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Part 11. Communications and Liaison

Chapter 3. Disclosure of Official Information

Section 38. Role and Responsibilities of Disclosure Managers

11.3.38  Role and Responsibilities of Disclosure Managers

11.3.38.1  (09-21-2007)
Purpose

  1. This section provides guidelines to assist Disclosure Managers in administering an effective and balanced Disclosure program.

11.3.38.1.1  (04-01-2006)
Background

  1. Public confidence in the ability of the Internal Revenue Service (IRS) to protect the confidentiality of tax information influences taxpayer compliance. A perception that the IRS is careless in preserving privacy rights is apt to have serious compliance ramifications.

  2. Congress, in the exercise of its oversight function, has expressed concern over situations where privacy violations appear to have occurred. This can be expected whenever there are indications of improper disclosures or improper use of information by IRS employees.

  3. Disclosure Managers are responsible for developing a program that encompasses activities that promote privacy and/or improve the efficiency of tax administration (program management) and provides for timely and accurate responses to requests for information (casework).

11.3.38.1.2  (04-01-2006)
Objectives

  1. The primary objectives of the Disclosure program are:

    1. Promoting the protection of and confidentiality of tax information

    2. Preserving the privacy rights of taxpayers and employees

    3. Releasing all requested tax and other sensitive information when appropriate

    4. implementing programs to ensure that IRS employees are fully aware of their disclosure responsibilities

    5. Responding to requests for access to tax or other sensitive information from various sources

11.3.38.2  (04-01-2006)
Organizational Structure and Placement

  1. The Disclosure Manager serves as the first line manager over employees who are the disclosure/privacy expert points of contact for his/her local office (i.e., for employees and offices in their assigned geographic area).

  2. The Disclosure Manager reports directly to the Area Manager, GLD.

  3. The GLD Area Manager is responsible for evaluating and reviewing the Disclosure Manager’s management of the Disclosure program.

11.3.38.3  (04-01-2006)
Responsibilities of Disclosure Manager

  1. The Disclosure Manager is responsible for planning and maintaining a balanced program consistent with the IRS’ Balanced Measures and consistent with operational priorities established in the SB/SE GLD Program Letter.

  2. Guidelines for the Disclosure program are often provided by Headquarters and the GLD Area Manager; however field Disclosure Managers may implement local programs to ensure the confidentiality and integrity of IRS records and to protect taxpayer and employee privacy.

  3. The Disclosure program is divided into two categories:

    1. Case management

    2. Program management

    Note:

    The case management responsibilities are described throughout IRM 11.3. This IRM Section will describe specific program management responsibilities and the actions necessary to carry out these responsibilities.

  4. Despite the size of the case management workload, program management responsibilities are equally important and must be met. Efficient and appropriate use of resources is the key in meeting this objective. The effective use of available resources and delegating casework not requiring a high level of Disclosure technical expertise to the appropriate function are two ways this balance can be achieved.

  5. Disclosure office staff serve as the technical experts in all disclosure/privacy matters. Their ability to provide accurate and timely guidance is a key element of an effective program.

  6. Disclosure Managers are responsible for:

    1. Developing and administering local disclosure programs, procedures and practices

    2. Coordinating and integrating the Disclosure program with other functions within their area of geographic responsibility

    3. Ensuring that Disclosure Office case and program files contain sufficient documentation to provide assurance that proper legal adherence and procedures have been followed

    4. Ensuring that Disclosure work is in compliance with IRM correspondence requirements

    5. Supervising a staff of employees

  7. Most disclosures made by employees in any given IRS office are made by individuals other than Disclosure personnel. Through program management delivery, the Disclosure Manager imparts the knowledge necessary for management and front-line personnel to make correct disclosure decisions.

  8. The Disclosure Manager serves as liaison in disclosure matters with other governmental agencies.

  9. The Disclosure Manager assists the Governmental Liaison (GL) in working with other governmental agencies.

  10. There are many aspects of the work that are also affected by privacy policies and initiatives promulgated by the Office of Privacy, a Headquarters function that develops and implements privacy policy for the IRS. Since the Office of Privacy does not maintain a field operation, the Disclosure Manager, because of his/her expertise, may be called on to assist or advise in matters concerning privacy policy that impacts field operations in certain instances.

11.3.38.3.1  (04-01-2006)
Governmental Liaison

  1. The Office of Governmental Liaison and Disclosure (GLD) has program responsibility for liaison with State tax agencies.

