10.5.7  Use of Pseudonyms by IRS Employees

Manual Transmittal

July 29, 2015

Purpose

(1) This transmits revised IRM 10.5.7, Privacy and Information Protection, Use of Pseudonyms by IRS Employees.

Background

This IRM provides information, guidance, and procedures for all Service managers and employees on the use of pseudonyms by Internal Revenue Service (IRS) employees in compliance with Section 3706 of the IRS Restructuring and Reform Act of 1998 (RRA 98).

This IRM contains information from the Pseudonym Memorandum of Understanding (MOU) signed by the IRS and NTEU on April 10, 2013.

Material Changes

(1) IRM 10.5.7 has been updated to include information from the Pseudonym Memorandum of Understanding (MOU) signed by the IRS and NTEU on April 10, 2013.

(2) Signature - Updated Signature of Authorizing Official from Tracey L. Showman, Director, Office of Privacy and Information Protection to Frances W. Kleckley, Director, Office of Privacy Policy and Compliance.

(3) Throughout, replaced the Office of Privacy Compliance with the Office of Incident Management & Employee Protection.

(4) Made editorial changes and updated text to improve clarity and flow throughout the IRM.

(5) IRM 10.5.7.1 (2) - Reworded content for clarity and added statement regarding the Pseudonym MOU.

(6) IRM 10.5.7.2.1 - Changed title of subsection from "What is a Pseudonym?" to "Pseudonym" ; made no substantive changes.

(7) IRM 10.5.7.2.2 - Changed title of subsection from "What is Protection of Personal Safety?" to "Protection of Personal Safety" ; and re-worded (f); however, made no substantive changes.

(8) IRM 10.5.7.2.4 - Changed title of subsection from "What is Harassment?" to "Harassment" ; made no substantive changes.

(9) IRM 10.5.7.2.5 - Changed title of subsection from "What is Adequate Justification?" to "Adequate Justification" ; reorganized subsection; made no substantive changes.

(10) IRM 10.5.7.2.6 - Made editorial changes and inserted an IRM reference; however, made no substantive changes.

(11) IRM 10.5.7.4 - Changed title of subsection from "Procedures for Requesting a Pseudonym" to "Requesting a Pseudonym" ; reworded content for clarity and reorganized subsection; added recommendation that maiden names not be used as pseudonyms; added language regarding the choice of famous names, characters, or products as pseudonyms; deleted (c) and moved the contents to a Note stating that OS GetServices Tickets must not be opened to request pseudonyms; replaced the Office of Privacy Compliance with the Office of Incident Management & Employee Protection; added procedures for pseudonym requests from Field Operation Employees; and changed "drop file" to "Employee Performance File (EPF)" .

(12) IRM 10.5.7.4.1 - Changed title of subsection from "When the Manager Approves the Use of a Pseudonym" to "Pseudonym Use Approved" .

(13) IRM 10.5.7.4.1 (1) and (2) - Replaced the Office of Privacy Compliance with the Office of Incident Management & Employee Protection; added the acronym for SEID in the third bullet of (1); added a requirement to include the employee's date of birth within the email in the fourth bullet of (1); and added a requirement to include adequate justification in the fifth bullet of (1).

(14) IRM 10.5.7.4.1 (3) - Reworded content for clarity

(15) IRM 10.5.7.4.1 (4) - Added IRM reference for withdrawing from the Pseudonym program.

(16) IRM 10.5.7.4.2 - Changed title of subsection from "When the Manager Disapproves the Use of a Pseudonym" to "Pseudonym Use Disapproved" and reworded content for clarity.

(17) IRM 10.5.7.4.3 - Changed title of subsection from "Office of Privacy Compliance Responsibilities" to "Office of Incident Management & Employee Protection Responsibilities" .

(18) IRM 10.5.7.4.3 (1) - Replaced the "Office of Privacy Compliance" with the "Office of Incident Management & Employee Protection" and changed the time frame for processing pseudonym requests from 14 business days to five to ten business days from receipt of the request.

