, we recommended that the Director, OMB, take a number of
steps aimed at improving agencies' compliance with the Privacy Act,
including overseeing and monitoring agencies' actions, assessing the need
for additional guidance to agencies, and raising agency awareness of the
importance of the act. In response, OMB established an Interagency Privacy
Committee to discuss privacy issues and issued updated guidance. However,
it has not addressed our other recommendations: to work with agencies to
ensure that they address the areas of noncompliance we identified;
institute a governmentwide effort to determine the level of resources
needed to fully implement the Privacy Act; and develop a plan to address
identified gaps in resources devoted to protecting privacy.

The data mining efforts that we reviewed have a variety of purposes, uses,
and outputs. For example, the efforts are used for program management, law
enforcement, and analyzing intelligence. The efforts fulfill these
purposes through a mix of subject-based and pattern-based queries, as
previously defined, and result in reports that are used by program
officials or shared with others. A detailed summary of each of the efforts
we reviewed is included in appendixes II through VI. A short summary of
the purpose and characteristics of each of the efforts is included here.

12GAO, Privacy Act: OMB Leadership Needed to Improve Agency Compliance,
GAO-03-304 (Washington, D.C.: June 30, 2003).

Page 11 GAO-05-866 Data Mining

     o The purpose of RMA's data mining effort is to detect fraud, waste, and
       abuse in the federal crop insurance program. It is used to identify
       potential abusers, improve program policies and guidance, and improve
       program performance and data quality. RMA uses information collected
       from insurance applicants as well as from insurance agents and claims
       adjusters. It produces several types of outputs, including lists of
       names of individuals whose behavior matches patterns of anomalous
       behavior, which are provided to program investigators and sometimes
       insurance agencies. It also produces programmatic information, such as
       how a procedural change in the federal crop insurance program's policy
       manual would impact the overall effectiveness of the program, and
       information on data quality and program performance, both of which are
       used by program managers.
     o The purpose of the Citibank Custom Reporting System used by State is
       to detect fraud, waste, and abuse by its employees who use the
       government purchase card program. The purchase card program is a
       governmentwide program run by the General Services Administration
       (GSA). Agencies like State use GSA's master contract to provide their
       employees with charge cards from an approved vendor. Citibank, the
       vendor chosen by State, provides its customers with a custom reporting
       system, which includes several tools that can be used for managing
       card accounts. State uses the system to analyze government charge card
       spending patterns by its employees. System outputs include summaries
       of card account holder information and purchases and can include
       personal information. Summaries are used by program managers and are
       on occasion provided to interested parties such as such as State's
       inspector general, GAO, and OMB for oversight.
     o The purpose of IRS's Reveal system is to detect criminal activities or
       patterns, analyze intelligence, and detect terrorist activities. IRS
       uses the system to identify financial crime, including individual and
       corporate tax fraud, and terrorist activity. Its outputs include
       reports containing names, Social Security numbers, addresses, and
       other personal information of individuals suspected of financial
       crime, including individual and corporate tax fraud and terrorist
       activity. Reports are shared with IRS field office personnel, who
       conduct investigations based on the report's results.
          * The purpose of the data mining effort used by the FBI's Foreign
            Terrorist Tracking Task Force is to detect criminal or terrorist
            activities or patterns and to analyze intelligence. The effort
            uses two information
          * systems-one classified and one unclassified-to support ongoing
            investigations by law enforcement agencies and the intelligence
            community, including locating foreign terrorists and their
            supporters who are in or have visited the United States. Its
            outputs include reports based on a request received from field
            investigators. Reports range from lists of individuals who might
            meet a certain profile to detailed information on a certain
            suspect and typically contain personal information. Reports are
            shared with field investigators, field offices, and other federal
            investigators.
     o The purpose of SBA's Lender/Loan Monitoring System is to improve
       service or performance. The system was developed by Dun & Bradstreet
       under contract to SBA. SBA uses the system to identify, measure, and
       manage risk in two of its business loan programs. Its outputs include
       reports that identify the total amount of loans outstanding for a
       particular lender and estimate the likelihood of loans becoming
       delinquent in the future based on predefined patterns.

These systems use information that the agency collects directly, as well
as information provided by other agencies, such as the Social Security
Administration, and private sector sources, such as credit card companies.
Table 3 details the inputs of each effort we reviewed and summarizes each
effort by the types of information sources used.

 Table 3: Characteristics of Information Inputs Used by the Data Mining Efforts
                                  We Reviewed

                                Types of inputs
  Government  
                             Not                                              
  Data mining                identified  Commercial             International
                             as                                 
  effort      Systems of     systems of  sources    Public      records       
              records        records                records     
  RMA's data  4 sources,     3 sources:  None       Various     None          
  mining      including      soils data,            sources,    
  effort      insurance      weather                including   
              records on     data, and              publicly    
                             land                               
              policyholders, survey data            available   
              agents,                                           
              and loss                              information 
              adjusters                                         
  Citibank    None           Account     Commercial None        None          
  Custom                     information    data                
  Reporting                  from State    provided             
  System                     employees           by             
                                           Citibank             
  (State)                    provided to consisting             
                             Citibank    of                     
                                     information on             
                                  purchases made by             
                                    State employees             
  Reveal      4 sources,    None          None      None        None          
  (IRS)       including                                         
              suspicious                                        
              activity                                          
              reports and extracts of                           
              corporate and taxpayer                            
              information                                       
  Foreign     29 sources,        1      11 sources, None        4 sources,    
  Terrorist   including          source                         
  Tracking    information from           consisting               including   
  Task        FBI's                         of data                 lost      
  Force (FBI) criminal database,           from                 property      
                                        commercial              
              immigration and             sources               reported to   
              visa                                              
              data, and customs                                 Interpol and  
              data                                              
                                                                 intelligence 
                                                                         data 
  Loan/Lender 1 source,       None       3 sources, None        None          
              including loan              including             
  Monitoring  and lender             corporate- and             
  System      information                                       
  (SBA)       for SBA's loan         consumer-level             
                                               data             
              programs                from private              
                                          companies             

  Agencies Addressed Many Required Privacy Provisions, but None Addressed All
  Requirements

                  Source: GAO analysis of agency information.

While the agencies responsible for the five data mining efforts took many
of the key steps needed to protect the privacy and security of personal
information used in the efforts, none followed all the key procedures.
Most of the agencies provided a general public notice about the collection
and use of the personal information used in their data mining efforts.
However, fewer followed other required steps, such as notifying
individuals about the intended uses of their personal information when it
was collected or ensuring the security and accuracy of the information
used in their data mining efforts. In addition, three of the five agencies
completed a privacy impact assessment of their data mining efforts, but
none of the

    Agencies Generally Provided Public Notice as Required

assessments fully complied with OMB guidance. Complete assessments are a
tool agencies can use to identify areas of noncompliance with federal
privacy laws, evaluate risks arising from electronic collection and
maintenance of information about individuals, and evaluate protections or
alternative processes needed to mitigate the risks identified. Agencies
that do not take all the steps required to protect the privacy of personal
information limit the ability of individuals to participate in decisions
that affect them, as required by law, and risk the improper exposure or
alteration of their personal information.

The Privacy Act requires agencies to notify the public, through notices
published in the Federal Register, when they create or modify a system of
records. The act's provisions include requirements for agencies to provide
general notice about the operation and uses of a system of records.
According to OMB's guidance on implementing the act, this public notice
provision is central to one of the act's basic objectives: fostering
agency accountability through a system of public scrutiny. This echoes the
1973 federal advisory committee's statement that public involvement is
essential for an effective consideration of the pros and cons of
establishing a personal data system.

Of the five efforts we reviewed, the personal information used in four
(IRS, RMA, FBI, and SBA) were the subject of published system of records
notices in the Federal Register. The public was not notified in the case
of the fifth system-State. Table 4 details the steps agencies took to
notify the public about the five efforts we reviewed.

Table 4: Questions Related to Agency Actions to Notify the Public about
New or Changed Information Collections or Efforts

Question                                            Yes  Partial No Exempt 
Was a timely system of records notice published in  CDE  Aa      B  
the Federal Register?                                               
Did the notice indicate the name and location of    ACDE         B  
the system of records?                                              
Did the notice specify the category of individuals  ACDE         B  
in the system of records?                                           
Did the notice specify the category of records in   ACDE         B  
the system of records?                                              
Did the notice specify the routine uses of the      ACDE         B  
system of records?                                                  
Did the notice specify how the agency stores,       ACDE         B  
maintains, and accesses the records?                                
Did the notice identify the individual responsible  ACD  E       B  
for maintaining the information in the system of                    
records and give instructions on how to contact                     
that person?                                                        
Did the notice specify the process by which an           E       B  ACD    
individual can request notification if the system                   
contains records pertaining to him or her?                          
Did the notice specify the procedures by which an        E       B  ACD    
individual can gain access to a record pertaining                   
to him or her and challenge its contents?                           
Did the notice specify the categories of            DE           B  AC     
information sources used by the system?                             

Legend:

A: RMA's data mining effort

B: State's Citibank Custom Reporting System

C: IRS's Reveal effort

D: FBI's Foreign Terrorist Tracking Task Force effort

E: SBA's Lender/Loan Monitoring System Source: GAO analysis of agency
information.

aRMA's notice was not timely because it was published after its effort had
been implemented.