  2. The Disclosure Manager assists the local GL who serves as the primary contact with State tax agencies.

  3. The Disclosure Manager supports the GL by:

    1. Reviewing and approving negotiated agreements, MOUs, and electronic data exchanges

    2. Coordinating actual exchanges of information

    3. Implementing joint initiatives that mutually benefit all agencies

11.3.38.4  (09-21-2007)
Program Management Responsibilities

  1. An effective disclosure program requires the balancing of resources and priorities directed towards delivery of both case and program management objectives. A Disclosure Manager must be technically and administratively competent to accomplish both objectives.

  2. Disclosure Managers must prepare and submit a written action plan for all Disclosure work (including casework) at the beginning of each fiscal year to the area manager. Priorities should be set, casework projected, and resources allocated.

11.3.38.4.1  (04-01-2006)
Disclosure/Privacy Awareness

  1. The principal objective of the Disclosure/Privacy Awareness program is to ensure, to the extent possible, that all employees know the disclosure and privacy statutes and principles and apply this knowledge correctly in the performance of their duties.

  2. A successful disclosure/privacy awareness program is predicated on a multiplier effect (awareness being further shared and disseminated by recipients). This increases the likelihood of employee compliance with disclosure/privacy statutes and principles. A high degree of compliance translates into:

    1. Taxpayer and employee confidence that confidential information is not being misused

    2. Reduced incidences of improper access (inspection) and disclosures

    3. Assurance to Congress that the IRS is providing its employees with the knowledge they need to understand and apply disclosure/privacy rules consistently and correctly

  3. Although primary program responsibility for ensuring awareness of disclosure/privacy requirements rests with the Disclosure Manager, all managers, regardless of function, are responsible for making certain their employees correctly observe disclosure/privacy laws and principles.

  4. Headquarters Disclosure is responsible for helping to identify awareness issues and develop materials for field Disclosure Managers' use and distribution. These products should be used if at all possible to ensure delivery of a consistent and accurate message is delivered. Copies of various presentations and Hot Topics are contained on the GLD website.

  5. The following actions must be taken by Disclosure Managers to address awareness program objectives:

    1. Develop and execute a fiscal year written plan encompassing disclosure/privacy awareness activities that meet both local and Headquarters directed awareness needs. This plan must be submitted to and approved by the appropriate GLD Area Manager. A template has been developed for this purpose and is included at IRM Exhibit 11.3.38-1. The use of this template or equivalent is mandatory.

      Note:

      This should be a flexible document that may be revised or amended throughout the year as circumstances dictate, but must contain sufficient coverage of those areas required to be addressed by the annual GLD Program Letter.

    2. Document all efforts to promote awareness on E-DIMS. Issues covered in awareness efforts should be relevant, timely and accurate. Copies of outlines and/or notes must be maintained and available for review by managers and others with oversight responsibilities.

  6. Functional Coordinators (if available) may be called upon to provide training and awareness presentations within their functions.

  7. GLD’s technical HQ staff (under the Chief, Disclosure) may also participate in disclosure/privacy awareness activities.

11.3.38.4.2  (09-21-2007)
Quality/Privacy Reviews

  1. Quality/privacy reviews are used to determine the level at which employees understand and observe disclosure/privacy rules, principles and procedures.

  2. At the same time, quality/privacy reviews:

    1. Allow analysis of the effectiveness of awareness efforts

    2. Isolate areas of disclosure weakness

    3. Assess progress in overcoming these weaknesses

    4. Determine areas where additional emphasis is appropriate

  3. Quality/privacy reviews are mandatory. Disclosure Managers are responsible for developing and executing a fiscal year review plan focusing on those areas required to be included in the annual plans as discussed in the GLD Program letter, but also incorporating reviews of local functions as appropriate. All plans must be approved by the GLD Area Manager. A template has been developed for this purpose and is included as IRM Exhibit 11.3.38-2. The use of this template or equivalent is mandatory.

  4. The plan should include procedures for:

    1. Conducting a review

    2. Reporting results of the review

    3. Taking follow-up action, if necessary

    Note:

    These reviews should be conducted on an ongoing basis and consideration should be given to incorporating Disclosure Quality/Privacy Reviews into existing functional review systems.

    Example:

    Functional quality assurance personnel can review work products against disclosure requirements along with their functional requirements and provide appropriate feedback to the Disclosure Manager.