(19) IRM 10.5.7.4.3 (2) and (3) - Replaced the "Office of Privacy Compliance" with the "Office of Incident Management & Employee Protection" ; moved the last requirement in (3) to (4) and renumbered the following paragraphs.

(20) IRM 10.5.7.4.3 (5), (6), and (7) - Moved prior (4) regarding the Pseudonym Master List to (6); inserted a new (5) to address updating Outlook and Discovery Directory to display the pseudonym by the Office of Incident Management & Employee Protection; and in (7) replaced the "Office of Privacy, Information Protection and Data Security" with the "Office of Privacy, Governmental Liaison and Disclosure (PGLD), Incident Management & Employee Protection" and embedded the link to the Pseudonym website.

(21) IRM 10.5.7.5 - Changed title of subsection from "Procedures for Withdrawal or Removal from the Pseudonym Program" to "Withdrawing from the Pseudonym Program" .

(22) IRM 10.5.7.5 (1) (a) - Added language stating that an employee with an approved pseudonym may withdraw from the program at any time.

(23) IRM 10.5.7.5 (1) (b), (c) and Note - Replaced the "Office of Privacy Compliance" with the "Office of Incident Management & Employee Protection" and added procedures in (c) for changing an employee's pseudonym back to the employee's legal name on Outlook and Discovery Directory and initiating the process of changing the Smart ID back to the legal name.

(24) IRM 10.5.7.6 - Removed "who are" from the title of this subsection; in (1), reworded content for clarity, updated the IRM reference from IRM 10.2.6.9 to IRM 10.2.6.11 and corrected the link; and in (2) updated the IRM reference from IRM 10.2.6.11 (5) to IRM 10.2.6.11 (4).

(25) IRM 10.5.7.7 - Changed title of subsection from "When to Use Unique Identifying Number" to "Employee Identification Requirements" ; deleted (4) regarding the Legacy ID Card and renumbered the following paragraphs; and replaced "unique identifying" with Smart ID Card in renumbered (5).

(26) IRM 10.5.7.7.1 - New subsection added, "Issuance of HSPD-12 Smart IDs to Employees with Pseudonyms" , to include procedures for giving a new Smart ID Card (HSPD-12) to employees who have a request for a pseudonym approved in the approved pseudonym name and procedures for the interim period between approval of the pseudonym and issuance of the HSPD-12 Smart ID Card.

(27) IRM 10.5.7.10 (1) - Inserted "business" to clarify that the approved pseudonym must be used with all internal and external business contacts.

(28) IRM 10.5.7.10 (6) - Inserted new (6) stating that managers must inform the local NTEU Chapter President of a bargaining Unit employee's pseudonym.

(29) IRM 10.5.7.12 (2) - Inserted new (2) stating that a pseudonym holder will be relieved from interacting with or performing work that involves a taxpayer identified as posing a threat of compromise to the legal identity of the pseudonym holder.

(30) IRM 10.5.7.12.1 - New subsection added, "Safety for Employees with Pseudonyms" , to include procedures regarding taxpayers identified as posing a threat of compromise to the legal identity of an employee.

(31) IRM 10.5.7.13 (2) - Added to the end of (2): If the IRS does not approve funding for travel expenses of employees performing NTEU business, the Travel Card cannot be used. Example: If Union officials travel using Union funds rather than government funds, the government Travel Card cannot be used.

Effect on Other Documents

IRM 10.5.7, Privacy and Information Protection, Use of Pseudonyms by IRS Employees, dated November 19, 2010, is superseded.

Audience

All IRS employees who hold pseudonyms and employees who submit a new request for the use of a pseudonym, and their managers.

Effective Date

(07-29-2015)

Frances W. Kleckley
Director, Privacy Policy and Compliance
Privacy, Governmental Liaison and Disclosure

10.5.7.1  (07-29-2015)
Introduction to the Use of Pseudonyms by IRS Employees

  1. The IRS is committed to the personal safety of its employees. This IRM explains the steps needed to acquire a pseudonym to ensure IRS employees have the necessary protection to their personal safety and the prevention of harm or danger to themselves and their families.