The published system of records notices related to the data mining efforts
at IRS, FBI, and RMA generally included the information required by the
Privacy Act. However, the notice published by SBA was only partially
compliant with the act because it did not clearly describe the process
individuals could use to review their information. For example, SBA's
notice listed several dozen contacts and indicated that individuals should
identify the appropriate contact from the list when making requests
related

    Two Agencies Allowed Individuals to Access their Information; Others Were
    Exempt

to their information. However, the notice did not describe how to identify
which contact would be appropriate.

No notice was published for the Citibank purchase card management tool
used by State. As the agency responsible for the governmentwide purchase
card program, GSA is responsible for ensuring that the program follows
statutory requirements, including those in the Privacy Act. However, it
has not published a system of records notice that would cover the
activities of State or other agencies participating in the program.
According to GSA officials, the agency did not consider purchase card
records to be a system of records because it believed the names and
addresses it collects pertain to government employees and thus are exempt
from the Privacy Act. The GSA officials added that a programwide system of
records notice has been partially drafted, but it has not been finalized
because it is waiting for guidance from OMB on a recent change to the
program that could require the collection of additional personal
information. Without adequate notice of this information collection
effort, the ability of State employees and the public to participate in
decisions about the collection and use of personal information, as
envisioned under the Privacy Act, is limited.

IRS, RMA, and FBI did not include in their notices a description of how
individuals can review their personal information because they claimed the
exemption available for records used in law enforcement.13

The Privacy Act requires agencies to, among other things, allow
individuals to (1) review their records (meaning any information
pertaining to them that is contained in the system of records), (2)
request a copy of their record or information from the system of records,
and (3) request corrections in their information. Such provisions can
provide a strong incentive for agencies to correct any identified errors.

State and SBA provided mechanisms by which individuals could review the
information the agencies collected and used in their data mining efforts;
the three other agencies claimed allowable exemptions from this
requirement. Table 5 details the steps the agencies took to provide

13The agency rules claiming exemptions from designated provisions of the
Privacy Act are published in the Code of Federal Regulations at 7 CFR
S:1.123 (RMA), 28 CFR S:16.96 (FBI), and 31 CFR S:1.36 (IRS).

Page 17 GAO-05-866 Data Mining

individuals with access to their personal information used in the data
mining efforts.

Table 5: Questions Related to Agency Actions to Provide Individuals with
Access to Their Personal Records

Question                                             Yes Partial No Exempt 
Does the agency permit individuals to review the     BE             ACD    
records                                                             
about themselves and have a copy?                                   
Does the agency permit individuals to request        BE             ACD    
amendments of records pertaining to them?                           
Does the agency permit individuals to request        BE             ACD    
corrections                                                         
to any portion of records pertaining to them?                       

Legend:

A: RMA's data mining effort

B: State's Citibank Custom Reporting System

C: IRS's Reveal effort

D: FBI's Foreign Terrorist Tracking Task Force effort

E: SBA's Lender/Loan Monitoring System Source: GAO analysis of agency
information.

Citibank provides State cardholders with monthly statements detailing
their purchase card activity and account information-the personal
information used in the data mining effort-that cardholders are required
to review. State also has a process with Citibank to dispute and resolve
any inaccuracies in this information.

SBA's system of records notice described a general procedure that
individuals could use to review personal information SBA collects (which
is one of the information sources used in the data mining effort.)14 In
addition, the agency has procedures that detail how individuals are
permitted to review records relating to them and request amendment.

FBI, IRS, and RMA claimed an allowable exemption for their efforts because
their records are used in law or tax enforcement. FBI and IRS have adopted
procedures under which they could waive the exemption and

14As indicated in table 3, SBA's effort also uses information provided by
commercial sources. However, the commercial information provided to SBA
does not include personal information on individuals.

Page 18 GAO-05-866 Data Mining

    Three Agencies Fulfilled or Partially Fulfilled Requirements Regarding the
    Notification of Individuals When Personal Information Is Collected

allow individuals to access their information in cases where disclosure
would not endanger ongoing investigations or reveal investigative methods.

The Privacy Act requires that, when collecting personal information from
individuals, agencies should provide those individuals with notice that
includes the purpose for which the information was collected and the
potential effect of not providing the information. Among other
requirements, the act requires that the notification be located on the
form the agency uses to collect information from the individual or on an
accompanying form that the individual can keep, and that the notice cite
the legal authority for the information request. According to OMB, this
requirement is based on the assumption that individuals should be provided
with sufficient information about the request to make a decision about
whether to respond. The 1973 federal advisory committee report noted that
the requirement was intended to discourage organizations from probing
unnecessarily for details of people's lives under circumstances in which
people may be reluctant to refuse to provide the requested data.

The agencies responsible for two of the five efforts we reviewed generally
fulfilled the Privacy Act requirements regarding providing notice at the
time of collection, one partially fulfilled these requirements, and two
agencies claimed exemptions from these requirements. Table 6 details the
steps agencies took to notify individuals when collecting personal
information.

Table 6: Questions Related to Agency Actions to Notify Individuals at the
Time Personal Information Was Collected

Question                                             Yes Partial No Exempt 
Were individuals notified of the legal authority      E  A       B  CD     
that authorized the agency to collect the                           
information?                                                        
Were individuals notified of whether or not          BE  A          CD     
submitting information was mandatory or voluntary?                  
Were individuals notified of the principal purposes  BE  A          CD     
for which the information was to be used?                           
Were individuals notified of the routine uses for    BE  A          CD     
the information?                                                    
Were individuals notified of the effects, if any, of BE  A          CD     
not supplying the information?                                      

Legend:

A: RMA's data mining effort

B: State's Citibank Custom Reporting System

C: IRS's Reveal effort

D: FBI's Foreign Terrorist Tracking Task Force effort

E: SBA's Lender/Loan Monitoring System Source: GAO analysis of agency
information.

State and SBA generally provided the required notice when they collected
personal information. Since May 2005, SBA has included a notice on
applications for its loan programs that addressed the Privacy Act
requirements. State provided notification using both a written notice on
the purchase card application and a mandatory training program that all
potential purchase cardholders must take before applying to the program.
However, neither of the methods State used to notify employees identified
the legal basis for the information request, as required by the Privacy
Act. State officials told us that they were unaware that such a notice was
required, but that they intend to notify employees of the legal basis in
the future.

RMA also provided a notice on application forms, but these notices were
not provided to everyone who supplied personal information. In the crop
insurance program, participants apply for coverage from an insurance
company that collects information from applicants and provides it to RMA.
Because the information is collected on its behalf, RMA is responsible for
ensuring that individuals receive the required notifications. However, RMA
could not demonstrate that all individuals who provided it with data were
properly notified. RMA provided documents showing that 16 of the 17

    Agencies' Actions to Ensure Security of Data Mining Efforts and Quality of
    Information They Used Were Inconsistent

insurance providers included the disclosures required by the Privacy Act
on the application forms they provided to borrowers. However, none of the
lenders demonstrated that they provided adequate notice to insurance
agents or adjusters, who also provided personal information used by RMA.
According to RMA officials, they were unaware that this Privacy Act
requirement applies to all the individuals about whom they collected
information. When agencies do not fully notify individuals about the
purpose and uses of the information they collect, the individuals have
limited ability to make a reasonable decision about whether or not to
supply the requested information.

FBI and IRS claimed allowable exemptions to the requirement to provide
direct notice to individuals when they collect information under the
Privacy Act because they use the collected information for law enforcement
purposes.

The Privacy Act requires agencies to establish appropriate administrative,
technical, and physical safeguards to ensure the security of records and
to protect against any anticipated threats or hazards to their security
that could result in substantial harm, embarrassment, inconvenience, or
unfairness to any individual about whom information is maintained. While
the act does not specify the types of procedures that agencies should take
to ensure information security, FISMA and related OMB guidance define
specific procedures for ensuring the security (which encompasses
protections for availability, confidentiality, and integrity) of
information. These procedures include performing risk assessments and
developing security plans. Guidance from OMB and the National Institute of
Standards and Technology (NIST) provide further detail on how agencies are
to address security.

The Privacy Act also requires agencies to maintain all records used to
make determinations about an individual with sufficient accuracy,
relevance, timeliness, and completeness as is reasonably necessary to
assure fairness. For the purposes of this report, we refer to these
requirements as data quality requirements. According to OMB, this
provision is intended to minimize the risk that an agency will make an
adverse determination about an individual based on inaccurate, incomplete,
or out-of-date records.

In the five efforts we reviewed, agency compliance with the security and
data quality requirements was inconsistent. Table 7 summarizes the steps
agencies took to ensure the security and accuracy of the information in
the data mining efforts. Appendix VII provides additional detail on the
specific actions that make up the key requirements and agencies'
compliance with them.

Table 7: Questions Related to Agency Actions Safeguarding and Ensuring the
Quality of Records Containing Personal Information

                         Question Yes Partial No Exempt

Has the agency performed a risk assessment to ACDE B determine the
information system vulnerabilities, identify threats, and develop
countermeasures to those threats?

Has the agency developed a security plan for each CD AE B system?

Has the agency had the system(s) certified and ADE B Ca accredited by
management?

Does the agency have a tested contingency plan for the CE AD B system?

Has the agency performed testing and evaluation of the DE ACa B data
mining system(s)?