  5. Quality/privacy reviews conducted by the functions themselves are a means of measuring disclosure compliance. Whether an office relies on functional participation or not, the Disclosure Manager should periodically review the disclosure standards for quality, accuracy, and timeliness to ensure that they properly address the disclosure requirements affecting the functions.

    Note:

    Records management (destruction) requirements must be considered during reviews, especially in light of Privacy Act and IRS Privacy Principles standards that generally require only relevant and necessary records be maintained.

  6. The following is a non-exhaustive list of suggested issues that may warrant a quality/privacy review. The planning of discretionary reviews should be predicated upon identifying a clear need at the local level and the existence of available resources to deliver reviews over and above the GLD Program directed reviews.

    1. IRC 6103(c) disclosure consents

    2. IRC 6103(e) material interest

    3. IRC 6103(k)(1) accepted offers-in-compromise

    4. IRC 6103(k)(2) amount of outstanding lien

    5. IRC 6103(k)(6) investigative disclosures

    6. IRC 6103(h)(1) Treasury employees

    7. IRC 6103(l)(4)(A) personnel action disclosures

    8. IRC 6013(l)(2) Department of Labor and Pension Benefit Guaranty Corporation

    9. Government Accountability Office

    10. Privacy Act requirements such as Privacy Act notices, Computer Matching Act compliance, and EPF maintenance

    11. Projects with State tax agencies

  7. Emphasis must be placed on delivery of those reviews identified in the GLD Program Letter. The local functions where the issues to be reviewed in the opinion of the Disclosure Manager and staff, are most prevalent, or where there is an indication of a problem should be assigned the next highest review priority.

  8. If circumstances exist that warrant a deviation from the planned areas of coverage, such deviation may be granted by obtaining the approval of the GLD Area Manager. The Area Manager must retain, with his/her copy of the plan, written documentation of why the deviation was requested and why it was granted.

  9. The review plan should be a flexible document, subject to amendment to accommodate other priorities identified during the year. The review plan should also establish a list of responsible parties, such as the:

    1. Disclosure Manager

    2. Disclosure Specialist

    3. Disclosure Assistant

    4. Functional Disclosure Coordinator

    5. Governmental Liaison

    6. Functional Reviewer

  10. The plan should require periodic reports on the results of the reviews done in each function. These periodic reports should include the following:

    1. Subject: Information about what is being reviewed.

      Note:

      Language similar to the following can be used:

      "A review of open case files was conducted on Revenue Agent Group [group number] on [date of review]."

    2. References: A brief discussion or summary establishing the authority for Disclosure to conduct the review or reference to the applicable IRM provision or program letter that requires these reviews. References to IRM 11.3.38 and the GLD Program Letter are acceptable.

    3. Background: A brief discussion about the purpose and intent of the review. Include comments regarding what or who was reviewed and the overall reasons why the review was conducted:

      Note:

      Language similar to the following can be used: "A review of Revenue Agent group [group number] was conducted to determine the level of understanding and compliance employees have with disclosure provisions. Information gathered from the review will be used to focus future awareness activities and to correct any weaknesses found as a result of this review."

    4. Method of Review: A discussion of what was reviewed and how, the scope and sample size of the review, and the methodology for the selection of cases for review. Include in this section of the report information about how the sample was selected and other important information about the choice of that sample or selected cases for review.

    5. Findings/Analysis: This should include an in-depth discussion of the results of the review, highlighting both the positives and the negatives of what was noted. Where improvement is needed or issues are found, Disclosure personnel must include these as a finding. Many times, checksheets are available specific to the function or disclosure issues likely to be encountered. Authors have a lot of latitude in how this part of the report is written, but it may be helpful to take each section of the checksheet and write a brief summary of whether or not any issues or findings were noted. There is no set format as long as adequate details pertaining to the results of the review are listed.

    6. Recommendations: Actions the function or group should take to address any findings noted. For every finding, there must be a recommendation. The recommendations should be something affirmative that management or IRS employees can control or accomplish with either a change in procedure, increased awareness or some other action.

    7. Conclusions: A discussion and calculation of the compliance rate (take the number of cases with errors divided by the number of cases reviewed, subtract this percentage from 100 to determine the overall compliance rate), whether the overall results were favorable or not, recommendations for any follow-up reviews or awareness activities and when, if known.