  2. This IRM provides information, guidance, and procedures for all Service managers and employees on the use of pseudonyms by IRS employees in compliance with Section 3706 of the IRS Restructuring and Reform Act of 1998 (RRA 98) and contains information from the Pseudonym Memorandum of Understanding (MOU) signed by the IRS and NTEU on April 10, 2013.

  3. Section 3706 of RRA 98 authorizes the use of pseudonyms by IRS employees. Listed below are some of the guidelines, requirements and conditions of having a pseudonym:

    1. Employees who used pseudonyms before the enactment of RRA 98, Section 3706 were "grandfathered" in under the statute.

    2. Section 3706 authorizes the use of pseudonyms by IRS employees only if adequate justification for the use is provided by the employee and its use is approved by the employee's manager.

    3. Prior to RRA 98 Section 3706, the use of pseudonyms by IRS employees was permitted if the employee believed he or she could be identified by his or her last name so as to warrant the use of a pseudonym. Further, no managerial approval was required. It was only required that the pseudonym be registered with the employee's manager.

    4. Section 3706 of RRA 98 is meant to eliminate the taxpayer perception that IRS employees avoid accountability for their actions through the use of pseudonyms, while still protecting an employee's right to use pseudonyms in appropriate circumstances.

    5. The employee's manager must approve use of the pseudonym prior to its use. Requests to use pseudonyms that do not provide adequate justification will be denied on that basis.

    6. See Exhibit 10.5.7-1, Verbatim Text of Section 3706 (RRA 98) from 26 USC 7804, dated July 22, 1998, for the text of Section 3706 (RRA 98) from 26 USC 7804.

10.5.7.2  (11-19-2010)
Definitions of Terms

  1. This subsection contains the definition of terms as used in the context of Section 3706 of RRA 98.

10.5.7.2.1  (11-19-2010)
Pseudonym

  1. A Pseudonym is a fictitious name.

10.5.7.2.2  (11-19-2010)
Protection of Personal Safety

  1. Protection of personal safety is keeping one’s self or others from harm or danger. Reasons for concern for personal safety include:

    1. Verbal and written threats of bodily harm or injury from a taxpayer or his or her representative directly involved in a case under review

    2. Actual bodily harm or injury from a taxpayer or his or her representative

    3. Harassment

    4. Taxpayer or his or her representative contacts an employee or employee's family member at his or her home without purpose of legitimate communication

    5. Evidence of taxpayer or representative aggression towards any government employee

    6. Threatening or aggressive acts by a taxpayer or his or her representative towards any government employee

10.5.7.2.3  (11-19-2010)
Reporting to TIGTA

  1. Employees have a responsibility to refer to TIGTA all assaults or threats to themselves or members of his or her family by a taxpayer or the taxpayer's representative.

10.5.7.2.4  (11-19-2010)
Harassment

  1. Harassment is the use of words, gestures, or actions that tend to alarm, disturb, or abuse another person.

10.5.7.2.5  (11-19-2010)
Adequate Justification

  1. Adequate justification is defined as credible evidence that establishes that a taxpayer or his or her representative is engaged in a physically, financially, or emotionally threatening activity, including but not limited to:

    1. Committing a battery against the employee, including unwanted touching

    2. Intimidating or attempting to intimidate the employee, such as with a show of weapons

    3. Uttering statements or specific threats of bodily harm directed to the employee

    4. Assaulting the employee

    5. Making statements threatening financial harm to the employe

    6. Harassing the employee

    7. Contacting an employee at his or her home

    8. Committing the acts set forth above against members of the employee’s family

    9. Committing the acts set forth above against another employee and the requesting employee has been assigned a case involving the same taxpayer

  2. Adequate justification is also defined as situations in which an employee’s job or place of duty exposes him or her to an increased risk to personal safety or that of his or her family. This increased risk may be due to, but not limited to, any of the following:

    1. A locator service shows the taxpayer, whose case the employee has been assigned, has a violent criminal history that would suggest a heightened risk of harassment toward an employee.