Did the agency take steps to ensure the accuracy, B A CDEb relevance,
timeliness, and completeness of the data used to make determinations about
individuals?

Legend:

A: RMA's data mining effort

B: State's Citibank Custom Reporting System

C: IRS's Reveal effort

D: FBI's Foreign Terrorist Tracking Task Force effort

E: SBA's Lender/Loan Monitoring System

Source: GAO analysis of agency information.

aThe IRS Reveal effort became operational in February 2005 and has interim
authority to operate-not full certification and accreditation. IRS is
currently testing the system.

b SBA's data mining effort is not used to make decisions about
individuals.

Security. While the agencies responsible for the data mining efforts we
reviewed followed a number of key security procedures, none had fully
implemented all the procedures we evaluated. Although SBA, FBI, and RMA
applied many of the key procedures required for the information systems
used in their data mining efforts, their documentation did not include all
the information called for in federal guidance. Specifically, SBA and RMA
did not fully document its incident response capability, and neither FBI
nor RMA demonstrated that their systems had tested contingency plans-a key
requirement for adequate security planning. IRS produced several of the
required security-related documents, but its documentation did not
demonstrate that all of the underlying requirements had been met. IRS's
system became operational in February 2005 and is currently undergoing
testing.

Neither of the two agencies responsible for State's data mining effort
took the steps required to ensure that the information systems used in the
effort had adequate security. As the contracting agency for the
governmentwide purchase card program, GSA is responsible for ensuring that
information and information systems used in the program-including those
provided by contractors-follow FISMA guidance. However, according to
agency officials, GSA has not evaluated vendors' systems for compliance
with the specific provisions of FISMA; instead, GSA currently relies on
the banks to provide security and on the Office of the Comptroller of the
Currency15 for oversight of the banks.

Because State uses an information system operated by Citibank, through its
task order under the purchase card program contract, FISMA requires that
State ensure that Citibank's system complies with FISMA provisions. While
State performed a general review of Citibank's security processes before
starting to use its systems, State did not specifically evaluate
Citibank's compliance with federal security requirements. Agencies that do
not take adequate steps to ensure information security risk having
information improperly exposed, altered, or destroyed. For example,
another bank participating in a related program lost backup tapes
containing personal information on government employees.16 GSA program
officials noted that they were satisfied that the situation was an
accident and not a reflection of a significant security failing on the
bank's part.

Data quality. State took steps to ensure that the information used in its
data mining efforts is accurate, relevant, timely, and complete. State
used a monthly review process whereby cardholders review the account
statements provided by Citibank for accuracy. The same information is also

15The Office of the Comptroller of the Currency, a component of the
Department of the Treasury, is responsible for oversight of nationally
chartered banks and state and federally chartered savings associations.
The office is responsible for auditing federally insured institutions
under its jurisdiction annually. The audit, in part, evaluates the
institution's safety and soundness; determines compliance with applicable
laws, rules, and regulations; and ensures that it maintains capital
commensurate with its risk.

16The recent incident involved Bank of America's loss of data regarding
the government travel card program.

    Five Agencies Lacked Comprehensive Privacy Impact Assessments for Their Data
    Mining Efforts

reviewed by the cardholders' supervisors. In addition, area program
coordinators must review the purchase card programs in their area
annually.

RMA took steps that partially ensure the quality of the data in its data
mining effort; for example, it has an editing and data validation process
in place. However, while this process addresses the accuracy of the
system's data, it does not address the relevance, timeliness or
completeness of the personal information in the data mining system because
program officials were unaware of the requirement to do so. Those agencies
that do not take adequate steps to ensure the quality of the information
they use and collect risk making unwarranted decisions based on inaccurate
information.

The provision regarding data quality did not apply to three efforts. SBA
does not use the information in its data mining effort to make
determinations about individuals; rather, it uses it to manage groups of
loans. FBI and IRS claimed an allowable exemption because their records
are used for criminal law enforcement. According to the rule justifying
FBI's exemption, it is impossible to make such determinations in part
because information that may initially appear to be untimely or irrelevant
can acquire new significance as an investigation proceeds.

The E-Government Act of 2002 requires that federal government agencies
conduct privacy impact assessments before developing or procuring
information technology or initiating any new electronic data collections
containing personal information on 10 or more individuals. According to
OMB, such assessments help agencies to

     o determine whether the agency's information handling practices conform
       to the established legal, regulatory, and policy requirements
       regarding privacy;
     o evaluate risks arising from electronic collection and maintenance of
       information about individuals; and
     o evaluate protections or alternative processes needed to mitigate the
       risks identified.

Thus, a timely and comprehensive privacy impact assessment can be used by
agencies as a tool to ensure not only strict compliance with the various
laws related to privacy, but also as a means to consider broader privacy
principles, such as the fair information practices that formed the basis
for those laws.

The E-Government Act lays out a series of requirements for assessments,
such as (1) they must describe and analyze how the information is secured,

(2) they must describe and analyze the intended uses of information, (3)
the agency's chief information officer (or designee) must review the
assessment, and (4) the assessment must be publicly available unless
making it so would raise security concerns or reveal sensitive or
classified information. OMB guidance does not require privacy impact
assessments for systems used for internal government operations or for
national security systems; however, individual agencies may have more
stringent privacy impact assessment requirements.

While four of the five agencies were required to conduct assessments by
statute or by agency rule, three (RMA, SBA, and IRS) did so. However, none
of these assessments adequately addressed all the statutory requirements.
Table 8 summarizes agency actions to assess the privacy impacts of their
data mining efforts.

Table 8: Questions Related to Agency Actions to Conduct Privacy Impact
Assessments

                         Page 25 GAO-05-866 Data Mining

Question                                            Yes Partial No  Exempt 
Was a privacy impact assessment prepared?           ACE         D   Bb     
Did the privacy impact assessment describe and          ACE     D   Bb     
analyze what information was to be collected?                       
Did the privacy impact assessment describe and          AC      DE  Bb     
analyze why the information was to be collected?                    
Did the privacy impact assessment describe and          AC      DE  Bb     
analyze the intended use of the information?                        
Did the privacy impact assessment describe and          ACE     D   Bb     
analyze with whom the collected information was to                  
be shared?                                                          
Did the privacy impact assessment describe and                  ADE  CaBb  
analyze the notice or opportunity for consent for                   
individuals impacted by the system?                                 
Did the privacy impact assessment describe and          ACE     D   Bb     
analyze how the information was to be secured?                      
Did the privacy impact assessment describe and          ACE     D   Bb     
analyze whether a Privacy Act system of records is                  
being created?                                                      

(Continued From Previous Page)                      
Question                                            Yes Partial No  Exempt 
Did the privacy impact assessment identify the          C       ADE Bb     
choices the agency made as a result of performing                   
the assessment?                                                     
Was the privacy impact assessment reviewed by the   C           ADE Bb     
agency's chief information officer or his/her                       
equivalent?                                                         
Was the privacy impact assessment made publicly     E   C       AD  Bb     
available?                                                          

Legend:

A: RMA's data mining effort

B: State's Citibank Custom Reporting System

C: IRS's Reveal effort

D: FBI's Foreign Terrorist Tracking Task Force effort

E: SBA's Lender/Loan Monitoring System

Source: GAO analysis of agency information.

aThe IRS Reveal system is exempt from giving notice at the time of
collection based on a law enforcement exemption to the Privacy Act.

bOMB guidance does not require privacy impact assessments for internal
government systems.

Three agencies conducted assessments that partially addressed the
requirements. For example, while RMA's plan addressed the information to
be collected and how it was to be used, it did not receive the required
review by the agency chief information officer or designee. In addition,
RMA's assessment was not made publicly available, even though the document
did not include any sensitive information.17 IRS's notice stated that it
would use the information for queries, but did not analyze the purpose for
collecting the information or its intended uses, as required. For
instance, IRS's privacy impact assessment states that the system "is used
to identify potential criminal investigations of individuals or groups" in
"support of the overall IRS mission." While this describes the purpose for
collecting the information and its intended uses, it does not analyze how
the agency reached these decisions. RMA and IRS did not fully address
these steps because they used a prior version of guidance that did not
address all the current requirements when conducting their assessments.
SBA conducted an assessment of a previous loan monitoring effort that

17Under OMB guidance, an agency may decide not to make the PIA document or
summary publicly available to the extent that publication would raise
security concerns or reveal classified (i.e., national security) or
sensitive information (e.g., potentially damaging to a national interest,
law enforcement effort, or competitive business interest) contained in an
assessment.

Page 26 GAO-05-866 Data Mining

addressed several aspects of their current data mining effort. This
assessment included general descriptions of what information was to be
collected, why the information was to be collected, the intended use of
the information, and how the information was to be secured. However, the
assessment did not analyze these decisions, as required by OMB's guidance.
According to SBA officials, the privacy assessment was not more specific
because at the time it was completed, the possible uses of the system and
the format it would take were not certain. SBA officials added that a more
specific privacy assessment of the data mining effort has been drafted and
is expected to be published later in the current fiscal year.

FBI has not conducted a privacy impact assessment for its data mining
effort. FBI is not required by statute to conduct assessments on these
systems because they are classified as national security systems. However,
under FBI regulations, assessments are required for these systems.
According to agency officials, FBI is in the process of preparing privacy
assessments for the two systems that make up its data mining effort, but
these assessments were delayed due to competing priorities for its
operational support team. The officials said that the agency does not have
a target date for completing the assessments.

