; by (bb) the number of System inquiries submitted for employment authorized individuals. (III) Error rate determination The audits required under this clause shall— (aa) determine the error rate for identity determinations pursuant to subsection (c)(1)(F) for individuals presenting their true identities in the same manner and applying the same standard as for employment authorization; and (bb) include recommendations, as provided in subclause (I), but no reduction in fines pursuant to subclause (IV) (IV) Reduction of penalties for recordkeeping or verification practices following persistent system inaccuracies Notwithstanding subsection (e)(4)(C)(i), in any calendar year following a report by the Inspector General under subclause (I) that the System had an error rate higher than 0.3 percent for the previous fiscal year, the civil penalty assessable by the Secretary or an administrative law judge under that subsection for each first-time violation by an employer who has not previously been penalized under this section may not exceed $1,000. (iv) Records security program Any person, including a private third party vendor, who retains document verification or System data pursuant to this section shall implement an effective records security program that— (I) ensures that only authorized personnel have access to document verification or System data