APPRAISAL REPORT FOR TACTICAL DATA SETS

File/Document ID:	

Agency:		Inland Revenue Department
P O Box 2190
			Wellington 6014

Agency Code:	AAEC

Scope:		Externally accessed Tactical Data Sets

Contact:		[name removed]

1. Appraisal Summary

1.1	Agency Coverage

Inland Revenue is the government department that administers taxation legislation and collects over 80% of the revenue that funds government programmes. It also helps to deliver government social assistance programmes such as child support, student loans, family assistance, and paid parental leave. Inland Revenue’s business is complex and it deals with a wide range of customer groups which can be defined as:

•	Large enterprises
•	Small-medium enterprises
•	Individuals
•	Families
•	Not for profit organisations
•	Intermediaries

In assisting customers to meet their obligations Inland Revenue, from time to time gathers additional information from third party sources for the enforcement or administration of the Revenue Acts.  In such cases Inland Revenue uses the provisions authorised by Section 17 of the Tax Administration Act 1994.

This provision may apply to a request to obtain information relating to a single individual, a group of like individuals, or in some cases all records contained in a database held by the third party.  

Examples of such requests for information may be:

•	Seeking bank information relating to a single identified individual;
•	Seeking details of members of a particular industry group such as, the membership register of Horticulture New Zealand;
•	Seeking a record of all motor vehicle registration for a given period from Land Transport Safety Authority;
•	Seeking historic geographical property rolls from Quotable Value New Zealand. 

The Inland Revenue Department has introduced an External Data Set Framework to enhance how it governs the use of its statutory powers under section 17 of the Tax Administration Act 1994 in obtaining Tactical Data Sets from third parties.

1.2	Definition of terms

•	Tactical data sets in this case pertains to third party data which is accessed for risk assessment, intelligence gathering and compliance strategy purposes.

•	Section 17 of the Tax Administration Act 1994 empowers the Commissioner of Inland Revenue to require any person to furnish in writing any information and produce books and documents for inspection where it is considered “necessary or relevant” for the Commissioner to exercise his statutory functions.

•	Raw data is defined as the copy of the data set obtained from the external source prior to any manipulation by Inland Revenue.

•	Business purpose is defined as a compliance risk or initiative that is considered necessary or relevant to the administration or enforcement of the Revenue Acts.

•	End of business purposes is defined as a date in time in which the business purpose has been met and this will often equate to ensuring that the data is held until all legal avenues have been exhausted in respect of that stated purpose.

1.3	Scope
The report covers two sub-classes of tactical data sets: raw tactical data sets and customised tactical data sets.

The information will principally be transferred by electronic means, but may be transferred in hard copy form.  The data sets will be stored in a secure file storage system for analysis either immediately or at a later date.  

All media containing tactical data sets are included in this report.  Current media include, but are not limited to, CD’s, DVD’s, film, tape cartridges, electronic files, and paper.

2. Appraisal Circumstances
The information obtained from external tactical data sets assist business areas to tailor services to meet the customer’s needs thereby encouraging and enhancing compliance.    Data matching of external data sets also assists in identifying those outside the system and discrepancies in customer information, therefore facilitating the detection of non compliance.

The data intended to be covered by this appraisal report is only external tactical data sets that have been gained under tax legislative provisions, namely Section 17 of the Tax Administration Act 1994, and where retained may be added to information already held by Inland Revenue for the purposes of administering and enforcing the Revenue Acts. 

Research has confirmed that society is suspicious of bureaucracies and their use of technology to capture and utilise personal information. International research highlights that the impacts arising from the breach of privacy principles are significant.

Privacy surveys have demonstrated a greater level of acceptance of data sharing where the reasons for the exchange were clearly visible and explained.  Therefore privacy issues and customer anxiety may be minimised through a transparent approach to accessing, collating, matching, security and disposal of information. While section 17 of the Tax Administration Act 1994 overrides the application of privacy principles contained within the Privacy Act the External Data Set Framework introduced by the Department proactively incorporates privacy principles, e.g. only personal information necessary for an identified and robust purpose is collected, and the information is not retained beyond serving that discrete purpose.  The External Data Set Framework was discussed with the Office of the Privacy Commissioner during its development.