The lack of comprehensive assessments is a missed opportunity for agencies
to ensure that the data mining efforts we reviewed are subject to the most
appropriate privacy protections. Because the assessments did not address
all the required subjects, including those related to several Privacy Act
provisions, agencies were sometimes unaware that they were not following
all the requirements of the act. Further, without analyses regarding their
approaches to privacy protection, agencies have little assurance that
their approaches reflect the appropriate balance between individual
privacy rights and the operational needs of the government.

GSA, the contracting agency for the governmentwide purchase card program,
did not conduct a privacy assessment because OMB guidance does not require
them for internal government programs. However, OMB guidance encourages
agencies to conduct privacy impact assessments on systems that collect
information in identifiable form about government personnel. Further,
according to agency officials, GSA is developing guidance requiring
assessments for all new agency systems which will apply to the purchase
card program.

  Conclusions

The five data mining efforts illustrate ways in which federal agencies
collect and use personal information for purposes such as program
oversight and law enforcement. The agencies responsible for these data
mining efforts took many of the key steps required to protect the privacy
and security of the personal information they used. However, none of the
agencies followed all the key privacy and security provisions we reviewed.
Those that did not apply key privacy protections limited the ability of
the public-including those individuals whose information was used-to
participate in the management of that personal information. Those agencies
that did not apply the appropriate security protections increased the risk
that personal information could be improperly exposed or altered. Until
agencies fully comply with the Privacy Act, they lack assurance that
individual privacy rights are appropriately protected.

Further, none of the agencies we reviewed conducted a complete privacy
impact assessment. Had their assessments fully addressed the required
Privacy Act provisions, the agencies would have had an opportunity to
identify and remedy areas of noncompliance. In addition, none of the
privacy impact assessments adequately addressed the choices that agencies
made regarding privacy in their data mining efforts. As a result, the
basis for their choices regarding tradeoffs between privacy protections
and operational needs is unclear. Better analyses of such choices could
help agencies strike the appropriate balance between operational needs and
individuals' rights to privacy.

To ensure that the data mining efforts reviewed include adequate privacy

  Recommendations

protections, we are making 19 recommendations to the agencies responsible
for them. Specifically, we recommend that the Secretary of Agriculture
direct the Administrator of the Risk Management Agency (RMA) to

     o provide the required Privacy Act notices to individuals, including
       producers, insurance agents, and adjusters, when personal information
       is collected from them;
     o apply the appropriate information security measures defined in OMB and
       NIST guidance to the systems used in the RMA data mining effort,
       specifically, the development of a complete system security plan, a
       tested contingency plan, and regular testing and evaluation of the
       systems used in the effort;
     o develop and implement procedures that ensure the accuracy, relevance,
       timeliness, and completeness of personal information used in the RMA
       data mining effort to make determinations about individuals;
     o revise the privacy impact assessment for the RMA data mining effort to
       comply with OMB guidance, including analyses of the intended use of
       the information it collects, with whom the information will be shared,
       how the information is to be secured, opportunities for impacted
       individuals to comment, and the choices made by the agency as a result
       of the assessment;
     o have the completed privacy impact assessment approved by the chief
       information officer or equivalent official; and
          * make the completed privacy impact assessment available to the
            public, as appropriate.
          * We recommend that the Secretary of the Treasury direct the
            Commissioner of the Internal Revenue Service to
     o apply the appropriate information security measures defined in OMB and
       NIST guidance to the systems used in the Reveal data mining effort,
       specifically, the performance of regular system testing and evaluation
       against NIST guidance;
     o revise the privacy impact assessment for the Internal Revenue
       Service's Reveal system to comply with OMB guidance, including
       analyses of the information to be collected, the purposes of the
       collection, the intended use of the information, how the information
       is to be secured, and opportunities for impacted individuals to
       comment; and
          * make the completed privacy impact assessment available to the
            public, as appropriate.
          * We recommend that the Attorney General direct the Director of the
            Federal Bureau of Investigation to
     o apply the appropriate information security measures defined in OMB and
       NIST guidance to the systems used in the Foreign Terrorist Tracking
       Task Force data mining effort, including the development of tested
       contingency plans;
     o establish a date for the completion of a privacy impact assessment for
       its data mining effort that complies with OMB guidance, including
       analyses of the information to be collected, the purposes of the
       collection, the intended use of the information, with whom information
       will be shared, how the information is to be secured, opportunities
       for impacted individuals to comment, and the choices made by the
       agency as a result of the assessment;
     o have the completed privacy impact assessment approved by the chief
       information officer or equivalent official; and
     o make the completed privacy impact assessment available to the public,
       as appropriate.

We recommend that the Secretary of State direct the Under Secretary for
Management to notify purchase card participants of the legal basis under
which the department collects their personal information, as required.

We recommend that the Administrator of the Small Business Administration

     o amend the system of records notice regarding its data mining effort to
       clearly identify the individual responsible for the effort, the
       process by which individuals can request notification that the system
       includes records about them, and the procedures individuals should use
       to review records pertaining to them;
     o complete a privacy impact assessment for the data mining effort that
       complies with OMB guidance, including analyses of the information to
       be collected, the purposes of the collection, the intended use of the
       information, how the information is to be secured, opportunities for
       impacted individuals to comment, and the choices made by the agency as
       a result of the assessment; and
          * make the completed privacy impact assessment available to the
            public, as appropriate.
          * We recommend that the Administrator of the General Services
            Administration
     o publish a system of records notice for the purchase card program that
       specifies the name of the system, the categories of individuals and

  Agency Comments and Our Evaluation

records in the system, the categories of information sources used by the
system, the routine uses of the system, how the agency stores and
maintains the system, the individual responsible for the effort, the
process by which individuals can request notification that the system
includes records about them, and the procedures individuals should use to
review records pertaining to them and

o  ensure that the appropriate information security measures defined in
OMB and NIST guidance are applied to the systems used in the Citibank
Custom Reporting System data mining effort, including the development of a
risk assessment, a system security plan, a tested contingency plan, the
performance of regular testing and evaluation, and the completion of
certification and accreditation by agency management.

We provided Agriculture, Treasury, Justice, State, SBA, and GSA with a
draft of this report for their review and comment. We received written
comments on the report and its recommendations from SBA, Agriculture,
State, and Treasury, and comments via e-mail from GSA's Assistant
Commissioner for Acquisition. These agencies generally agreed with the
majority of our recommendations, but disagreed with others. Justice's
Senior Audit Liaison stated that the department had no comments.
Agriculture, IRS, State, and SBA also provided technical comments, which
we addressed as appropriate.

The Administrator, RMA, stated that RMA agreed with the majority of our
recommendations and that the agency had taken steps to implement many of
them. In response to our recommendation that RMA strengthen security
measures, the Administrator stated that RMA has a security plan for its
data mining system and performs regular testing and evaluation. While our
draft indicated that RMA had implemented some of the necessary security
measures, we noted that it did not follow all related guidance.
Specifically, the system security plan did not describe its incident
response capability, and RMA did not document that it had conducted annual
testing or that its tests included penetration or vulnerability testing.
We clarified this recommendation to focus on the incomplete and
undocumented security measures we identified. In response to our
recommendation that RMA develop and implement procedures that ensure the
quality of personal information used in its data mining system, USDA
commented that they already have an editing and validation process in
place. We clarified the discussion of this point in our report. However,
while this process addresses the accuracy of the system's data, it does
not address the relevance, timeliness or completeness of the personal
information in the data mining system. USDA's comments are contained in
appendix VIII.

Treasury's Chief Information Officer generally agreed with our
recommendations regarding a privacy impact assessment, and said that IRS
will conduct a new privacy impact assessment that complies with current
OMB guidance after Reveal becomes operational. While conducting a new
privacy impact assessment is an appropriate step, we note that the
E-Government Act and OMB guidance require that assessments be conducted
before systems become operational. In responding to our recommendation to
ensure that appropriate security measures are applied to IRS's Reveal data
mining effort, Treasury stated that Reveal is in compliance with OMB,
NIST, and Treasury security guidance and is operating under an interim
authorization to operate while it undergoes certification and
accreditation. Our report acknowledges that IRS had applied several
security measures, but also notes that required regular testing and
evaluation was not yet in place. We clarified this recommendation to focus
on these requirements. Treasury's comments are contained in appendix IX.

State's Assistant Secretary and Chief Financial Officer generally agreed
with our recommendation that it notify purchase card participants of the
legal basis under which the Department collects their personal
information; State responded that it will take the necessary steps to
address this recommendation. In addition, regarding a recommendation we
made to GSA concerning the Citibank Custom Reporting System, State raised
the issue of whether a privacy impact assessment is required for systems
that collect information on federal employees, as is the case with this
system. As discussed below in our response to GSA, we agree that OMB
guidance exempts internal government systems from the requirement to
conduct privacy impact assessments and have clarified our report to
reflect this. State's comments are contained in appendix X.

SBA's Associate Deputy Administrator for Office of Capital Access
generally agreed with our recommendations and provided information on its
planned actions. SBA's comments are contained in appendix XI.

