10.5.7 Use of Pseudonyms by IRS Employees

Manual Transmittal

October 05, 2018

Purpose

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

Material Changes

(1) IRM 10.5.7 has been updated to include relevant internal controls as they relate to the Pseudonym program as recommended by the Government Accountability Office (GAO) and as outlined in IRM 1.11.2, Internal Management Documents System, Internal Revenue Manual (IRM) Process, November 14, 2016 revision. These internal controls describe the program objectives and officials charged with program management and oversight and ensure:

  • Mission and program objectives are clearly delineated and key terms defined.

  • Program goals are established and performance is measured to assess the efficient and effective mission and objective accomplishment.

  • Program and resources are protected against waste, fraud, abuse, mismanagement and misappropriation.

  • Program operations are in conformance with applicable laws and regulations.

  • Reliable information is obtained and used for decision making and quality assurance.

(2) New internal controls are in 10.5.7.1 and 10.5.7.1.1 through 10.5.7.1.7.

(3) IRM 10.5.7.1, Introduction to the Use of Pseudonyms by IRS Employees, moved and renumbered to 10.5.7.2.

(4) IRM 10.5.7.1.6, Terms/Definitions/Acronyms. New table added to (9) listing commonly used acronyms and their definitions.

(5) IRM 10.5.7.3, Definition of Terms. Entire section moved to 10.5.7.1.6, Terms/Definitions/Acronyms. Subsequent subsections renumbered.

(6) IRM 10.5.7.4.3, Office of Incident Management & Employee Protection Responsibilities, moved to (2) in 10.5.7.1.3, Responsibilities.

(7) IRM 10.5.7.7, Employee Identification Requirements. Previously 10.5.7.8. Updated IRM reference; deleted the acronym APC and its’ definition; added the acronym PCSS and its’ definition.

(8) IRM 10.5.7.13, Pseudonym Holder’s Official Travel. Previously 10.5.7.14. Title of sub-section updated from Pseudonym Holder’s Official Travel to Pseudonym Holder’s Government Travel Card. Inserted new (1) with the definition of a Travel Card. In (2), updated "agency credit card" to "government Travel Card" and clarified (2) to state that pseudonym holders may apply for a Travel Card in their legal name or pseudonym name. Moved old (6) regarding the purchase of airline tickets up to (3). Added new (4) with instructions to pseudonym holders to not consent to the credit check if applying for a Travel Card in their pseudonym name; added new (4) (a) with instructions to pseudonym holders to notify the Pseudonym office once they have applied for and received their Travel Card; and added new (4) (b) to state that the Pseudonym office will notify CFO Credit Card Services to remove any restrictions on the Travel Card resulting from not consenting to the credit check. In (5), updated "credit card" to "Travel Card" . Inserted new (6) to add a reference to IRM 1.32.4.

(9) IRM 10.5.7.15, Mismatched Pseudonym Holder Names. Previously 10.5.7.16. Restructured first sentence in (1).

(10) Throughout, made editorial changes and updated text to improve clarity.

(11) Throughout, reviewed and updated links and citations, website addresses, legal references and IRM references as necessary.

Effect on Other Documents

IRM 10.5.7 dated November 29, 2016, 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

(10-05-2018)

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

Program Scope and Objectives

  1. Purpose: This Internal Revenue Manual (IRM) provides information, guidance, and procedures for all Service managers and employees on the process for requesting a pseudonym, rescinding a pseudonym and the use of the pseudonym after it is obtained.

  2. Audience: The provisions in this manual apply to all IRS employees who hold pseudonyms and their managers and all IRS employees who submit a new request for the use of a pseudonym and their managers.

  3. Policy Owner: The Office of Privacy, Governmental Liaison and Disclosure (PGLD) under the Office of the Deputy Commissioner for Operations Support is the policy owner for this IRM.

  4. Program Owner: The Office of Incident Management and Employee Protection (IM&OEP) under the Office of Privacy Policy and Compliance (PPC) in PGLD is the program office responsible for this IRM.

  5. Contact Information: To recommend changes or make any other suggestions to this IRM, email the *Pseudonym mailbox at pseudonym@irs.gov.

  6. Primary Stakeholders: Current and future IRS pseudonym holders and their managers.

  7. Program Goals: The IRS is committed to the personal safety of its employees. The IRS Pseudonym program provides the necessary framework and process to ensure the timely assignment (within 5-10 business days after receiving the request) of a pseudonym to IRS employees requesting one for the necessary protection to their personal safety and the prevention of harm or danger to themselves and their families.

