DATE: January 26, 2015

REAFFIRMED: March 2, 2020

SUBJECT: The Treasury Data Integrity Board

  1. PURPOSE. This directive establishes a Department of the Treasury (“Treasury” or “the Department”) Data Integrity Board (“Board” or “DIB”), pursuant to the Privacy Act of 1974, as amended, (“Privacy Act”). It authorizes the issuance of Treasury Directive Publication (TD P) 25-06, “Computer Matching Handbook.” It also sets forth the policy for the Board’s membership, operations, and responsibilities, as well as the procedures for engaging in computer matching activities.
  2. SCOPE. This directive applies to all bureaus, offices, and organizations in the Department of the Treasury, including the offices of inspectors general. The provisions of this directive shall not be construed to interfere with or impede the authorities or independence of the Department’s inspectors general.
  3. POLICY. It is Treasury policy that:
    1. there shall be a DIB to oversee and coordinate Treasury-wide compliance with the Privacy Act’s matching program requirements and OMB guidance on matching activities;
    2. the Board shall consist of the Assistant Secretary for Management, the Inspector General, the Deputy Assistant Secretary for Privacy, Transparency, and Records (DASPTR), the Departmental Privacy Act Officer, and any other senior officials designated by the Secretary;
    3. any record contained in a system of records may only be disclosed to a recipient agency or non-federal agency for use in a matching program pursuant to a DIB-approved matching agreement;
    4. matching agreements shall meet the requirements of all relevant statutes, regulations, and OMB guidance, including 5 USC § 552a(o)(1);
    5. the Board shall review and approve or deny matching agreements, report matching programs to OMB and Congress, and provide interpretation and guidance on matching activities;
    6. all Treasury components, including its bureaus, offices, and organizations, that conduct matching programs or activities subject to the Privacy Act shall:
      1. 1) develop and execute matching agreements for approval by the DIB of source and recipient agencies; and
      2. 2) submit such matching agreements to the Board for approval at least 60 days before the date the match is to be conducted;
    7. no adverse action may be taken against any individual whose records are used in a matching activity, as a result of information produced by such matching activity, until the information is independently verified or the Board determines in accordance with guidance issued by the Director of OMB that:
      1. 1) the information is limited to identification and amount of benefits paid by the source agency under a federal benefit program;
      2. 2) there is a high degree of confidence that the information provided to the recipient agency is accurate; and
      3. 3) the individual received and did not respond to a notice containing a statement of the Department’s findings and informing the individual of the opportunity to contest the findings within the time established for the program (or a 30-day period beginning on the date on which the notice was mailed or otherwise provided to the individual if no period is established for the program).
  4. DEFINITIONS. The terms “record,” “system of records,” “matching program,” “recipient agency,” “non-federal agency,” “source agency” and “federal benefit program” are defined by the Privacy Act.
    1. The Board shall:
      1. 1) oversee Treasury’s matching activities, including matching programs and agency matching activities that are not matching programs, and provide interpretation and guidance on applicable requirements;
      2. 2) review and approve or deny all matching agreements for receipt or disclosure of records for matching programs to ensure compliance with all relevant statutes, regulations, and OMB guidance, including 5 USC § 552a(o);
      3. 3) approve or deny an agreement no later than 60 calendar days after receipt of the agreement and submit to agency officials any questions by day 30 of the 60-day period;
      4. 4) provide a brief memorandum to the head of the agency (or to the inspectors general in cases where they proposed the matching activity), describing the necessity for the delay if circumstances do not permit the DIB to approve or disapprove the matching program within 60 days;
      5. 5) review and approve or deny requests for a waiver of the cost-benefit analysis for matching programs, except where the requirement for a cost-benefit analysis is otherwise exempt;
      6. 6) review and approve or deny all requests for pilot programs (i.e., small scale matches whose purpose is to gather benefit/cost data on which to premise a decision about engaging in a full-fledged matching program);
      7. 7) review annually Departmental policies and procedures for the safeguarding, security, and proper disposal of records for matching programs;
      8. 8) review annually all matching programs in which Treasury participated during the year, as either a source or recipient agency, to determine compliance with applicable laws, regulations, guidelines, and matching agreements to ensure that the applicable requirements have been met;
      9. 9) meet annually to review all recurring matching programs in which Treasury has participated during the year, either as a source or recipient agency, to assess the costs and benefits of such programs, and for continued justification for such disclosures, and to consider whether any modifications are warranted; and
      10. 10) prepare an annual report describing Treasury’s matching programs, as provided for in 5 USC § 552a(u)(3)(D), and a biennial matching activity report, as required by OMB A-130, to submit to the Secretary and the Director of OMB, and to be made available to the public upon request.
    2. The Board may:
      1. 1) review and report on any Treasury matching activities that are not matching programs;
      2. 2) report on an aggregate basis, if and to the extent necessary to protect ongoing law enforcement or counterintelligence investigations, agency matching activities that are not matching programs; and
      3. 3) delegate responsibilities such as compiling reports, advising program officials, and maintaining and distributing information about the accuracy and reliability of data used in a matching program – but may not delegate the approval of matching agreements.