GSA's Assistant Commissioner for Acquisition generally disagreed with our
recommendations. He stated that GSA has not published a system of records
notice for the purchase card program because this program does not capture
personal information. However, as described in the report, the system
retrieves information about individuals by personal identifiers, and thus
meets the Privacy Act's definition of a system of records. In commenting
on our recommendation that GSA ensure that appropriate security measures
defined in OMB and NIST guidance are applied to the data mining effort,
GSA explained that they have reviewed the security standards of the five
financial institutions on the GSA SmartPay master contract, and have
concluded that the commercial standards and procedures provided by these
institutions offer the Citibank Custom Reporting System sufficient
security protection. However, GSA is required to ensure that information
and information systems used in the program-including those provided by
contractors-meet the requirements of FISMA, including the implementing
guidance from OMB and NIST. Further, recent OMB guidance requires agencies
to ensure implementation of security measures identical to those required
under FISMA. GSA also provided a security risk assessment of the security
in the SmartPay Master Contract. However, the assessment does not address
any of the elements of the NIST guidance for implementing risk
assessments, such as identifying the system's vulnerabilities and threats.
Finally, in response to our three recommendations regarding the
requirement to conduct a privacy impact assessment, the Assistant
Commissioner stated that GSA is not required to conduct a privacy impact
assessment because it is contracting for a financial system, not an IT
system. Because it is an internal government system, we agree that GSA is
not required by OMB guidance to conduct a privacy impact assessment on the
Citibank system and have clarified our report to reflect this.

As agreed with your office, unless you publicly release the contents of
this report earlier, we plan no further distribution until 30 days from
the report date. We will send copies of this report to the Chairmen and
Ranking Minority Members of other Senate and House committees and
subcommittees that have jurisdiction and oversight responsibility for SBA,
Agriculture, State, Treasury, GSA, and Justice. Copies will be made
available to others on request. In addition, this report will be available
at no charge on the GAO Web site at http://www.gao.gov.

If you have any questions concerning this report, please contact me at
(202) 512-6240 or by e-mail at [email protected]. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on the
last page of this report. GAO staff who made major contributions to this
report are listed in appendix XII.

Sincerely yours,

Linda D. Koontz Director, Information Management Issues Appendix I

Scope and Methodology

To address our objectives, we used a case study methodology. We selected
the data mining efforts to be included in our evaluations from the 122
federal data mining systems reported to us in 2004.1 In that report, we
identified the six most common purposes for the data mining activities
reported to us. For the purposes of this review, we excluded systems used
for two purposes: we did not select any systems used for analyzing
scientific and research information because few of those systems used
personal information, and we excluded systems used for managing human
resources because such records fall under different privacy rules and
regulations.

The remaining four most common purposes were

     o improving service or performance;
     o detecting fraud, waste, and abuse;
     o detecting criminal activities or patterns; and
          * analyzing intelligence and detecting terrorist activities.
          * From the systems that were used for these purposes, we selected
            all those that met each of the following criteria:
     o used personal identifiers,
     o were operational, and
     o used data from another agency or private sector data.

These criteria were chosen to ensure that the efforts we selected
illustrated agency practices regarding personal information. In addition,
we selected no more than one system from each department or agency.

We analyzed the information provided in 2004 and determined that 11 data
mining efforts met all of our initial selection criteria. We contacted the
agencies responsible for the systems to confirm the accuracy of the
information previously provided. As a result of the updated information,
we

1See GAO, Data Mining: Federal Efforts Cover a Wide Range of Uses,
GAO-04-548 (Washington, D.C.: May 4, 2004).

Page 35 GAO-05-866 Data Mining Appendix I Scope and Methodology

eliminated from consideration several systems that no longer met all of
the selection criteria, resulting in the final selection of five data
mining systems for our case study review.

To describe the characteristics of the selected federal data mining
efforts, we analyzed system documentation, public notices, and other
relevant documents and interviewed officials at the responsible department
or agency, and, when applicable, the supporting contractor. Agency
officials were provided with several opportunities to review our
descriptions of the selected systems and the graphical depictions included
in appendixes II through VI.

To determine whether agencies provided adequate privacy protection for the
personal information used in the selected data mining efforts, we analyzed
federal privacy and security laws, regulations, and other guidance to
identify key steps and procedures for protecting the privacy of individual
information. We then developed a data collection instrument consisting of
a series of questions about agency actions that followed the key steps and
procedures, as well as questions on the detailed characteristics of the
data mining systems, and provided the instrument to the responsible
agencies. We reviewed the agencies' responses and any supporting
documentation they provided, and assigned an answer of yes (compliant with
all of the guidance related to that question), no (not compliant with any
of the guidance related to that question), or partial (compliant with
some, but not all of the guidance) to each question. We also reviewed
rules claiming exemptions. We discussed the results with agency officials
and made adjustments as appropriate.

Because we studied only five data mining efforts and because of the method
of selection, we cannot conclude that our results represent any larger
group of data mining efforts. Although they were not representative of all
federal data mining efforts, we believe that the five efforts we reviewed
illustrate some of the ways in which agencies satisfy federal privacy
provisions and the circumstances under which agencies can claim exemptions
to these provisions.

We conducted our work from May 2004 to June 2005 at the Washington, D.C.,
area offices of the Departments of State and Agriculture, Internal Revenue
Service, Federal Bureau of Investigation, Small Business Administration,
and General Services Administration, at an agency facility in
Philadelphia, Pennsylvania, and at the Stephenville, Texas, location of an

Appendix I Scope and Methodology

agency contractor. Our work was conducted in accordance with generally
accepted government auditing standards.

Appendix II

                  Risk Management Agency's Data Mining Effort

                                Purpose and Uses

The Risk Management Agency1 (RMA) uses a data mining system designed by
Tarleton State University's Center for Agribusiness Excellence (CAE) to
assist it in detecting fraud, waste, and abuse in the federal crop
insurance program. The data mining system is used to identify producers,
insurance agents, and loss adjusters who may be abusing the program. Its
inputs include insurance records on policy holders, agents, and loss
adjusters, as well as data on soil, weather, and land. It produces several
types of outputs, including lists of names of individuals whose behavior
is anomalous.

The purpose of the RMA data mining system is to detect fraud, waste, and
abuse in the federal crop insurance program by investigating potential
leads and confirming suspicious activity in high-profile cases.2 It also
uses the system to improve program policies, guidance, and data quality.
According to RMA officials, the system significantly augmented agency
program integrity initiatives and accounted for over $340 million in cost
avoidance savings since its inception.

According to RMA officials, CAE analysts identify potential abusers of the
federal crop insurance program primarily by developing scenarios of abuse
of the program by producers, insurance agents, and loss adjusters.
Analysts query the data warehouse by using data mining and pattern
recognition techniques to identify information, patterns, anomalies, or
relationships indicative of fraud, waste, and abuse. CAE analysts then
generate reports for RMA regional compliance offices, which use the
reports to determine which producers should be inspected for potential
abuse.

RMA uses reports produced by the data mining system for policy development
in the Crop Insurance Handbook and improvement of the federal crop
insurance program. RMA's officials often request data mining reports (1)
to help evaluate pilot programs before making policy changes,

(2) to determine the best way to change program procedures once the
policies are implemented, and (3) to determine ways to enhance the data
through quality control reviews.

1The Risk Management Agency is a component of the U.S. Department of
Agriculture.

2The federal crop insurance program is designed to protect farmers from
financial losses caused by events such as droughts, floods, hurricanes,
and other natural disasters as well as losses resulting from a drop in
crop prices. RMA administers and oversees the federal crop insurance
program.

Page 38 GAO-05-866 Data Mining

            Appendix II Risk Management Agency's Data Mining Effort

How It Works RMA's data mining effort uses a data warehouse containing
crop insurance data and information from weather, soil, and land survey
sources to develop and conduct pattern-based searches for identifying
information, patterns, anomalies, or relationships indicative of fraud,
waste, and abuse. Pattern-based searches are based on scenarios of
fraudulent schemes for obtaining crop insurance indemnities (the dollar
amount paid in the event of an insured loss) that are developed by
analysts and agricultural experts. The data mining system helps analysts
uncover these patterns through an iterative process. Each scenario is
tested and refined by querying data in the warehouse. The results are then
provided to a CAE product review team that approves or rejects the
scenario. Once a scenario is approved, analysts can use it to search the
data warehouse for individuals who match the scenario patterns. Analysts
use multiple scenarios to query the data warehouse in order to identify
program participants who are potentially involved in fraudulent
activities, resulting in a "spot check list."

Table 9 lists (1) the names and attributes of the scenarios developed by
RMA and CAE and (2) the agency-reported summary of potentially fraudulent
claims reported by producers whose behavior was identified as anomalous on
the 2002 spot check list. According to RMA officials, the eight scenarios
listed in table 9 have been the most successful in generating program
savings.

