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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  (10-23-2009)
Purpose

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

11.3.38.1.1  (10-23-2009)
Background

  1. The confidence the public has in the ability of the Internal Revenue Service (IRS) to protect the confidentiality of tax information influences the public's willingness to opt into our voluntary tax system. A perception that the IRS is careless in preserving privacy rights can have serious compliance ramifications.

  2. Congress 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. The privacy of employee information is also important and employee information must only be released in accordance with the Privacy Act or other applicable laws.

  4. Disclosure Managers are responsible for implementing activities that promote privacy principles 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  (10-23-2009)
Objectives

  1. The primary objectives of Disclosure offices are as follows:

    1. Promoting the protection and confidentiality of tax information.

    2. Preserving the privacy rights of taxpayers and employees.

    3. Releasing all requested tax and other sensitive information as 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  (10-23-2009)
Organizational Structure and Placement

  1. The Disclosure Manager serves as the first line manager over a staff of employees who provide disclosure services to IRS employees in a specified geographical area.

  2. The Disclosure Manager reports directly to the Area Manager, Governmental Liaison and Disclosure (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  (10-23-2009)
Responsibilities of Disclosure Manager

  1. The Disclosure Manager is responsible for planning and maintaining a balanced program consistent with operational priorities established in the SB/SE GLD Strategic Plan and the Roles and Responsibilities document.

  2. Guidelines for the Disclosure program are often provided by Headquarters and the GLD Area Manager. However, field Disclosure Managers may implement local activities 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:

    • Case management

    • Program management

    Note:

    The case management responsibilities are described throughout various sections in 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.

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

  6. Disclosure Managers are responsible for the following:

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

    4. Ensuring that Disclosure work complies 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 Information Protection and Data Security (PIPDS), a Headquarters function that develops and implements privacy policy for the IRS. Since the PIPDS does not maintain a field operation, the Disclosure Manager, because of his/her expertise, may be called on to assist or advise in matters that impacts privacy policy for field operations.

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. 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  (10-23-2009)
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 the following:

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

    2. Reduced incidences of improper access (UNAX) 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. 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 using the Disclosure inventory management system. 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 supervision of Chief, Disclosure) may also participate in disclosure/privacy awareness activities.

11.3.38.4.2  (10-23-2009)
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. 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. The annual plan will incorporate Disclosure HQ priorities and where possible, reviews of local functions. 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.

    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.

  4. Quality/privacy reviews conducted by the functions are methods of measuring disclosure compliance. Disclosure Managers should periodically review the disclosure standards used by the functions for quality, accuracy, and timeliness to ensure that they properly address the appropriate 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.

  5. The following is a non-exhaustive list of suggested topics 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.

    • IRC §6103(c) disclosure consents

    • IRC §6103(e) material interest

    • IRC §6103(k)(1) accepted offers-in-compromise

    • IRC §6103(k)(2) amount of outstanding lien

    • IRC §6103(k)(6) investigative disclosures

    • IRC §6103(h)(1) Treasury employees

    • IRC §6103(l)(4)(A) personnel action disclosures

    • IRC §6013(l)(2) Department of Labor and Pension Benefit Guaranty Corporation

    • Government Accountability Office

    • Privacy Act of 1974 requirements such as Privacy Act notices, Computer Matching Act compliance, and EPF maintenance

    • Projects with State tax agencies

  6. Emphasis must be placed on delivery of those reviews identified in the GLD Program Letter or other Disclosure Headquarters directives. Where possible, quality reviews of local functions where there are indications of possible disclosure issues, should be completed.

  7. 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.

  8. 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:

    • Disclosure Manager

    • Disclosure Specialist

    • Disclosure Assistant

    • Functional Disclosure Coordinator

    • Governmental Liaison

    • Functional Reviewer

  9. 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 that 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, check sheets are available specific to the function or the 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 check sheet 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 errorless cases divided by the number of cases reviewed, and convert to a percentage to get 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.

  10. 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.

  11. 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

  12. 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.

