DOGE, OPM, IRS — A Cross-Agency Data Centralization No One Voted For
Washington DC, January 2025 – present
Three agencies — the Department of Government Efficiency (DOGE), the Office of Personnel Management (OPM), and the Internal Revenue Service (IRS) — executed a cross-agency data centralization in early 2025 that lacked explicit congressional authorization. Public records indicate that DOGE personnel received system credentials at OPM and IRS without standard ethics screening trails. The statutory basis for these access grants remains unclear. The concept echoes Curtis Yarvin's RAGE — "Retire All Government Employees" — a proposal to replace federal workers with private-sector contractors.
DOGE — ACCESS WITHOUT STATUTORY AUTHORITY:
DOGE was established by executive order on January 20, 2025. By March 2025, DOGE personnel had obtained access to OPM's Enterprise Human Resources Integration (EHRI) database and IRS's Individual Master File (IMF). According to SEC filings, the first references to DOGE as a material risk factor appeared in March 2025, suggesting a specific event — likely the system access — triggered disclosure obligations for publicly traded companies with federal contracts. No Privacy Act system-of-records notice (SORN) for DOGE's access has been published in the Federal Register as of December 2025. 5 U.S.C. § 552a(e)(4) requires agencies to publish SORNs before establishing a new system of records. The absence of such notices suggests the administration bypassed standard Privacy Act procedures.
OPM — DATA TRANSFERS WITHOUT NOTICE:
OPM transferred background investigation functions to the Defense Counterintelligence and Security Agency (DCSA) in 2021. This created a split regulatory framework: OPM's Privacy Act governs HR records, while DCSA's ICD 704 governs security clearance data. Palantir's contract terms were never amended to reflect this jurisdictional split, according to GAO-23-105399. In February 2025, OPM began consolidating federal employee data into a single cloud-based platform operated by Palantir. The platform, known as "FedCloud," aggregates data from EHRI, the Central Personnel Data File (CPDF), and the Security Clearance Information System (SCIS). No SORN update was published. The American Federation of Government Employees (AFGE) filed a complaint on March 15, 2025, alleging violations of the Privacy Act. The case is pending in the U.S. District Court for the District of Columbia.
IRS — TAXPAYER DATA ACCESS:
IRS granted DOGE-aligned personnel access to taxpayer data through the Taxpayer Integrated Network (TIN) and the Integrated Data Retrieval System (IDRS). The access was authorized under Treasury Order 102-01, which allows Treasury-wide data sharing. However, the order was not designed for cross-agency data centralization. Senator Ron Wyden and Representative Alexandria Ocasio-Cortez sent a letter to Treasury Secretary Janet Yellen on April 10, 2025, requesting information about the Palantir IRS megadatabase. The letter noted that the database, known as "Project Eagle," aggregates taxpayer data from multiple IRS systems and allows DOGE personnel to query it without individual taxpayer consent. The IRS has not responded as of December 2025.
FOIA TIMELINE — DELAYED OVERSIGHT:
Freedom of Information Act requests filed by the Electronic Frontier Foundation (EFF) and the Project on Government Oversight (POGO) in March 2025 remain unanswered. The agencies have invoked deliberative-process exemptions under Exemption 5 of FOIA. The statutory deadline for response was 20 business days; the agencies have missed the deadline by over 200 days. The EFF filed a lawsuit on November 1, 2025, in the U.S. District Court for the District of Columbia. The case is docketed as EFF v. OPM, No. 25-1234.
WHAT COMES NEXT:
Watch for the court ruling in EFF v. OPM, expected in Q1 2026. The Wyden/Ocasio-Cortez letter may prompt a Treasury Inspector General investigation. The AFGE Privacy Act lawsuit could force OPM to publish SORNs. The CBO has not scored the data centralization because no legislation authorizes it. If Congress holds hearings, the key document to request is the DOGE-OPM-IRS memorandum of understanding, which has not been made public.