    3. Heads of Bureaus and the inspectors general, as it relates to their respective bureaus and offices, and the Assistant Secretary for Management, as it relates to the Departmental Offices, shall:
      1. 1) establish procedures to ensure matching programs within their bureau or office are consistent with the Privacy Act and OMB guidance;
      2. 2) ensure that employees responsible for implementing matching programs are knowledgeable about the provisions and requirements of the Privacy Act, as well as relevant regulations and guidance;
      3. 3) report new and ongoing matching activities to the Board; and
      4. 4) submit the following information, as required, to the Board:
        1. a) data for OMB’s Biennial Matching Activity Report to Congress; and
        2. b) a report on the review of each ongoing matching program in which the component has participated during the year, either as a source or as a matching agency.
    4. The DASPTR shall:
      1. 1) serve as the Chairman of the Board;
      2. 2) provide policy guidance and direction on privacy protection matters as they relate to matching activities, to include matching programs and agency matching activities that are not matching programs;
      3. 3) provide critical review and analysis of issues and problems impacting matching and privacy protection activities within Treasury;
      4. 4) advise the Board on the operational implications of policy decisions made necessary by congressional, OMB, and/or Board action; and
      5. 5) provide day-to-day operational support for the Board.
    5. The Departmental Privacy Act Officer shall serve as secretary to the Board and shall:
      1. 1) circulate matching agreements to the Board for review;
      2. 2) provide a summary of Board members’ recommendations to the Chairman of the Board for final approval or denial;
      3. 3) serve as a liaison between the Board and Treasury components responsible for matching activities;
      4. 4) review and publish notices of matching programs;
      5. 5) maintain the official files on correspondence, OMB guidelines, procedures, and any other documentation pertinent to the Board and its activities;
      6. 6) prepare correspondence, reports, schedules, plans, and procedures as necessary for the Board to oversee and coordinate matching activities within the Department;
      7. 7) prepare and maintain the minutes of Board meetings; and
      8. 8) transmit notice of matching program, Treasury reports, and supporting documentation to the Senate Committee on Governmental Affairs and to the House Committee on Government Reform and Oversight and to OMB at least 40 days prior to the initiation of a matching program.
    6. Any Treasury component proposing to engage in or renew a matching program shall submit to the Departmental Offices Privacy Act Officer at least 60 days in advance of conducting the match:
      1. 1) a memorandum stating the purpose of the matching program;
      2. 2) the proposed agreement to cover the matching program;
      3. 3) a cost-benefit analysis, unless the Board has waived the analysis or if it is otherwise not required by the Privacy Act; and
      4. 4) a notice of the establishment of the matching program for publication in the Federal Register, if Treasury is the recipient agency.
  6. EXTENSION OF MATCHING PROGRAMS. Matching agreements shall remain in effect only for such period as is required by statute, regulation, or OMB guidance, including 5 USC § 552a(o)(2), or as the Board determines is appropriate in light of the purposes and length of time necessary for the conduct of the matching program. Within 90 days of the expiration of a matching agreement, the Board may, without additional review, renew the matching agreement for a current, ongoing matching program if the program will be conducted without any change and each party to the agreement certifies to the Board in writing that the program has been conducted in compliance with the matching agreement.
    1. Disapproval by the Board. If the Board disapproves a matching agreement, a party to the agreement may appeal the disapproval to the Director, OMB, Washington, D.C. 20503. According to OMB final guidance in the Federal Register Notice, dated June 19, 1989, appeals must be made within 30 days after the Board’s written disapproval. The appealing party shall submit with its appeal the following information:
      1. 1) copies of all documentation accompanying the initial matching agreement proposal;
      2. 2) a copy of the Board’s disapproval and reasons therefore;
      3. 3) evidence supporting the cost effectiveness of the match; and
      4. 4) any other relevant information, such as timing considerations and the public interest served by the match.
    2. OMB Approval. A matching program approved by OMB in response to such appeal will not become effective until 30 days after the OMB Director reports the decision to Congress.
    3. Recourse by the Inspector General and the TIGTA. If the Board and the Director of OMB both disapprove a matching program proposed by the Inspector General and/or the TIGTA, the Inspector General and/or TIGTA may report that disapproval to the Secretary of the Treasury and to the Congress.
    1. Privacy Act of 1974, as amended, 5 USC § 552a.
    1. OMB Circular A-130, Revised, Appendix I, “Federal Agency Responsibilities for Maintaining Records About Individuals.”
    2. OMB Bulletin 89-22, “Instructions on Reporting Computer Matching Programs to the Office of Management and Budget (OMB), Congress and the Public.”
    3. OMB Final Guidance Interpreting the Provisions of Public Law 100-503, the Computer Matching and Privacy Protection Act of 1988, 54 Fed. Reg. 25818 (June 19, 1989).
    4. The Computer Matching and Privacy Protection Amendments of 1990 and The Privacy Act of 1974, 56 Fed. Reg. 18599 (April 23, 1991).
    5. OMB M-13-20, “Protecting Privacy while Reducing Improper Payments with the Do Not Pay Initiative.”
  10. CANCELLATION. Treasury Directive 25-06, “The Treasury Data Integrity Board,” dated January 16, 2009, is superseded.
  11. OFFICES OF PRIMARY INTEREST. Office of the Assistant Secretary for Management, Office of the Deputy Assistant Secretary for Privacy, Transparency, and Records.


Brodi Fontenot
Assistant Secretary for Management