            Appendix II Risk Management Agency's Data Mining Effort

             Table 9: Scenarios Used to Identify Potential Abusers

Dollars in millions
                                                          Summary of the 2002
                                                             spot check list:
                                                       potentially fraudulent
Scenario name    Scenario characteristics                           claims 
Triplets         Agents, adjusters, and producers linked by           $4.3 
                    anomalous behavior that is suggestive of           
                    collusion.                                         
Rare big losses  Producers who make claims much too often compared    32.8 
                    to other producers of the                          
                    same crop in the same area.                        
Under-reported   Producers who hide part of their production by       23.5 
                    reporting it under someone else's                  
harvest          name or by growing a crop on land hidden from      
production       inspectors. They are compared only                 
                    to other producers who experienced the same        
                    weather conditions.                                
Frequent filers  Anomalous producers reporting consecutive            21.7 
                    multiyear losses. They make claims for             
                    seven consecutive years and their indemnities each 
                    year are at least as high as their                 
                    insurance premiums.                                
Yield switching  Producers whose yield difference (the difference     15.5 
                    between their rate yield and actual reported       
                    yield) is-over a period of years-significantly     
                    above or significantly below other producers in    
                    the same area for the same crop.                   
All or nothing   Insurance agents whose losses on their               12.2 
                    policyholders' crop insurance policies are         
                    disproportionately higher than those of agents in  
                    the same area.                                     
Prevented        Producers who grow crops outside the planting         7.0 
planting         schedule required by the Federal                   
                    Crop Insurance Handbooka and file a claim for not  
                    being able to produce the crop.                    
Excessive yield  Producers with crop units that have excessive        36.2 
                    reported yields when compared to                   
                    those of agents in the same area.                  

Source: RMA.

aThe Federal Crop Insurance Handbook contains underwriting standards for
administering crop insurance policies under RMA's oversight.

RMA's six regional compliance offices use the data mining query results,
including the spot check list, to determine which producers should be
inspected for potential abuse. Once the regional compliance offices review
the list, they forward it to employees of USDA's Farm Service Agency who
send notification letters to the producers on the list, alerting them to
pending inspections. According to RMA officials, the notice of a pending
inspection is often enough to discourage the producers from filing
fraudulent claims. Figure 2 depicts this process.

Appendix II Risk Management Agency's Data Mining Effort

                    Figure 2: An Overview of the RMA System

                      Source: GAO analysis of agency data.

            Appendix II Risk Management Agency's Data Mining Effort

Inputs The RMA data mining effort uses government data covered by systems
of records notices, including crop insurance data. Data in the RMA system
not from systems of records include public land, weather, and soils data.
In addition to government data, RMA uses other publicly available
information on an as-needed basis.

Government Data from Systems Crop Insurance Information. Insurance
companies participating in the

of Records program provide crop insurance information to RMA on program
participants, including producers, insurance agents, and loss adjusters.
The crop insurance data contains personal identifiers that can be linked
to program participants, including names, addresses, phone numbers, and
Social Security numbers.

Government Data Not from Land Survey Data. The system uses digital maps
from the Public Land

Systems of Records Survey System-regulated by the Bureau of Land
Management3-that depict public survey information, such as township
locations referred to in legal land descriptions. Analysts use this
information to determine whether there is a discrepancy between a
producer's claim and land records.

Weather Data. RMA uses information from public weather records from the
National Oceanic and Atmospheric Administration to assist in validating
specific causes of loss for further investigation.

Soils Data. RMA plans to uses soils data from USDA's Natural Resources
Conservation Service when determining whether soil on a producer's land is
acceptable for growing an insured crop.

Public Data The agency also uses other publicly available information
including information found on public Web sites.

Outputs RMA's data mining system produces reports for program
investigators on producers whose behavior patterns are anomalous. The
system also produces reports for program managers that include
programmatic information-such as how a procedural change in the federal
crop insurance program's policy manual would affect the overall
effectiveness of

3The Bureau of Land Management is a Department of the Interior agency that
manages 264 million surface acres of public lands located primarily in 12
western states, including Alaska.

Page 42 GAO-05-866 Data Mining Appendix II Risk Management Agency's Data
Mining Effort

the program-and other information on data quality and program performance.

Appendix III

The Citibank Custom Reporting System Used by the Department of State

                                Purpose and Uses

The U.S. Department of State (State) contracts with Citibank through the
General Services Administration's GSA SmartPay1 contract to provide State
employees with purchase cards.2 Under the contract, Citibank provides
State and other contracting agencies access to the Citibank Custom
Reporting System (CCRS)-a proprietary tool designed by Citibank. State
uses this system to analyze transaction data and help prevent fraud,
waste, and abuse in its purchase card program. The system's inputs include
account information from State employees and commercial data from
transactions made by State employees. System outputs include summaries of
card account holder information and purchases.

The purpose of State's data mining effort is to prevent fraud, waste, and
abuse in the purchase card program by using CCRS to ensure that credit and
purchase limits are in place and to conduct spot checks of individual
purchase card expenditures.3 Officials also use the system to improve
program performance through the results of simple subject- and
pattern-based queries.4

According to State officials, the department uses reports containing
information on agency purchase card accounts and suspended or cancelled
accounts. State officials also regularly review a CCRS report that
summarizes single transaction and monthly spending limits for all
cardholders to ensure that they are accurate. According to State
officials, one of the most important tasks accomplished through system
reports is ensuring that the ratio of cardholders to approving officials-a
cardholder's

1In 1998, GSA awarded contracts to five major banks through the GSA
SmartPay program to provide federal agencies with purchase cards as well
as travel cards and cards for fleet-related expenses. The participating
banks are Bank of America, Bank One (now J.P. Morgan Chase), Citibank,
Mellon Bank, and U.S. Bank. Individual agencies select one of the
participating banks and issue a task order to the bank based on the terms
of the master contract with GSA.

2Purchase cards are bank charge cards used primarily for purchases
totaling less than $2,500.

3State is the lead U.S. foreign affairs agency and operates more than 250
posts around the world. State employees use purchase cards to make
work-related purchases in support of State's mission.

4Users can use subject-based queries to receive reports on an individual
account's expenditures and can use pattern-based queries to determine,
among other things, which vendors employees make purchases from.

  Appendix III The Citibank Custom Reporting System Used by the Department of
                                     State

immediate supervisor-is low enough for expenditures to be effectively
reviewed.

According to State officials, the department also uses reports to assist
with overall purchase card program management functions. These reports
provide the ability to track overall purchase card expenditures by a
number of data elements, including spending by region or embassy, or by
vendors used by State employees. State also uses CCRS to collect and
compile statistical information about the program for quarterly reports
submitted to the Office of Management and Budget. These reports include
information on the number of current accounts, dollars spent, rebate
amounts earned, and single purchase and monthly expenditure limits for
cardholders.

How It Works The CCRS electronic reporting tool is a Citibank proprietary
system. The system interfaces with Citibank's Global Data Repository,
which stores account and transaction data for an 18-month period. A
portion of the data resulting from the transaction process is replicated
in the primary system database for use in analysis and report preparation.
Figure 3 illustrates the transaction process. Reports can be printed or
downloaded from the system; the presentation of the data can be edited
within the system, or the data can be downloaded to be analyzed in an
outside program.

When using the system, State users can access reports developed in the
system, including reports of purchase card accounts, suspended or
cancelled accounts, and summary reports on the vendors State employees
purchase from. Reports not already established in the system can be
created by Citibank at the request of agency officials. Figure 3
illustrates this process.

Appendix III The Citibank Custom Reporting System Used by the Department
of State

         Figure 3: An Overview of the Citibank Custom Reporting System

Appendix III The Citibank Custom Reporting System Used by the Department
of State

Source: GAO analysis of agency data.

  Appendix III The Citibank Custom Reporting System Used by the Department of
                                     State

Inputs CCRS includes transaction and account data. Account data are
collected from agency employees, with an account number issued by
Citibank; transaction data consist of records of purchase card
transactions conducted by State employees.

Government Data Not from Account Data. State collects personal
information, including name, last

Systems of Records four digits of the Social Security number, and the
cardholder's office phone number and mailing and e-mail addresses as part
of the purchase card application process. According to agency officials,
State retrieves records by cardholder name. State supplies that
information to Citibank. State also supplies required account
parameters-such as single transaction and monthly spending limits-and
assigns a unique identifying number. Other account information is assigned
by Citibank.5

Commercial Data Transaction Data. The amount and level of detail available
in the transaction data varies depending on the technical capabilities of
the vendor from whom products are purchased. For example, vendors with the
most basic capabilities transfer standard commercial transaction data,
including the total purchase amount, date of purchase, vendor's name and
location, date the charge or credit was processed, and a reference number
for each charge or credit. Vendors with more advanced technology can
provide additional information including, among other things, unit cost
and quantity, vendor's category code, and sales tax amount.

Outputs CCRS provides reports on purchase card transactions and account
information, including a list of all purchase card accounts, a report on
suspended or cancelled accounts, and reports summarizing expenditures by
region or by vendor. Many reports in the CCRS system are available in a
summary form that does not contain personal identifiers and in a detailed
form containing personal identifiers, including account number and name.

According to State officials, CCRS reports are used within State's
purchase card office to ensure adequacy and accuracy of compensating
controls

5Account data from the purchase card program are not covered by a system
of records notice. See p. 17 for more information.

Page 48 GAO-05-866 Data Mining Appendix III The Citibank Custom Reporting
System Used by the Department of State

such as credit limits. Reports are also used to track expenditures and are
supplied to other State offices, such as State's Inspector General, for
use in analyzing purchases.

Appendix IV

                    Internal Revenue Service's Reveal System

  Purpose and Uses

How It Works

The Internal Revenue Service1 (IRS) uses the Reveal system to detect
patterns of criminal activity, analyze intelligence, and detect terrorist
activities. According to agency officials, IRS uses the system to identify
financial crime, including individual and corporate tax fraud, and
terrorist activity. Inputs for Reveal include Bank Secrecy Act data, tax
information, and counterterrorism information. Its outputs include reports
containing names, Social Security numbers, addresses, and other personal
information of individuals suspected of financial crime or terrorist
activity.