    2. The employee is expected to encounter taxpayers or representatives who are active members of groups that advocate violence against IRS or other federal employees.

    3. The employee is expected to encounter taxpayers who have been reported to have engaged in activities that physically, financially, or emotionally threaten or harm any other federal, state, county, or local government employee.

10.5.7.2.6  (11-19-2010)
Documentation of Credible Evidence

  1. Documentation of credible evidence includes, but is not limited to, the examples listed below:

    1. A signed statement by an employee, family member(s) or witness, or a letter signed by the taxpayer or his or her representative which demonstrates any of the criteria in IRM 10.5.7.2.5, Adequate Justification

    2. A document from a financial institution showing that a taxpayer has tried to place liens on an employee's assets

10.5.7.3  (11-19-2010)
Protecting Taxpayer-Specific Information Designated as IRC 6103 Material

  1. Any taxpayer-specific information submitted to justify the request for a pseudonym remains the return information of the taxpayer and must be protected under the provisions of Internal Revenue Code (IRC) section 6103. Any return information included with the application must be specifically designated as IRC 6103 material.

10.5.7.4  (07-29-2015)
Requesting a Pseudonym

  1. The procedures in this section must be used by employees to request a pseudonym and by managers to approve the use of pseudonyms by IRS employees.

  2. An employee must submit his or her request for a pseudonym to his or her immediate manager via encrypted email or hard copy in a confidential envelope. Employee requests must provide adequate justification for the use of a pseudonym related to the protection of personal safety.

  3. An employee request for the use of a pseudonym must include the pseudonym that he or she chooses to use. Use the following guidance when choosing a pseudonym:

    1. Choose a common surname (last name). It is recommended that maiden names not be used as pseudonyms.

    2. In rare cases, where the legal first name is unique to the point of compromising the employee's identity, a first name may also be chosen.

    3. Pseudonym initials can be consistent with real name initials

    4. Choose a name with which the employee is comfortable and which may be easily remembered.

    5. Do not choose the name of someone famous, a character, or a product.

    Note:

    Employees and managers must not open OS GetServices Tickets to request pseudonyms.

  4. Employees requesting the use of a pseudonym will not be able to utilize the pseudonym until notified that the request was approved by management or as a part of a resolution to the employee’s grievance. The employee must also wait until confirmation is received from the Office of Incident Management & Employee Protection that the pseudonym has been added to Outlook (email) and Discovery Directory.

  5. An employee who receives an approved pseudonym must use it in the performance of all official duties during his or her hours of work. If a pseudonym is compromised, the employee can request a replacement pseudonym without need for establishing adequate justification, as approval was previously given by the appropriate manager.

  6. Field Operation Employees. A request for a pseudonym made by any employee in Field Operations who has regular face-to-face contact with taxpayers shall normally be presumed to have satisfied the adequate justification as defined in IRM 10.5.7.2.5, Adequate Justification, when those employees have personal safety concerns and one of the following applies:

    1. The field employee has been assigned cases in high risk geographic areas, but not limited to Potentially Dangerous Taxpayers (PDTs) and Caution Upon Contact (CAUs), (e.g., Revenue Officers in remote areas with limited cell phone access, field calls to correctional facilities, and historically high crime areas).

    2. The field employee perceives that his or her safety or the safety of his or her family is at risk.

    3. The field employee is assigned to a case or is assisting an employee that is assigned a case where either the history of the case indicates a safety concern or the taxpayer(s) involved have been coded either PDT (Potentially Dangerous Taxpayer) or CAU (Caution Upon Contact).