  13. 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.

    Note:

    There may be special projects assigned by HQ Disclosure where HQ writes the report of the findings. In that event, the routing will not include an Area Manager.

11.3.38.4.3  (10-23-2009)
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:

    • IRC §6103(d)

    • Policy Statement P-1-1, Mission of the IRS

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

    • Policy Statement P-6-14, FedState Relations

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

    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, Disclosure to State and Local Governments).

  6. The GL program is administered 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:

    • Implementing agreements or memorandums of understanding

    • Specific requests (made outside of the Implementing Agreement or Memorandum of Understanding)

    • Electronic data exchanges (that can be referenced in Implementing Agreements or Memorandums of Understanding or specific requests)

  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  (10-23-2009)
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, and their authorized 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. The Office of Safeguards within the Communications, Liaison, and Disclosure function is responsible for all on-site safeguard reviews of:

    1. State Tax Agencies

    2. Child Support Agencies

    3. Public Assistance Agencies

    4. Other State and Federal Agencies receiving tax information

  3. The Pre-award reviews of IRS contractors is the responsibility of AWSS, Office of Physical Security and Emergency Preparedness. The required post-award on-site safeguard reviews are performed by AWSS, Real Estate and Facilities Management. If tax information is contained on computer systems controlled by the contractor, MITS, Office of Cybersecurity, conducts reviews of contractor compliance with computer security requirements.

  4. Disclosure Managers and staff assist the Office of Safeguards, AWSS and MITS Cybersecurity 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 and contractors.

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. The Disclosure Managers should use the following guidelines to carry out training responsibilities:

    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  (10-23-2009)
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, Freedom of Information Act.

    Note:

    A willful act is one where there is an 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. 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, Safeguard Review Program for a discussion of requirements for agencies subject to IRC §6103(p)(4) safeguards.

11.3.38.6.1  (10-23-2009)
Reporting Inadvertent Disclosures of Sensitive Information

  1. When sensitive information, including tax information and information protected by the Privacy Act, is disclosed in any way, it is required to be reported using procedures developed by the Computer Security Incident Response Center (CSIRC) office.

  2. Form 10848, Report of Unauthorized Inadvertent Disclosure of Tax or Privacy Act Information is obsolete and no longer used to report such incidents.

  3. The CSIRC incident reporting form is to be used to report inadvertent disclosures of sensitive information. It is designed to be used on line and can be accessed at the following: http://www.csirc.web.irs.gov/reporting/.

  4. Upon becoming aware of an inadvertent, unintentional disclosure, you are required to report the incident within one hour to the following:

    • Your immediate manager

    • CSIRC online or at (866) 216-4809

      Note:

      You will not contact TIGTA in these situations.

  5. 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 are appropriate. If the manager believes the unauthorized disclosure is willful or deliberate, they should report it to TIGTA instead of CSIRC.

  6. Incidences involving erroneous notice issuances are also reported differently. Employees who learn of erroneous notice issuances do not contact CSIRC, but the Notice Gatekeeper, who will contact CSIRC as necessary. See IRM 21.3.1.1.1, Taxpayer Contacts Resulting from Notice Issuance for more information.

  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.

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:

    • Manages the Disclosure program in his/her area

    • 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  (10-23-2009)
Automated Inventory Control System

  1. Disclosure uses an automated inventory management system for input, control, processing, and closing assigned case and program work. This is a helpful tool for Disclosure Managers to monitor all activities of their office. It is important that the data entries made are accurate and timely. DMs must include comments in case reviews or in other observations about the accuracy and completeness of all required data entry and case history notes.

  2. HQ GLD Data Services is responsible for the operations of the system.

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 the following:

    • Quality/privacy reviews

    • Preparation of responses to simple disclosures requests

    • Answers to routine disclosure questions from individuals within their functions

    • Review of administrative or investigative case files responsive to FOIA requests

    • IRC §6103(i)(1) clearance process

    • Recommendations concerning the release or withholding of documents

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

    • 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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