  11. Feedback should be provided to the manager of the group or function being reviewed. If disclosure problems persist as determined by any follow-up review, the appropriate next level supervisor should be informed.

  12. Because there is a need to analyze reports for significant trends in a respective division or function, copies of final reports for reviews of local functions are to be forwarded to Chief, Disclosure at the following address:

         Chief, Disclosure
         SE:S:CLD:GLD:D
         Room 2012/IR
         1111 Constitution Ave., N.W.
         Washington, DC 20224

  13. The staff of the Chief, Disclosure will conduct an analysis of significant trends for use in:

    1. Designing appropriate awareness products to address disclosure and Privacy Act weaknesses or issues noted.

    2. Drafting an overall executive summary report discussing the results of the review and planned actions to address disclosure issues noted to share with appropriate SB/SE management.

  14. If there are Headquarters directed reviews of other functions or areas reflected in the GLD Program Letter, for any given year, final reports reflecting these reviews are to be signed by the Director, GLD.

    1. Upon completion of the report, it should be routed to the Director, GLD, via the Area Manager and Chief, Disclosure.

    2. After concurrence and signature, the report will be submitted to the point of contact or responsible management official with a copy provided to the local Disclosure Manager who submitted the report.

11.3.38.4.3  (04-01-2006)
Governmental Liaison (GL) Program

  1. Liaison activities with state tax agencies are carried out by the local GL.

  2. Disclosure Managers ensure compliance with law and policy such as:

    1. IRC 6103(d)

    2. Policy Statement P-1-1, Mission of the IRS

    3. Policy Statement P-1-35, Agreements to exchange information with States entered into when in the interest of good tax administration

    4. Policy Statement P-6-14, FedState Relations

  3. The Disclosure Manager and/or GL have responsibility for:

    1. Negotiating and ensuring compliance (e.g. need and use determinations) with the basic agreement, all supporting agreements, and all memorandums of understanding

    2. Coordinating activities (based on local assignment for responsibility)

    3. Ensuring preparation of disclosure accountings

  4. The local GL is the focal point for the Governmental Liaison program.

  5. The Disclosure Manager is responsible for ensuring that disclosure standards are maintained in the basic agreement, implementing agreements, or any other type of agreement or memorandum of understanding that may exist between state tax agencies and the IRS. To carry out this responsibility, Disclosure Managers must:

    1. Consult with the GL and state tax agency officials regarding disclosure problems involved in proposed formal agreements on coordination of tax administration. Review the execution of such agreements as necessary

    2. Assist the GL in negotiations with state tax agency officials concerning the provisions of agreements that will supplement the basic agreement. Specify the nature, quantity, and mechanics for exchange of tax information, including tolerances and criteria for selection

    3. Conduct on-going need and use determinations prior to releasing or approving the release of tax information and ensure need and use documentation is maintained for each item of tax information to be disclosed, including all items pursuant to the agreement, MOU and electronic data exchange (See IRM 11.3.32)

  6. The GL program is maintained by the local Governmental Liaison. Each function has responsibility to recognize its role in the program and to carry out that role. Disclosure Managers are expected to assist the GLs to ensure that all disclosure provisions are followed.

  7. All exchanges of tax information fall into one of the following categories:

    1. Implementing agreements or memorandums of understanding

    2. Specific requests (not covered in a)

    3. Electronic data exchanges (not covered in a)

  8. Disclosure Managers and staff also support efforts by GLs in exploring opportunities for exchange of tax information with other federal agencies and provide advice related to various disclosure provisions related to these exchanges.

11.3.38.4.4  (04-01-2006)
Safeguard Review Program

  1. The purpose of the Safeguard review program is to ensure:

    1. Disclosure of tax returns and tax return information by the IRS to external agencies, their authorized agents, their authorized contractors, and IRS contractors is in accordance with statutory authority

    2. Tax information is used by these recipients only as authorized by the enabling legislation and/or implementing regulations

    3. Returns and return information are protected from unauthorized disclosure and inspection as specified in IRC 6103(p)(4) and supplemented by IRS’ Publication 1075, Tax Information Security Guidelines for Federal, State, and Local Agencies;

  2. Safeguards is responsible for all on-site safeguard reviews of:

    1. State Tax Agencies

    2. Child Support Agencies

    3. Public Assistance Agencies

  3. The Pre-award and required on-site reviews of IRS contractors is the responsibility of the Safeguards office with the Office of Independent Test, Validation and Verification conducting computer security assessments and the Office of Emergency Management and Physical Security conducting the physical security portion of these reviews.