  7. Documentation of pseudonym approval will be maintained in the Employee Performance File (EPF).

10.5.7.4.1  (07-29-2015)
Pseudonym Use Approved

  1. If the manager approves the employee's request for the use of a pseudonym, the manager must register the pseudonym with the Office of Incident Management & Employee Protection. The manager will forward the request using encrypted email to the Office of Incident Management & Employee Protection at *Pseudonym. The manager must include the following information within the email:

    • Legal name of the employee

    • Chosen pseudonym of the employee

    • Employee's SEID (Standard Employee Identifier)

    • Employee's Date of Birth (Required for new Smart ID Card Sponsorship)

    • Adequate justification

  2. Within three business days from receipt of the request, the manager will inform the employee that the pseudonym request is approved with instructions that the employee must not begin using the pseudonym until advised by the Office of Incident Management & Employee Protection that the change from his or her legal name to a pseudonym has been made within Outlook (email) and Discovery Directory.

  3. Once an employee begins using his or her pseudonym, the employee's manager will promptly take steps to ensure that the employee’s co-workers (i.e., employees that work in the same office building (excluding campuses), work unit, or work stream, as appropriate) and the NTEU Chapter President are notified of the Bargaining Unit employee’s pseudonym so that the employee is not addressed or referred to by his or her legal name revealing his or her identity to taxpayers. Organizational listings of employees must also be updated to show only the pseudonym.

  4. A pseudonym stays with an employee for the duration of his or her IRS career, unless the employee determines he or she no longer requires one. See IRM 10.5.7.5, Withdrawing from the Pseudonym Program, for instructions on how to withdraw from the pseudonym program.

10.5.7.4.2  (07-29-2015)
Pseudonym Use Disapproved

  1. If the manager disapproves the employee's request for the use of a pseudonym, within three business days from receipt of the request, the manager must return the request to the employee for additional justification. The manager must provide, in writing, the reason(s) for disapproval. The manager must also advise the employee, in writing, that he or she has the right, within five business days, excluding absences from work, to provide additional justification or information in support of his or her request. This can be done via encrypted email or hard copy in a confidential envelope.

  2. The employee has five business days from receipt of the disapproval, excluding absences from work, to provide additional written justification or information to his or her manager in support of his or her request for the use of a pseudonym.

  3. Upon receipt of the additional justification, the manager has three business days to review the request.

  4. If the manager approves the second request , he or she will follow the guidance provided in IRM 10.5.7.4.1, Pseudonym Use Approved, (1), (2), and (3).

  5. If the manager disapproves the request a second time, he or she will return the request to the employee, and provide, in writing, the reason(s) for disapproval. The manager will provide the name and contact information for the next level manager and advise the employee that they have the option, within three business days, excluding absences from work, to appeal the disapproval and to elevate his or her request to the next level of management.

  6. The employee has three business days, excluding absences from work, to appeal the disapproval to the appropriate next level manager.

  7. If the employee appeals the disapproval, the next level manager has three business days to review the request and approve or disapprove it. If disapproved at this level, the employee may file a grievance under the terms of Article 41 of the National Agreement for bargaining unit employees, or utilize agency grievance procedures for non-bargaining unit employees.

10.5.7.4.3  (07-29-2015)
Office of Incident Management & Employee Protection Responsibilities

  1. The Office of Incident Management & Employee Protection will process all requests for pseudonyms received by the manager of record within five to ten business days from receipt of the request.

  2. The Office of Incident Management & Employee Protection will maintain a copy of the encrypted email documenting the approval of a request for a pseudonym.

  3. The Office of Incident Management & Employee Protection will be responsible for managing and maintaining the official Pseudonym Master List and all other related files where pseudonym information will be stored.

  4. The Office of Incident Management & Employee Protection will ensure that all information pertaining to pseudonym holders is maintained in a secure manner consistent with IRS security and privacy policy requirements.

  5. The Office of Incident Management & Employee Protection will update Outlook (email) and Discovery Directory to display the pseudonym and initiate the process to change the Smart ID to the pseudonym.

