U.S. Postal Service:

Status of Efforts to Protect Privacy of Address Changes

GGD-99-102: Published: Jul 30, 1999. Publicly Released: Jul 30, 1999.

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Pursuant to a congressional request, GAO updated its previous report on the U.S. Postal Service's National Change of Address (NCOA) program, focusing on: (1) the actions the Service has taken in response to GAO's 1996 report; and (2) whether any additional actions are needed to strengthen the Service's oversight of the program.

GAO noted that: (1) as recommended, the Service has developed and implemented written procedures that addressed its NCOA program oversight and control responsibilities for: (a) using seed records to help detect the unauthorized disclosure of NCOA data by licensees, should it occur; and (b) reviewing, responding to, and documenting NCOA-related complaints and inquiries from postal customers and NCOA-related proposed advertisements by licensees; (2) however, procedures designed by the Service to ensure that it is alerted when mail is sent to seed record addresses were not working as intended; thus, the Service lacked assurance that the seeding process provided an effective program oversight mechanism; (3) further, even though required to do so by the licensing agreement or by prescribed program procedures, during the 1996 through 1998 period GAO examined, the Service did not always: (a) conduct the minimum number of licensee audits, including on-site audits; (b) promptly reaudit licensees that failed initial audits; or (c) promptly or always suspend or terminate licensees that failed successive audits; (4) also, the Service reported that it had performed more licensee audits than were documented in its audit files; however, even when GAO included these additional audits in its data, GAO determined that the Service did not perform all audits required; (5) the Service has taken no action on GAO's recommendations that it explicitly state, in the acknowledgement form signed by customers of licensees, that NCOA program-linked data are not to be used to create or maintain new-movers lists; and (6) GAO continues to believe that more specific language in the acknowledgement form could help ensure that use of NCOA program-linked data is limited to the purposes for which they were collected.

Matter for Congressional Consideration

  1. Status: Closed - Not Implemented

    Comments: No action has been taken on this matter and none is anticipated, so the matter for consideration should be closed.

    Matter: If Congress is concerned about the failure of the Postal Service to implement the recommendation GAO made in its prior report concerning the creation and maintenance of new-movers lists by customers of its licensees, it may wish to amend the Postal Reorganization Act of 1970. An amendment could either: (1) expressly prohibit the use of change-of-address data by licensees and their customers in the creation or maintenance of new-movers lists; or (2) specifically require the Service to have its licensees and their customers acknowledge in writing that they have been informed and understand that change-of-address data may not be used for any purpose not authorized by law, including the creation or maintenance of new-movers lists.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: According to the Postal Services' 31 U.S.C.720 response to the Committee on Appropriations (letter dated Oct. 26, 1999), action to implement this recommendation has been completed.

    Recommendation: To help ensure that the NCOA program operates in compliance with applicable provisions of federal privacy law and NCOA program requirements, the Postmaster General should ensure that NCOA program officials: (1) conduct the minimum number of annual and on-site audits, as well as reaudits of licensees as required by the licensing agreement and the program procedure guide; and (2) document in the program office files licensee audits performed, the results of those audits, and actions taken.

    Agency Affected: United States Postal Service

  2. Status: Closed - Implemented

    Comments: According to the Postal Services' 31 U.S.C. response (letter dated Oct. 26, 1999), action on this recommendation has been completed.

    Recommendation: To help ensure that the NCOA program operates in compliance with applicable provisions of federal privacy law and NCOA program requirements, the Postmaster General should also ensure that NCOA program officials and other appropriate Service officials coordinate actions to identify and correct weaknesses in the process of alerting program officials when mail is sent to seed record addresses so that the process works as intended.

    Agency Affected: United States Postal Service

  3. Status: Closed - Implemented

    Comments: According to the Postal Services' 31 U.S.C. 720 response (letter dated Oct. 26, 1999), action has been completed on this recommendation.

    Recommendation: To help ensure that the NCOA program operates in compliance with applicable provisions of federal privacy law and NCOA program requirements, the Postmaster General should also ensure that NCOA program officials and other appropriate Service officials coordinate actions to ensure that licensees that fail successive audits are promptly suspended or terminated, as appropriate, from the program or that the licensing agreement is revised to reflect Service policy regarding when licensees will be suspended or terminated.

    Agency Affected: United States Postal Service

 

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