  4. Disclosure Managers and staff assist Safeguards personnel with issues related to the interpretation and application of IRC 6103 and the Privacy Act as they relate to information shared with or disclosed by the various agencies.

11.3.38.5  (04-01-2006)
Training

  1. Disclosure Managers are responsible for providing employee training regarding disclosure and non-disclosure of information and Privacy Act responsibilities.

  2. To effectively carry out training responsibilities, Disclosure Managers should:

    1. Provide technical guidance and direction to all employees (includes providing new functional coordinators with the appropriate training course as soon as practicable)

    2. Ensure the adequacy, quality and effectiveness of disclosure-related training programs by assisting in development of local training materials and attending local training classes to address employees’ concerns and answer disclosure-related questions.

  3. See IRM 6.410, Learning and Education, for Disclosure orientation training, and IRM 11.3.14.9, Privacy Principles, for Privacy Act training.

11.3.38.6  (04-01-2006)
Reporting Unauthorized Accesses or Disclosures

  1. IRS employees are required to report suspected willful unauthorized inspections/disclosures of returns and return information and Privacy Act violations to the Treasury Inspector General for Tax Administration (TIGTA). Field employees should report these matters to the local TIGTA Special Agent. Washington, DC metro area employees should report to TIGTA’s main office. Non-willful unauthorized disclosures of tax or Privacy Act protected information are to be reported in accordance with IRM 11.3.13.38.6.1..

    Note:

    A willful act is one where there is a voluntary intentional violation of a known legal duty.

    Note:

    If any employee reports an unauthorized willful disclosure/inspection to a Disclosure Manager before reporting it to TIGTA, the Disclosure Manager will direct the employee to TIGTA, without delay.

  2. Suspected incidents of unauthorized access/inspection (UNAX) should be handled in accordance with current procedures.

  3. Reports of unauthorized disclosures received by TIGTA where it is apparent by the nature of the information that there is no willfulness involved or no prosecution or referral to management for adjudicative action is warranted, will generally be referred back to IRS for appropriate action.

  4. Disclosure Managers will provide feedback to the functions on violations reported to them as outlined in (3) above and IRM 11.3.38.6.1, by recommending whatever corrective action is deemed appropriate to prevent such disclosure violations from recurring. Corrective action may include, but is not limited to:

    1. Training

    2. Counseling (normally conducted by the appropriate manager)

    3. Implementing new procedures or revising existing ones

    4. Appropriate awareness actions to address the problem

    Note:

    Disclosure Managers should not comment upon whether or not any conduct or performance action should be initiated by the function.

  5. Documentation concerning unauthorized disclosures and related follow-up activities must be maintained by the Disclosure Manager in accordance with GLD’s approved record control schedule.

  6. Non-IRS agencies and their employees/contractors/agents subject to IRC 7213 or IRC 7213A should have internal procedures in place to substantially replicate the provisions of these IRM instructions. Any suspicion of a willful IRC 7213 or IRC 7213A violation must be reported to TIGTA.

    Note:

    See IRM 11.3.36 for a discussion of requirements for agencies subject to IRC 6103(p)(4) safeguards.

11.3.38.6.1  (09-21-2007)
Report of Inadvertent Improper Disclosures

  1. Inadvertent improper disclosures, while still unauthorized, are those disclosures where no willfulness of intent is involved. Examples of inadvertent disclosures include but are not limited to:

    1. Invalid/incomplete written/oral authorization

    2. Error in faxing

    3. Misrepresentation of identity or authority

    4. Established procedures inadequate to establish taxpayer’s identity

    5. Disclosure made as a result of erroneous interpretation of IRC §6103

    6. Improper disclosure to contractor

    Note:

    Mail sent to the address of record but opened by a third party is not an unauthorized disclosure.

  2. Employees must report inadvertent disclosures directly to their immediate supervisors who, in turn, are expected to bring these disclosures to the attention of their servicing disclosure office. Headquarters managers should direct the reports to the Director, GLD.

