Public Information Private Information

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Public Information- Private Information

• Worlds Apart?

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Public Information Private Information

• Define a Public Record
• How does Private Info Get in There
• How does this relate to identity theft
• Can we stop this ourselves or is the Federal
  Government going to Mandate we act
• Act or Redact
• What time is lunch and when does the bar at the
  hotel open?

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Carolyn AblemanChief Deputy Auditor
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Donald V. WarrinerCEO and Chairman of the Board
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Mary RonanSenior Analyst
186-23-8729
IRS Office of Privacy Advocate
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Angela ClarkPresident
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Privacyand the Public Record

• How can a Record be Public and Private at the
  same Time??

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Is it the Type of Data or is it the Record?

• Fear of the availability of certain types of
  information comes from mis-use of that data
• Addresses, Birthdates, SSs, Mothers Maiden
  Name, Financial Information, etc.
• Official Open Public Records have not been widely
  used for identity theft

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Recorded Documents

• Purpose
• To give public notice regarding transactions
  affecting real property, or other contractual
  relationships as required by law
• How can we give the public NOTICE, but still give
  the public PRIVACY?
• Eliminate all records from Internet view
• PROS a. Making access normally difficult (ie.
  pre-internet) gives people a sense of security
  not every nut case and computer weirdo can get
  my information! b. While record is still public,
  and can be viewed by coming to courthouse, it
  gives the illusion of control.
• CONS a. The business case for open access is a
  good one. Thousands of lookups per day for
  mostly legitimate use equals good business, good
  government. Wasnt that our business holding
  and preserving the public record and making it as
  accessible as possible? Free access, just as if
  they were to come to the county means less
  customer traffic and less customer service needed

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Recorded Documents

• Charge customers for access via the Internet
• PROS a) Eliminate inappropriate, idle,
  searching by having trusted third party
  agreements or at least the illusion of such b)
  Collect revenue to pay for special access
  method.
• CONS a) Gives illusion that if you can pay, you
  can get any information you want b) People can
  still use the information inappropriately.
• Redact specific Information from Documents
• PROS a) Sensitive information in question is
  removed automatically from the public record b)
  Depending upon the level and importance of the
  information, can have alternative method to get
  that information.
• CONS a) Changes the nature of public records
  since they are now incomplete, b) requires more
  work and funding on part of government agency
  doing the service c) hampers private industry
  that has used the information and have set up
  systems based on that use.t

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Dont Put Sensitive Info into the Docs!

• Pros
• Sensitive info not there
• Puts burden on preparer to remove
• Doesnt require redaction

• Cons
• Recorder must make sure info is not there
• Who has liability if info is buried in the
  document, not in the index fields?

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Washington State PREP (Property Records Education
Partners)

• PREP a NACRC/IACREOT/ALTA/AEA sponsored joint
  educational group (Pilot project)
• Washington State PREP first met September 2003
  Two Primary Subcommittees one was to deal
  with Privacy issues.

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WA PREP and Privacy

• PREP Membership voted to focus on taking PRIVACY
  action
• Propose proactive legislation before our
  legislators propose reactionary legislation from
  groups affected by privacy issues (Law, Safety
  and Justice groups, Veterans, Domestic violence
  victims, ID Theft victims)
• Such as
• Sheriffs bill Proposes redaction of all
  personal information on any record placed on the
  public record that represents employees, family
  members, volunteers, etc. of police, corrections,
  judicial employees.
• Judicial Officers Bill Proposes making
  non-public all personal information in the Human
  Resource files of employees, families, etc.

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SB 6573 Puts the burden on the document preparer

• Eliminate sensitive information on the document
  in the first place
• Washington State SB 6573 proposed not allowing
  the following information to be placed on
  documents for recording
• Mothers Maiden Name as associated to a specific
  person noted in the document
• Full Social Security Number
• Birthdate as associated to a specific person
  noted in the document

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Public Records

• Will keeping the data out of the records help
  with privacy?
• Yes if its not critical to the land records
  industries.
• No if the data is being compiled elsewhere and
  accessible anyway
• Will keeping the records off of the internet for
  free help privacy?
• Yes if the perception desired is that
  information is being protected
• No if the sensitive data can be retrieved
  anyway there is no real protection stalkers and
  ID thieves dont mind coming into county offices

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Other States

• Other states have adopted one, all or
  combinations of these remedies
• Florida
• Utah
• Virginia
• ETC
• WA state None of the legislation passed this
  session, so we are back to square one, with
  individual counties
• Taking all or some of the records off of the
  internet
• Installing subscription systems
• Redacting information as ordained locally, or
• Doing nothing

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Freedom of Information Will it stay that way in
US?

