Objectives, Scope, and Methodology

The objectives of our review were to determine (1) how the Postal Service collects, disseminates, and uses NCOA program data to provide mailers with accurate change-of-address information and (2) whether the Postal Service adequately oversees the release of NCOA data in accordance with privacy provisions of relevant federal laws. Thus, Postal Service officials said they believe that the NCOA program does not violate the prohibition in the Privacy Act against the unauthorized disclosure of an individual’s “name and address.”

		Privacy Provisions of the Licensing Agreement

Postal Service officials said they believe that the NCOA licensing agreement, with its conditions and performance provisions, helps to ensure that federal privacy guarantees are not compromised through the operation of the NCOA program. The Postal Service has set a high standard for the performance of licensees’ address-matching software. Further, the modification requires the Postal Service to terminate the license of any licensee that fails three consecutive audits. The Postal Service did not terminate the license of any of the 10 licensees who failed successive process audits during 1992. However, the Postal Service failed to respond to these proposed advertisements. Finally, we found that the Postal Service had not clearly communicated, through licensees, to licensees’ customers, the restrictions on the use of NCOA data to create or maintain new-movers lists. Recommendations

To strengthen oversight of the NCOA program, we recommend that the Postmaster General 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; and in addition, enforce all provisions of the licensing agreement, including (1) conducting at least the prescribed minimum number of licensee 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. Unless the Postal Service implements and attempts to enforce these limitations, it cannot ensure that use of NCOA-derived data is limited to the purpose for which it was gathered. U.S.
Why GAO Did This Study

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.

What GAO Found

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.