  6. The Office of Incident Management & Employee Protection will update the Pseudonym Master List each month to ensure that the information is correct.

    Note:

    Visit the Office of Privacy, Governmental Liaison and Disclosure (PGLD), Incident Management & Employee Protection Pseudonym websiteon IRWeb at http://irweb.irs.gov/AboutIRS/bu/pipds/pip/itim/pseudonym/default.aspx for up-to-date information about the IRS Pseudonym program.

10.5.7.5  (07-29-2015)
Withdrawing from the Pseudonym Program

  1. The following procedures must be used by IRS employees to withdraw from the Pseudonym program:

    1. An employee with an approved pseudonym may withdraw from the program at any time. When an employee no longer desires a pseudonym, the employee must notify his or her manager via either encrypted email or hard copy in a confidential envelope.

    2. If the manager receives such notification, or when the pseudonym holder separates from the IRS, the manager must send an encrypted email to the Office of Incident Management & Employee Protection at: *Pseudonym stating that the employee no longer requires a pseudonym. The manager must include the employee's legal name, the employee's assigned pseudonym, the employee's SEID, and the reason for withdrawal from the program.

    3. The Office of Incident Management & Employee Protection will take the necessary steps to remove the employee's pseudonym records from the Pseudonym Master List; change the pseudonym back to the employee's legal name on Outlook (email) and Discovery Directory; and initiate the process of changing the Smart ID back to the legal name.

    Note:

    Employees must not open OS GetServices Tickets to withdraw from the pseudonym program. An employee must submit his or her request for withdrawal through his or her manager to the Office of Incident Management & Employee Protection at *Pseudonym.

10.5.7.6  (07-29-2015)
Pseudonym Guidance for Employees Authorized to Carry a Pocket Commission

  1. Employees authorized to carry a pocket commission will be provided with a pocket commission in the employee's approved pseudonym per the instructions found in .IRM 10.2.6.11, Use of Pseudonyms on Non-Enforcement Pocket Commissions.

  2. Please note that IRM 10.2.6.11 (4) states that, "A non-enforcement pocket commission issued in a registered pseudonym may not be used as a retirement memento, for an honorary presentation, or for similar purpose. The non-enforcement pocket commission must be recovered by the employee's manager and sent to the APC for destruction." (APC = Area Processing Center).

10.5.7.7  (07-29-2015)
Employee Identification Requirements

  1. RRA 98 Section 3705(a) provides identification requirements for all IRS employees (including employees with a pseudonym) working tax related matters.

  2. IRS employees (including pseudonym holders) are required to give their name and unique identification number (badge number), during taxpayer telephone, face to face, and written contact. In addition, a telephone number is required on all taxpayer correspondence. This will provide taxpayers with enough information to identify an IRS employee who may have previously assisted with tax related matters.

  3. The term "ID Card Number" refers to an employee's badge number only. It must not be construed to be the employee's enforcement shield or pocket commission number.

  4. On manually generated and handwritten correspondence, employees with an approved pseudonym must use their pseudonym name and generated Integrated Data Retrieval System (IDRS) or other unique letter system number. If an IDRS/unique letter system number is not generated, use of an employee's unique identifying number is required.

  5. While reviewing taxpayer correspondence and observing employee telephone or in-person contacts with taxpayers or taxpayers' representatives, managers must ensure that the employee name (approved pseudonym) and generated IDRS/unique letter system number, or Smart ID Card number, are properly used.

  6. When attempting to locate a specific employee at the insistence of the taxpayer or the taxpayer's representative, managers must ensure that only the approved pseudonym used by the Service employee is disclosed.

10.5.7.7.1  (07-29-2015)
Issuance of HSPD-12 Smart IDs to Employees with Pseudonyms

  1. Employees who have a request for a pseudonym approved will be given a new Smart ID Card (HSPD-12) in the approved pseudonym name. After the pseudonym is processed, the Office of Incident Management and Employee Protection will initiate the process for the Smart ID Card and provide the pseudonym employee’s manager information to obtain the new card. The Smart ID Card will be provided between 7 to 14 business days after the pseudonym employee’s manager submits the Form 13716, Request for Media and/or Access Card for IRS Employees, to the credentialing station and the employee re-enrolls with the pseudonym. Questions regarding Pseudonym Smart ID’s can be sent to *IRS HSPD-12 ICAM.