• Change open records law and adjust business
  relationships accordingly
• Take greater care with putting sensitive
  information everywhere only ask for what you
  need on publicly accessible documents change
  legislated document formats accordingly
• Start managing information better before making
  it open

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PRIA Panel Discussion

• Blue Lime Software
• We are an industry pioneer answering the need for
  accurate valuation through accurate, timely and
  complete data
• We serve the private and public sector
• Realtors
• Appraisers
• Lenders
• Insurance companies
• Governmental agencies
• Our primary data sources
• Multiple Listing Service (MLS)
• Deed
• Assessor
• Customer/Industry Benefits
• Elimination of many types of fraud (documentation
  and inflated appraisals)
• Competitive advantage, speed, efficiency and a
  better appraisal product

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We are facing challenges

• Assessor Data Challenges
• Inconsistent access to data
• Inaccurate data
• Lack of cooperation to share data
• Disparate data pricing
• Education
• User awareness of data quality risks and
  opportunities is in its infancy
• Data is the foundation of technology and industry
  advancement
• Inaccurate data equates to lost revenue for the
  public sector and lost profit for private
  industry
• Importance of fraud reduction
• False inflation of property values between 1990
  and 1998, Mortgage Asset Research Institute
  (MARI) reports 5 of appraisal misrepresented
  (they admit this figure is incorrectly low)
• Fabrication of documentation (MARI reports this
  as the single biggest fraud issue)
• IRS reports the number of real estate fraud
  investigations initiated by IRS Criminal
  Investigation doubled in just two years from 2001
  to FY 2003.

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Our Goals

• Drive Change
• Fraud prevention
• Consumers risk foreclosure, bankruptcy, and
  irreparable damage to credit rating
• Lenders risk foreclosures and delinquencies
• Governmental agencies risk lost revenue
• Industry standards
• Private vs. public data
• Data expiration date
• Data cost
• Data availability
• Improved technology Tools

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Our Mission
To ensure that IRS policies and programs
incorporate taxpayer and employee privacy
concerns and that the public is aware of our
privacy business practices.
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Privacy Program

• Privacy Awareness Training
• Policies
• Privacy Principles
• Privacy Impact Assessment

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IRS Privacy Principles

• Protecting taxpayer privacy is a public trust.
• Personal information will only be collected if it
  is necessary for tax administration or other
  legally authorized purposes.
• Information will be used only for the purpose for
  which it was collected, or as specifically
  authorized by law.
• Information will be collected directly from the
  individual to whom it relates. Information that
  is collected from third parties will be verified
  for accuracy with the subject before final
  action is taken.
• All IRS employees share in the responsibility to
  protect the privacy of individuals whose
  information they have access to taxpayers,
  employees, and visitors to IRS web sites.

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Privacy Impact Assessment

• Evaluation tool used to embed privacy into the
  design of information systems.
• Enables system developers and system owners to
  identify and evaluate privacy risks.
• Best Practice by CIO Council

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Privacy Impact Assessment

• Data in the System
• Access to the Data
• Attributes of the Data
• Maintenance of Administrative Controls

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Office of the Privacy Advocate Telephone
202-927-5170 fax [phone] Internet
www.irs.gov/privacy E-Mail privacy.advocate_at_irs.
gov Maya Bernstein Privacy Advocate Zaida
Candelario, Dorothy DAntoni, Susan Dennis,
Priscilla Hopkins, Mary Ronan, Gino Talbot,
Charlene W. Thomas, Brian Townsend
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IRS Privacy Policies

• Privacy Principles
• PIA Certification
• Web Notices

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Personal Identity

• Lack of identifying information creates
  difficulty confirming a person's personal
  history which impacts various types of commerce.
• Background searches are hindered, which in turn
  impact the ability of businesses to make prudent
  hiring decisions. Some examples of those at risk
  would include banks, credit card service
  companies, child care centers and transportation
  services.

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• Locating individuals for legitimate reasons
  becomes more difficult for example - parents
  avoiding child support responsibilities, heirs to
  real estate in order to conduct conveyances,
  adopted children in need of medical information
  and parents attempting to locate missing
  children.
• Inability to verify patterns of behavior of
  individuals regarding questionable insurance
  practices leads to higher risks for insurance
  companies which would likely pass costs on to the
  consumer.
• Even simple businesses such as dating services
  could be hampered in determining marital status
  of individuals posing as potential mates.

Personal Identity
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