U.S. Postal Service:

Improved Oversight Needed to Protect Privacy of Address Changes

GGD-96-119: Published: Aug 13, 1996. Publicly Released: Aug 13, 1996.

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Pursuant to a congressional request, GAO examined the U.S. Postal Service's oversight of the National Change of Address (NCOA) program, focusing on: (1) how the Postal Service collects, disseminates, and uses NCOA data; and (2) whether the Postal Service adequately oversees the release of NCOA data in accordance with privacy laws.

GAO found that: (1) the Postal Service uses 24 licensees to collect and disseminate address-correction information; (2) the licensees provide address services to other private firms and organizations in accordance with standard licensing agreements; (3) the Postal Service has been unable to prevent, detect, or correct potential breaches in the licensing agreement; (4) the Postal Service audits the software that licensees use to match their mailing lists with NCOA files, reviews NCOA advertisements that licensees propose to use, and investigates complaints concerning the NCOA program; (5) Postal Service officials believe that the NCOA licensing agreement helps to ensure that federal privacy guarantees are not compromised through the operation of the NCOA program; (6) the Postal Service has not expressed a clear and consistent position regarding the use of NCOA data to create new-movers lists; (7) the Postal Service failed to terminate the license of any licensee that failed successive process audits in 1992; (8) the NCOA program office is not terminating licensees that fail to maintain address-matching software or enforcing the performance standards prescribed in the license agreements; and (9) the Postal Service needs to enforce these limitations to ensure that the use of NCOA-derived data is limited to the purpose for which it was intended.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: By letter of May 30, 1996, the Postmaster General advised that oversight procedures had been established to address all of the recommendations.

    Recommendation: To strengthen oversight of the NCOA program, the Postmaster General should require the NCOA program office to develop and implement written oversight procedures, which should include: (1) the responsibilities and timetables for using seed records to help verify that licensees release new addresses only as a result of accurate name and address matching; (2) requirements to obtain and review licensees' NCOA-related proposed advertisements, document the review, and notify licensees of the results within the time period prescribed in the licensing agreement; and (3) requirements for systematically recording all NCOA-related complaints received, including actions taken to resolve complaints.

    Agency Affected: United States Postal Service

  2. Status: Closed - Implemented

    Comments: By letter of May 30, 1996, the Postmaster General advised that procedures had been established to address all of the recommendations.

    Recommendation: To strengthen oversight of the NCOA program, the Postmaster General should require the NCOA program office to enforce all provisions of the licensing agreement, including: (1) conducting at least the prescribed minimum number of license audits, currently three per contract year; and (2) suspending or terminating, as appropriate, licensees that fail two consecutive audits or that are determined to be in noncompliance with other terms or conditions of the licensing agreement. (As provided in the agreement, licensees that fail three consecutive audits should be terminated.)

    Agency Affected: United States Postal Service

  3. Status: Closed - Not Implemented

    Comments: The Postal Service declined to implement the recommendation and restated its objections in a letter dated September 3, 1997 to the Chairman of the House Subcommittee on the Postal Service. It did not believe that the restriction on the new-movers list on the part of licensees' customers was required by the Privacy Act or could be enforced. GAO believes that the Privacy Act does restrict the use of address data and that the enforceability of restrictions on such use does not present a barrier to notifying customers of licensees that the Privacy Act restricts the use of NCOA data.

    Recommendation: The Postmaster General should further restrict the use of NCOA-linked data to create or maintain new-movers lists by explicitly stating it on the acknowledgement form that is signed by customers of NCOA licensees.

    Agency Affected: United States Postal Service

 

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