  2. At the employee's request, during the interim period between approval of the pseudonym and issuance of an HSPD-12 Smart ID Card and other IRS credentials, the Employer shall use its discretion pursuant to the Pseudonym MOU and this IRM to ensure that the employee is relieved from interacting with or performing work that involves a taxpayer identified as posing a threat of compromise to the legal identity of the pseudonym holder or interacting with the taxpayer(s) identified as posing the threat if that interaction requires the employee to use his or her name or produce a form of identification that contains his or her name.

10.5.7.8  (11-19-2010)
IRS Systems of Records Notice That Pertain to the Use of Pseudonym Name Lists

  1. Pseudonym lists are included in the IRS system of records, General Personnel and Payroll Records, Treasury/IRS 36.003, and must be treated accordingly for disclosure purposes.

10.5.7.9  (11-19-2010)
Pseudonym Holders, the Courts and Legal Matters

  1. Sworn documents and/or any other document filed with any court, including but not limited to affidavits used in connection with enforcing summonses and obtaining writs of entry, may only be signed with the approved pseudonym if the document states that it is signed using a pseudonym. Absent such a statement, the document must be signed using the declarant's legal name and should be filed with the court as a sealed document.

  2. Employees testifying in court must use their legal name unless, prior to giving testimony, the court has been informed and consented to the employee's use of the approved pseudonym.

  3. The signing of sworn documents or any other document filed with any court and the testimonial use of pseudonyms will require close coordination with the appropriate Chief Counsel office.

10.5.7.10  (07-29-2015)
Sensitive Nature of Pseudonyms

  1. Employees who use an approved pseudonym must use it with all internal and external business contacts, and will not be permitted to change back and forth between his or her pseudonym and legal name.

  2. Once the employee begins using the approved pseudonym, the manager must ensure that the employee's co-workers and associates are informed of the pseudonym, and explain that all employees must use the pseudonym when speaking of or to the employee.

  3. Managers of pseudonym holders must ensure that office documents including team listings, organization charts, and telephone directories are updated to reflect each employee's pseudonym.

  4. Managers and employees who work with a pseudonym holder must never reveal the legal name of the pseudonym holder to anyone internally or externally.

  5. Managers and employees who work with a pseudonym holder must introduce the pseudonym holder by the pseudonym name, not his or her legal name, in all situations.

  6. Managers must inform the local NTEU Chapter President of a Bargaining Unit employee’s pseudonym.

10.5.7.11  (11-19-2010)
Effects of Pseudonym Requirements on Other IRMs

  1. IRMs for Services and Enforcement and Operations Support that may impact pseudonym holders must be updated to comply with the provisions of RRA 98, Section 3706, and the provisions of this IRM.

10.5.7.12  (07-29-2015)
Assignment of Work to Pseudonym Holders

  1. Casework, and all other work, that could compromise the legal identity of a pseudonym holder, will not be assigned to the pseudonym holder. For example, a customer service representative, revenue agent or other employee who is a pseudonym holder, would not be assigned a case in which the taxpayer was already aware of the employee's legal name due to a previous case.

  2. A pseudonym holder will be relieved from interacting with, or performing work that involves, the taxpayer identified as posing a threat of compromise.

10.5.7.12.1  (07-29-2015)
Safety for Employees with Pseudonyms

  1. While a manager is considering an employee’s request for a pseudonym, the manager shall use his or her discretion in accordance with IRM 10.5.7.12, Assignment of Work to Pseudonym Holders, to ensure that the employee is relieved from performing work related to the taxpayer(s) posing the threat of compromise or interacting with the taxpayer(s) identified as posing the threat of compromise.