  3. All of the examples in (1) above require a Form 10848, Report of Inadvertent Unauthorized Disclosure of Tax or Privacy Act Information to be completed. The form is completed by the employee either discovering or making the disclosure and submitted to the employee’s manager. Part 1 of the Form is retained by the manager and the second page is forwarded to the servicing disclosure office. Form 10848 is available at the following intranet site and is PDF fillable online at: http://publish.no.irs.gov/FORMS/INTERNAL/PDF/65283F05.PDF

  4. No taxpayer or employee identifying information is needed by Disclosure. Only the details of the situation or incident and corrective actions are required. If Form 10848 is not available, a separate report containing the following items is acceptable:

    1. Entity information concerning who committed the inadvertent unauthorized disclosure

    2. Dates of the disclosure and when discovered

    3. Description of what was disclosed

    4. Explanation of what caused the disclosure

    5. Actions taken to prevent recurrence

    6. Identity of the person who prepared the report and the manager who reviewed it

      Note:

      Reports of loss or theft of government property including laptop computers are to be reported in accordance with the guidance issued by Modernization and Information Technology Services found at: http://www.csirc.web.irs.gov/about/contact.html. They are not to be reported to Disclosure using Form 10848.

  5. Inadvertent improper disclosures do not require any contact with or letters to taxpayers informing them of the incident where their tax or identity information was inadvertently disclosed. Such letters or contacts are not statutorily required and so should not be issued.

  6. Generally, employees commit inadvertent disclosure errors once (e.g., because of a misunderstanding of rules or procedures) and no further corrective action is necessary once the matter is discussed with the employee. Occasionally, errors are repeated by the same employee or are serious enough even in one incident to warrant corrective action. When managers believe additional corrective action is necessary, they should consult with Labor Relations staff to determine if conduct or performance actions is appropriate. The manager should still complete a Form 10848 and send Part II to the servicing disclosure office. Disclosure can advise the manager and Labor Relations on the technical aspects of the disclosure but not on the appropriateness of any conduct or performance action. Again, if the manager believes the unauthorized disclosure is willful or deliberate, they should report it to TIGTA instead of Disclosure and Labor Relations.

  7. Non-IRS agencies and their employees, contractors, and/or agents subject to IRC 7213 or 7213A should have internal procedures in place to substantially replicate the provisions of these IRM instructions concerning inadvertent disclosures. The Form 10848 or equivalent may be used for this purpose.

11.3.38.7  (04-01-2006)
Role of the Area Manager

  1. The GLD Area Manager, serves as the manager for the Disclosure Managers and Governmental Liaisons (GLs) in their respective areas.

  2. The Area Manager:

    1. Manages the Disclosure program in his/her area

    2. Assists the Director, GLD, in implementing the national Disclosure program

  3. To be effective, the Area Manager should:

    1. Provide necessary managerial assistance and support to DMs and GLs

    2. Assess the effectiveness of the Disclosure and GL programs through visitations

    3. Prepare procedures and instructions for local offices concerning Disclosure and GL programs

    4. Define and explain the importance of privacy as well as the part the Disclosure program and the local DM play in protecting the confidentiality of tax information and sensitive non-tax information, as appropriate

    5. Monitor disclosure office and GL compliance with Headquarters’ directives and guidelines and ensure that GLD priorities are followed

    6. Review and approve exchange agreements for conformity with IRC 6103(d) and the Privacy Act

    7. Determine which technical issues require Headquarters’ action; suggest new legislation, regulations and procedures to Headquarters as warranted

    8. Advise Headquarters of procedural problems which may extend beyond Area jurisdiction, detail efforts made to resolve them, and offer suggestions to prevent recurrence

    9. Provide input as required by Headquarters on the status of Disclosure and GL activities within the Area

    10. Coordinate, consolidate, and ensure that required reports are complete, timely, and accurate

  4. The Area Manager will utilize the Business Performance Review System to monitor performance indicators against the desired outcomes established for the Disclosure and GL programs.

11.3.38.8  (09-21-2007)
Disclosure Manager Supervisory Responsibilities

  1. In addition to program and case management responsibilities, Disclosure Managers also have supervisory (i.e., front line management) responsibilities for technical and clerical personnel. As such, they must perform the full range of tasks expected of all IRS supervisors.