The purpose of the Reveal data mining system is to detect criminal
activities and patterns in support of IRS's work in investigating
potential criminal violations of the Internal Revenue Code and related
financial crimes. This work is conducted by IRS's Criminal Investigation
unit. According to agency officials, Reveal is used to analyze available
databases to support ongoing investigations relating to financial crime,
including individual and corporate tax fraud, and terrorist activity.

The system provides the capability to query data from multiple sources in
an effort to identify links in the data. System users develop reports that
include query results and graphical depictions of the data. The reports
are then provided to field offices, which conduct investigations based on
the reports' results.

The system allows users to establish a profile of the actions and persons
associated with the search subject by allowing the user to trace numerous
financial transactions between individuals and institutions.

Reveal uses commercial software to query multiple databases. The system
provides Criminal Investigation users with a visual depiction of the
results, and allows them to search on names, Social Security numbers, and
other information to help narrow their search. Reveal consists of (1) a
data retrieval and manipulation tool that performs queries and (2) a
software tool that provides a visual depiction of the query results. The
retrieval and manipulation tool queries and gathers information on large
sets of data that reside locally on a relational database on the system's
database server. This tool allows users to sort, group, and export data
from multiple information repositories simultaneously, including
combinations of databases. It also

1The Internal Revenue Service is a bureau of the Department of the
Treasury.

              Appendix IV Internal Revenue Service's Reveal System

can perform two kinds of queries: reactive and proactive. To perform a
reactive query, the user must provide a known value of an individual or
entities. To perform a proactive query, the user narrows the search
criteria to identify groups of individuals and patterns of suspicious
activity.

When users narrow their search criteria using the query tool, they can use
the visualization component to refine and assess the results of the
queries. The software visualization tool shows relationships between data
in the queries, and facilitates the discovery of relationships among
entities, patterns, and trends in the data. It also organizes and presents
the information in a variety of graphical formats. Figure 4 depicts this
process.

Inputs Reveal currently uses government system of records data as its only
type of input. These inputs include (1) Bank Secrecy Act data, (2) tax
data, and (3) counterterrorism data. These three types of data all contain
personal information, such as address, Social Security number, and date of
birth. Data sets are copied and stored locally.

              Appendix IV Internal Revenue Service's Reveal System

Tax Data. Tax data used by Reveal include information from IRS's Schedule
K-1, corporate and individual tax information, and applications for
employer and tax identification numbers. It is used to report a
beneficiary's share of income, deductions, and credits from a trust or a
decedent's estate.

Counterterrorism Data. Reveal uses counterterrorism data from various
sources on individuals.

Outputs Reveal's outputs include reports that contain names, Social
Security numbers, addresses, and other personal identifiers of individuals
suspected of financial crimes, including corporate and tax fraud, and of
terrorist activity. Reports are shared with IRS agents who conduct
investigations based on the report's results.

Appendix V

FBI's Foreign Terrorist Tracking Task Force Data Mining Effort

                                Purpose and Uses

The data mining effort used by the Federal Bureau of Investigation's (FBI)
Foreign Terrorist Tracking Task Force analyzes intelligence and detects
terrorist activities. In support of its responsibilities, the task force
operates two information systems-one unclassified and one classified-that
form the basis of its data mining activities.

The purpose of the task force's data mining effort is to analyze
intelligence and detect terrorist activities.1 The task force supports
ongoing investigations in law enforcement agencies and the intelligence
community by using its data mining effort to respond to requests for
information about foreign terrorists from FBI agents or officials from a
partner agency.2 For example, task force program officials informed us
that they occasionally receive information about specific threats from the
intelligence community or law enforcement partners. When such threat
information is received, they identify potential sources of information
that may reveal persons capable and motivated to carry out the threat.
They then connect this information with persons listed in other databases
linked to terrorist information. The task force then provides the names of
high risk individuals whose characteristics match the threat profile to
FBI field agencies and to Joint Terrorist Task Force(s).

According to task force officials, analysts conduct research and analysis
based on requests and provide a report of the results to the requesters
and to affected agencies, as appropriate. For example, according to agency
officials, the task force received a list of possible suicide bombers from
a foreign government. Through analysis, the task force determined that
several of the bombers had names and other identifiers that were similar
to those of individuals currently in the United States. The task force
provided the information to law enforcement investigators to determine
whether the individuals identified were the same as those on the list of
suicide bombers provided by the foreign government.

1The task force's mission is to assist federal law enforcement and
intelligence agencies in locating foreign terrorists and their supporters
who are in or have visited the United States, and to provide information
to other law enforcement and intelligence community agencies that can lead
to their surveillance, prosecution, or removal.

2The task force's partner agencies include Immigration and Customs
Enforcement, the Department of Defense Counterintelligence Field Activity
office, the Office of Personnel Management, and members of the
intelligence community.

Appendix V FBI's Foreign Terrorist Tracking Task Force Data Mining Effort

How It Works Task force analysts use two systems together in their data
mining effort: one sensitive but unclassified, and one classified. After
receiving a request for information about a threat or person of interest,
task force leadership routes the information to an appropriate analyst.
Analysts initially search within the task force's existing data, including
certain immigration records, to determine whether they already have
information relevant to the request.

Task force analysts use several analytical tools to help search for and
analyze information in the systems. According to task force officials, the
analysts' primary query tool is the Query Tracking and Initiation Program.
FBI developed this program to allow users to search the systems using,
among other things, multiple variants or transliterations of names. It
also allows analysts to search within and between different data sets.

The unclassified system serves as the initial repository for unclassified
data. Through this system, task force analysts can use the query tracking
program to submit queries on individuals to commercial databases to find
any relevant information. The resulting information is returned to the
unclassified system, where analysts can conduct analysis using query
tracking and other tools.

The classified system contains law enforcement and intelligence data,
including FBI case files. Information initially collated in the
unclassified system is loaded into the classified system daily. However,
if analysts need expedited results, they can perform an initial analysis
using data contained in the unclassified system and then conduct a more
detailed analysis once data are loaded into the classified system. The two
systems are illustrated in figure 5.

Appendix V FBI's Foreign Terrorist Tracking Task Force Data Mining Effort

Figure 5: An Overview of FBI's Foreign Terrorist Tracking Task Force Data Mining
                                     Effort

                      Source: GAO analysis of agency data.

Inputs FBI officials reported that the task force's systems contain
multiple sets of data from multiple government and nongovernment sources,
some of which were acquired on a one-time basis and others that are
regularly updated. Data from outside sources, including nonpartner
government

Page 56 GAO-05-866 Data Mining Appendix V FBI's Foreign Terrorist Tracking
Task Force Data Mining Effort

     agencies and commercial entities, are typically acquired on an as-needed
                                     basis.
                                    Twenty-nine of the task force's           
                                    government data sets are part of a system 
Government Data from Systems     of                                        
of Records                       records. Many of these data sets come     
                                    from within the Department of             
                                    Justice. Other agencies also supply the   
                                    task force with data, including           
                                    information from immigration records,     
                                    from the Federal Aviation                 
                                    Administration, and from Customs and      
                                    Border Protection. According to           
                                    program officials, most data that come    
                                    from sources outside the                  
                                    Department of Justice are acquired under  
                                    a provision of the Privacy Act            
                                    that allows a law enforcement agency to   
                                    request certain data from a               
                                    government entity for law enforcement     
                                    purposes. According to agency             
                                    officials, outside agencies provided      
                                    their data sets to FBI on the basis of    
                                    formal requests.                          
                                    The task force's data mining effort       
Government Data Not from         receives one set of government data that  
Systems of Records               is not part of a system of records        
                                    because the information does not contain  
                                    personal identifiers.                     
                                    The task force data mining system also    
                                    contains 15 data sets that include        
                                    information on criminal aliens,           
                                    intelligence data and alerts, and various 
                                    watchlists. FBI officials responsible for 
                                    the task force were unaware of            
                                    whether these data are part of a system   
                                    of records, but said that the data        
                                    were supplied to the task force under the 
                                    same conditions as other                  
                                    government data.                          
                                    The task force data mining effort uses    
Commercial Data                  data from several commercial              
                                    sources,3 many of which are updated       
                                    frequently. According to FBI officials,   
                                    analysts can query commercial sources     
                                    during the course of an                   
                                    investigation, if needed. Program         
                                    officials noted that analysts request     
                                    information from commercial sources using 
                                    personal identifiers.                     
                                    The task force received 4 data sets from  
Data from International Entities Interpol (an international police         
                                    organization) on wanted persons, stolen   
                                    property and other intelligence.          

3Commercial data are maintained by private companies and can include
personally identifiable information that either identifies an individual
or is directly attributed to an individual, such as name, address, and
telephone number.

Page 57 GAO-05-866 Data Mining

Appendix V FBI's Foreign Terrorist Tracking Task Force Data Mining Effort

Outputs The task force's outputs include reports that contain personal
identifiers and other information that is relevant to the initial request.
Reports are shared with the requesting entity or agent and as needed with
partner agencies. Agents conduct investigations based on the results of
the reports.