  2. During the period of time after an employee’s request for a pseudonym is approved, but prior to the Office of Incident Management & Employee Protection registering the pseudonym and completing changes to Outlook (email) and Discovery Directory, at the employee's request and management's discretion, the employee may be relieved from interacting with or performing work that involves the taxpayer identified as posing a threat of compromise.

  3. At management’s discretion, if a field employee believes that his or her pseudonym identity would be compromised within a particular community or geographic area (e.g. because his or her identity is known in this area), and his or her safety could be jeopardized, the employee may request that he or she not be assigned cases/taxpayer contact in that identified area.

  4. At the employee’s request and management’s discretion, management shall assign an assisting field employee to accompany a pseudonym employee if he or she is assigned a case in an area identified by the employee, as one in which the employee believes that his or her pseudonym identity would be compromised or where the history of the case indicates a safety concern.

  5. All Business Operating and Functional Divisions with employees whose duties require them to have contact with taxpayers should refer to IRM 25.4.1, Employee Protection, Potentially Dangerous Taxpayer, for further guidance. For field contacts, if the taxpayer(s) involved have been coded PDT (Potentially Dangerous Taxpayer) an armed escort should be requested per IRM 5.1.3.5.1(3), Safety, Security, and Control. If the taxpayer(s) involved have been coded CAU (Caution Upon Contact), follow the provisions in IRM 5.1.3.5.1(4).

10.5.7.13  (07-29-2015)
Pseudonym Holder's Official Travel

  1. Pseudonym employees are allowed to acquire an agency credit card in the pseudonym name.

  2. The pseudonym credit card can be used for all official travel, including IRS approved funding for travel expenses of employees performing NTEU business. In such cases, pseudonym employees are still required to comply with the Government bank card provisions regarding timely payments on the credit card. If the IRS does not approve funding for travel expenses of employees performing NTEU business, the Travel Card cannot be used. Example: If Union officials travel using Union funds rather than government funds, the government Travel Card cannot be used.

  3. Employees are required to use their legal name when purchasing airline tickets.

10.5.7.14  (11-19-2010)
Communications With and About Pseudonym Holders

  1. Just as pseudonym employees must use their pseudonym for all official purposes, all agency employees and managers must correspond and converse with, or about, pseudonym employees using only the employee's pseudonym.

  2. The only exceptions are pertinent personnel matters (e.g., payroll). For example, employee lists, including email distribution lists, to, or about, pseudonym employees must include pseudonyms rather than employee legal names. Otherwise, pseudonym employees' legal identities could ultimately be compromised.

10.5.7.15  (11-19-2010)
Mismatched Pseudonym Holder Names

  1. To ensure pseudonym names are properly used by all IRS employees, other than for pertinent personnel matters, employee name lists and distribution lists must be acquired from Discovery Directory only. Information acquired from personnel systems such as HR Connect, SETR/TAPS, and TIMIS, contain legal names and the use of these personnel systems could compromise the identity of a pseudonym holder.

10.5.7.16  (11-19-2010)
Protecting the Pseudonym Holder's Legal Identity

  1. Any written correspondence including a pseudonym holder's pseudonym and legal name must be protected. Email including such information must be encrypted.

Exhibit 10.5.7-1 
Verbatim Text of Section 3706 (RRA 98) from 26 USC 7804, dated July 22, 1998

USE OF PSEUDONYMS BY INTERNAL REVENUE SERVICE EMPLOYEES

Public Law 105-206, Title III, Sec. 3706, July 22, 1998, 112 Stat. 778, provided that:

  1. In General. - Any employee of the Internal Revenue Service may use a pseudonym only if -

    1. adequate justification for the use of a pseudonym is provided by the employee, including protection of personal safety; and

    2. such use is approved by the employee's supervisor before the pseudonym is used.

  2. Effective Date. - Subsection (a) shall apply to requests made after the date of the enactment of this Act [July 22, 1998].


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