  2. The supervisory responsibilities of the Disclosure Manager will include:

    1. Performing periodic casework and workload reviews to evaluate employee performance. The minimum number of reviews and other guidance is established by separate instructions to managers issued by the Chief, Disclosure

    2. Designating the specific duties and responsibilities of each member of the staff

    3. Addressing training needs for staff members

    4. Ensuring case and program assignments are consistent with staff grade level

    5. Assisting staff members in career development

    6. Establishing specific assignments for functional coordinators

    7. Conducting mandatory employee briefings

    8. Monitoring work in progress using available reports and observations to ensure staff members are following required procedural guidelines at all times

    9. Providing periodic reports to the Area Managers and/or Area Technical Advisors for use in monitoring program objectives.

11.3.38.9  (09-21-2007)
The Electronic Disclosure Information Management System (E-DIMS)

  1. E-DIMS is the nationwide information system for inventory control, casework management and standardized reporting for the national Disclosure program. It is a tool to help Disclosure Managers (DMs) balance program work, case work and management responsibilities. Key to making this a useful tool is to ensure users are making accurate and timely data entry. DMs must include comments in case reviews or in other observations about the accuracy and completeness of all required data entry and history notes.

  2. The HQ GLD Data Services Branch is responsible for the User Guide. The E-DIMS User Guide provides detailed information concerning the use of the application. Copies are available from the E-DIMS Help menu or by contacting one of the E-DIMS representatives listed on the Data Services web page at: http://sbse.web.irs.gov/CL2/GLD/resources/EDIMS/EDIMS.htm

11.3.38.10  (04-01-2006)
The Role of the Disclosure Specialist

  1. The specific duties of Disclosure Specialists are determined by their position descriptions. The assignments are technical and non-supervisory in nature.

  2. Specialists generally handle day-to-day technical issues (i.e., casework).

  3. Disclosure Specialists with sufficient experience may be assigned responsibility for aspects of program management as needed and act for the Disclosure Manager in his or her absence.

    Example:

    Coordinating and/or conducting awareness presentations; performing Quality/Privacy reviews.

11.3.38.11  (04-01-2006)
Role of the Disclosure Assistant

  1. The Disclosure Assistant contributes to implementation of the Disclosure/Privacy Program in his/her local Disclosure Office.

  2. The Disclosure Assistant performs a variety of duties in assisting in the administration of local disclosure policies, practices and procedures.

  3. These duties normally include processing the more routine type of FOIA, Privacy Act and IRC 6103 requests, as well as performing many of the administrative duties, such as preparing accountings for disclosure and certification of documents.

11.3.38.12  (04-01-2006)
Role of Functional Disclosure Coordinators

  1. Functional Disclosure Coordinators serve as liaisons to the Disclosure Manager and assist the Disclosure Manager, on an as-needed basis, in performing a variety of tasks.

  2. The functional knowledge that coordinators possess provides important help to the Disclosure Manager in analyzing problems and devising solutions.

  3. Functional Disclosure Coordinators perform or assist the Disclosure Manager with:

    1. Quality/privacy reviews

    2. Preparation of responses to simple disclosures requests

    3. Answers to routine disclosure questions from individuals within their functions

    4. Review of administrative or investigative case files responsive to FOIA requests

    5. IRC 6103(i)(1) clearance process

    6. Recommendations concerning the release or withholding of documents

    7. Awareness training and serving as the technical contact point within their functions

    8. Other assistance to the Disclosure Manager, as appropriate

  4. It is important that the contributions made to the local disclosure program by effective functional coordinators receive adequate recognition. It is recommended that the coordinator's manager be apprised of their accomplishments.

  5. Functional coordinators can and should be used in HQ. Their increased use reflects the philosophy that disclosure/privacy concerns are not solely within the purview of one function but that all employees and managers share the legal and ethical responsibility to preserve taxpayer and employee privacy as well as protect the confidentiality of tax and other sensitive information.

Exhibit 11.3.38-1  (04-01-2006)
Disclosure/Privacy Awareness Plans

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SUGGESTIONS FOR COMPLETING DISCLOSURE/PRIVACY AWARENESS PLANS:

  • Emphasis must be placed on those areas designated in the GLD Program Letter as pertaining to or assigned to the respective disclosure office

  • Other areas can be included with approval of the GLD Area Manager

Exhibit 11.3.38-2  (04-01-2006)
Quality/Privacy Reviews

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COMPLETION OF QUALITY/PRIVACY REVIEW PLAN:

  • Reviews of functions or divisions as required by the GLD Program Letter will have priority

  • Other reviews of discretionary areas are to be included only with approval of the GLD Area Manager


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