Appendix VI

Small Business Administration's Loan/Lender Monitoring System

                                Purpose and Uses

The Small Business Administration (SBA) contracted with Dun & Bradstreet
to provide information and analytical capabilities that assist SBA in
managing credit risks in two major business loan guarantee programs. The
Loan/Lender Monitoring System (L/LMS) combines SBA data with private
sector data on businesses and consumers to predict future performance of
outstanding business loans.

The purpose of L/LMS is to identify, measure, and manage risk in two of
its business loan programs. It does this specifically by developing
predictive ratings that allow SBA to improve the performance of two of its
business loan programs-the 7(a) loan program1 and 504 program2-using risk
management principles. The system analyzes SBA loan data, Dun & Bradstreet
business data, and data provided by subcontractors, including consumer
credit bureau information and business credit scores. It uses a
commercially available suite of scorecards to produce business credit
scores that predict the likelihood of an SBA loan becoming severely
delinquent over the next 18 to 24 months-a leading indicator of default.3
It also contains trends databases that provide historical data on
approximately one dozen performance and credit risk fields on each
outstanding loan.

Finally, the system contains lender databases that provide information
about individual lenders that can be compared to the information about a
lender's peers.

1Under the 7(a) loan program, SBA can provide guarantees on loans made by
participating lenders authorized by SBA. The 7(a) program is intended for
small business borrowers who could not otherwise obtain credit under
suitable terms and conditions from the private sector without an SBA
guarantee. SBA guarantees approximately $14 to $16 billion
lender-originated 7(a) loans each year, of which SBA guarantees only
approximately $9 to $10 billion each year. Upon default by a borrower, the
participating lender may request that SBA purchase the guaranteed portion
of a loan.

2The 504 program provides long-term, fixed-rate financing to small
businesses for expansion or modernization, primarily for real estate and
major assets such as heavy equipment. The 504 financing is delivered
through nonprofit corporations established to contribute to the economic
development of their communities. SBA guarantees about $4 billion in 504
loans annually.

3A loan is severely delinquent when payments on the loan are past due by
60 or more days.

Appendix VI Small Business Administration's Loan/Lender Monitoring System

                                  How it Works

Dun & Bradstreet and Fair Isaac use the input data in a proprietary
scoring process to generate a predictive risk score for each outstanding
loan. In addition, Dun & Bradstreet appends its commercial demographic and
risk data to the electronic records of all outstanding SBA business loans,
after removing any personal identifiers. Dun & Bradstreet then transfers
this information to a module where it can be accessed by SBA. None of the
data transferred from Dun & Bradstreet to SBA contains personal
identifiers.

SBA can use the L/LMS to view its entire business loan or lender portfolio
and can perform analysis by various data elements, including dollars
outstanding, lender, lender corporate family, SBA region, industry sector,
and loan type. According to SBA officials, the agency uses system-produced
reports to help them determine which lenders' SBA business loan portfolios
are most at risk of default, driving the selection of lenders for further
review. Figure 6 depicts this process.

Inputs The L/LMS uses two kinds of input data: data from government
systems of records and data from commercial sources. The data include
information on businesses and individuals.

Government Data from Systems SBA Loan Records. SBA electronically
transfers about 10 data files

of Records monthly to Dun & Bradstreet. These files contain existing data
on individual 7(a) and 504 SBA business loans and on the lending
institutions that manage the loans and include information on small
businesses; names, addresses, and phone numbers, as well as limited
information about business principals, including personal identifiers.

Appendix VI Small Business Administration's Loan/Lender Monitoring System

           Figure 6: An Overview of the Loan/Lender Monitoring System

Source: GAO analysis of agency data.

Commercial Data Credit Evaluation Data. The L/LMS uses several sources of
commercial data, including Dun & Bradstreet demographic and risk data from
its global business database, consumer bureau data on the business
principals (e.g., information relating to recent delinquencies), and
predictive risk scores

Appendix VI Small Business Administration's Loan/Lender Monitoring System

developed by Dun & Bradstreet and Fair Isaac.4 This information can
contain personal identifiers.

Outputs The L/LMS analyzes the data to generate reports on each lender's
portfolio. SBA also creates aggregate reports that evaluate loans by
portfolio value, projected risk, and historical performance trends.
According to SBA officials, system reports are currently used by program
officials to support business loan, lender, and portfolio monitoring
efforts.

4Fair Isaac is a company that provides business and consumer analytical
services, including credit ratings.

Page 62 GAO-05-866 Data Mining

Appendix VII

Detailed Assessments of Agency Actions to Address Security Requirements in Data
Mining Efforts

The Privacy Act requires agencies to establish appropriate administrative,
technical, and physical safeguards to ensure the security of records and
to protect against any anticipated threats or hazards to their security
that could result in substantial harm, embarrassment, inconvenience, or
unfairness to any individual about whom information is maintained.
Although the act does not specify the procedures agencies should employ to
ensure information security, subsequent legislation and guidance from the
Office of Management and Budget (OMB) and the National Institute of
Standards and Technology (NIST) provide specific procedures that agencies
should take to protect the security of information.

For example, the Federal Information Security Management Act (FISMA)
requires that agencywide information security programs include detailed
plans for providing adequate information security for networks,
facilities, and systems or groups of information systems, as appropriate.
OMB requires that agencies prepare IT system security plans consistent
with NIST guidance, and that these plans contain specific elements,
including rules of behavior for system use, required training in security
responsibilities, personnel controls, technical security techniques and
controls, continuity of operations, incident response, and system
interconnection.1 In addition, OMB requires that agency management
officials formally authorize their information systems to process
information and thereby accept the risk associated with their operation.
This management authorization (accreditation) is to be supported by a
formal technical evaluation (certification) of the management,
operational, and technical controls established in an information system's
security plan. NIST guidelines detail the requirements for certification
and accreditation, including the requirement that the certification
documents include the system security plan, risk assessment, and tested
contingency plan.2 In addition, NIST guidance on recommended security
controls for federal information systems requires agencies to develop,
implement, and test contingency plans for their systems and risk
assessments.

1NIST, The Security Certification and Accreditation of Federal Information
Systems, Special Publication 800-37 (May 2004) and Office of Management
and Budget, Management of Federal Information Resources, Circular No.
A-130, Revised, Transmittal Memorandum No. 4, Appendix III, "Security of
Federal Automated Information Resources" (Nov. 28, 2000).

2NIST, Guide for the Security Certification and Accreditation of Federal
Information Systems, Special Publication 800-37 (May 2004).

Page 63 GAO-05-866 Data Mining

    Appendix VII Detailed Assessments of Agency Actions to Address Security
                      Requirements in Data Mining Efforts

Table 10 lists each of the security requirements that we evaluated and the
results of our evaluation for each of the five data mining efforts
included in this report.

Table 10: Questions Related to Agency Actions Safeguarding and Ensuring
the Quality of Records Containing Personal Information

Question                                            Yes  Partial No Exempt 
Has the agency performed a risk assessment to       ACDE         B  
determine the information system                                    
vulnerabilities, identify threats, and develop                      
countermeasures to those threats?                                   
Has the agency developed a security plan for each   CD   AE      B  
system?                                                             
Does the plan address-                                              
rules of the system?                                ACDE         B  
training?                                           ACDE         B  
personnel controls?                                 ACDE         B  
incident response capability?                       CD   AE      B  
system interconnection?                             ACDE         B  
Has the agency had the system certified and         ADE          B  Ca     
accredited by management?                                           
Did the certification documentation include an      ADE          B  Ca     
approval document including a                                       
statement of risk acceptance?                                       
Has the agency performed testing and evaluation of  DE   ACa     B  
the data-mining system(s)?                                          
Was the testing and evaluation-                                     
conducted no less than annually?                    DE   ACa     B  
conducted using NIST Special Publication 800-26 or  DE   A       BC 
appropriate alternative?                                            
conducted using an element of internal penetration  CDE          AB 
or vulnerability testing?                                           
Does the agency have a tested contingency plan for  CE   AD      B  
the system?                                                         
Did the agency take steps to ensure the accuracy,   B    E       A  CD     
relevance, timeliness, and                                          
completeness of the data it maintains?                              

Legend:

A: RMA's data mining effort

B: State's Citibank Custom Reporting System

C: IRS's Reveal effort

D: FBI's Foreign Terrorist Tracking Task Force effort

E: SBA's Lender/Loan Monitoring System Source: GAO analysis of agency
information.

aThe IRS Reveal effort became operational in February 2005 and has interim
authority to operate-not full certification and accreditation. IRS is
currently testing the system.

Appendix VIII

Comments from the U.S. Department of Agriculture

Appendix VIII Comments from the U.S. Department of Agriculture Appendix
VIII Comments from the U.S. Department of Agriculture Appendix VIII
Comments from the U.S. Department of Agriculture

Appendix IX

Comments from the Department of the Treasury

Appendix IX Comments from the Department of the Treasury

                                   Appendix X

                     Comments from the Department of State

Appendix X Comments from the Department of State

Appendix X Comments from the Department of State

Appendix XI

Comments from the Small Business Administration

Appendix XI Comments from the Small Business Administration

Appendix XII

                     GAO Contact and Staff Acknowledgments

Linda D. Koontz (202) 512-6240

  GAO Contact

In addition to the contact named above, Barbara Collier, Neil Doherty,

  Acknowledgments

Mirko Dolak, Nancy Glover, Alison Jacobs, Kathleen S. Lovett, David
Plocher, James R. Sweetman, Jr., and Marcia Washington made key
contributions to this report.

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