The New Zealand tax system operates on the basis of a self assessment regime.  Tactical data sets are obtained for a specific purpose and it is imperative to ensure that the information is not used for an unspecified purpose. 

Any failure to dispose of this information could seriously undermine public trust in government, and in particular Inland Revenue.  The authority to dispose of this data promotes public confidence in Inland Revenue as a Government organisation.

This report seeks approval to dispose of these tactical data sets once they have been used for the purpose in which the data was obtained for.

3. Agency Information
Agency code:		AAEC
Agency name:		Inland Revenue Department
Year established:		1976

4. Methodology

This disposal authority request is for a schedule based on class: an ongoing authorisation where records are identified by broad band/class. As they are received, records can be sentenced for future destruction or retention.  

Tactical Data Set Lifecycle

Raw information received 
The volumes of information intended to be collected using the provisions of Section 17 of the Tax Administration Act 1994 will be large.  The raw data will be analysed and manipulated to form customised data sets.  The raw data sets will be held off line until the specific business purpose has been met and we seek authority to dispose of this data at that time.  

The raw data set received is a duplicate as the original data remains with the Third Party from whom the data was requested from.

Information received and integrated after analysis
Where information received is retained by Inland Revenue for its business purposes, whether integrated with specific information held or stored separately, the information will be handled using those practices already in use by Inland Revenue. 

Once the information is received by Inland Revenue, the information becomes tax secret information and as such is treated in the same way as information that may be provided directly by a customer.  

Inland Revenue will dispose of the information for the sub classes referred to herein using current practises for electronic (and hard copy documentation) data destruction.  Those data sets on optical media or if collected on USB key will be archived to optical media and the USB key wiped. A centralised area would be responsible for destroying the optical media the datasets are received or archived on. 

5. Disposal Criteria

The following data sets will be recommended for destruction:

•	Raw Tactical Data Sets
These data sets contain the raw data obtained from the third party that are retained by Inland Revenue off line until such time that the specific, identifiable business purpose has run its course.  The raw data will be analysed and manipulated to form customised data sets.  

•	Customised Tactical Data Sets
These data sets are based on raw tactical data sets that have been normalised, manipulated, matched and analysed.  These data sets form records that are retained by Inland Revenue, whether integrated with specific information held or stored separately, for a specific, identifiable business purpose. 

6. Data Set Type Information
A class is a group of documents or identifiable sub-divisions of series or record groups, having common characteristics or similar value.  This section examines the two sub-classes of the record class called “tactical data” from a functional and evidential value perspective. 

6.1 Raw Tactical Data Sets

Sub Class number:		1.1

Description:	
These data sets contain the raw data obtained from the third party that are retained by Inland Revenue off line until such time that the specific, identifiable business purpose has run its course.  The raw data sets form the basis of the customised data sets.

Value:
Records in this sub-class do not have archival value.  Raw tactical data sets do not have high evidential value, as they do not always contain complete and fully accurate information.  The evidential value of these raw data sets is however important, especially in the event that manipulations need to be replicated either to correct inaccurate assumptions made during normalisation or if they need to be replicated for or explained in court proceedings.

Recommendation: 
Destroy once the data has been used for the specific purpose for which it was obtained.

6.2 Customised Tactical Data Sets

Sub Class number:		1.2

Description:	
These data sets are based on raw tactical data sets that have been normalised, manipulated, matched and analysed.  These data sets form records that are retained by Inland Revenue, whether integrated with specific information held or stored separately, for a specific, identifiable business purpose. 

Value:
Customised data sets have substantial evidential value in respect of a specific compliance risk or opportunity.  These data sets quantify compliance risks and opportunities and as such have evidential value for a specified period of time.  A data custodian is charged with considering the retention period for these customised data sets.  These records contain the most accurate information.  The customised (purpose specific) data allows Inland Revenue to identify and employ appropriate responses.

Recommendation: 
Destroy once the data has been used for the specific purpose for which it was obtained.

7. Recommendation

This appraisal report seeks approval to dispose of tactical data sets requested by Inland Revenue from third parties in accordance with section 17 of the Tax Administration Act 1994 once the data has been used for the purpose in which it was requested.