Background

  1. Section 3706 of the IRS Restructuring and Reform Act of 1998 (RRA 98) from 26 USC 7804, dated July 22, 1998, provides that any employee of the Internal Revenue Service may use a pseudonym only if adequate justification for the use of a pseudonym is provided by the employee, including protection of personal safety; and such use is approved by the employee’s supervisor before the pseudonym is used. Verbatim text of Section 3706 of IRS RRA 98 is provided in Exhibit 10.5.7-1, Verbatim Text of Section 3706 (RRA98) from 26 USC 7804, dated July 22, 1998.

Authority

  1. This IRM has been developed in accordance with Section 3706 of IRS RRA 98.

Responsibilities

  1. IRS’ Privacy, Governmental Liaison and Disclosure’s Incident Management and Employee Protection (IM&OEP) Office is responsible for administering and managing agency program requirements for ensuring incidents involving the loss or theft of an IRS asset, or the loss, theft, or disclosure of PII (data loss incidents) are investigated, analyzed and resolved. IM&OEP is also responsible for administering and managing programs tracking potentially dangerous taxpayers and those taxpayers that should be approached with caution as well as managing and administering the IRS Pseudonym program. Specific responsibilities for IM&OEP, IRS employees, and managers as they relate to the IRS Pseudonym program are listed below.

  2. The Incident Management and Employee Protection Office is responsible for:

    1. Managing the IRS Pseudonym Program in support of protecting those employees who may, because of threats or potential threats to their personal safety, need to work under the protection of a pseudonym.

    2. Processing all requests for pseudonyms received by the manager of record within five to ten business days from receipt of the request.

    3. Maintaining a copy of the encrypted email documenting the approval of a request for a pseudonym.

    4. Managing and maintaining the official Pseudonym Master List (PML) and all other related files where pseudonym information will be stored.

    5. Ensuring that all information pertaining to pseudonym holders is maintained in a secure manner consistent with IRS security and privacy policy requirements.

    6. Updating HR Connect to add employee’s pseudonym information.

    7. Updating Outlook (email) and Discovery Directory to display the pseudonym and initiating the process to change the Smart ID to the pseudonym.

    8. Updating the Pseudonym Master List each month to ensure that the information is correct and up-to-date.

    9. Processing all requests to withdraw from the IRS pseudonym program received by an employee’s manager of record. See IRM 10.5.7.5, Withdrawing from the Pseudonym Program.

      Note:

      Visit the Pseudonym page at https://portal.ds.irsnet.gov/sites/vl003/lists/employeeprotection/pseudonyms.aspx in the Disclosure and Privacy Knowledge Base at https://portal.ds.irsnet.gov/sites/vl003/pages/default.aspx for additional information about the IRS Pseudonym program.

  3. IRS employees are responsible for:

    1. Submitting his or her request for a pseudonym to his or her immediate manager via encrypted email, or hard copy in a confidential envelope.

    2. Following all request requirements as outlined in IRM 10.5.7.4, Requesting a Pseudonym.

    3. Ensuring that the pseudonym is not used until notified that the request was approved by management or as a part of a resolution to the employee’s grievance and confirmation is received from the Office of IM&OEP that the pseudonym has been added to Outlook (email) and Discovery Directory.

    4. Following the procedures as outlined in IRM 10.5.7.4.2, Pseudonym use Disapproved if his/her initial pseudonym request is not approved by their immediate manager.

    5. Using the approved pseudonym in the performance of all official duties during his or her hours of work.

    6. Notifying his or her manager via either encrypted email, or hard copy in a confidential envelope, if they wish to withdraw from the pseudonym program. See IRM 10.5.7.5, Withdrawing from the IRS Pseudonym Program.

    7. Employees must not open OS GetServices Tickets to request pseudonyms.

  4. IRS Managers are responsible for:

    1. Reviewing requests for pseudonyms to ensure all request requirements as outlined in IRM 10.5.7.4, Requesting a Pseudonym, have been addressed by the submitting employee.

    2. Within three business days from receipt of the request, informing the employee of approval or disapproval of the request.

    3. If approved, forwarding the request using encrypted email to IM&OEP’s *Pseudonym mailbox at pseudonym@irs.gov to register the pseudonym and process the request.

    4. Instructing the employee not to begin using the pseudonym until advised by IM&OEP that the change from his or her legal name to a pseudonym has been made in Outlook (email) and Discovery Directory.

    5. Upon use of his or her pseudonym, promptly ensuring 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 any 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.

    6. Updating organizational listings of employees to show only the pseudonym of the employee.

    7. Following the procedures as outlined in IRM 10.5.7.4.2, Pseudonym use Disapproved, when not approving the employee’s initial request for a pseudonym.

    8. Upon receipt of a pseudonym holder’s request to withdraw from the program, sending an encrypted email to IM&OEP’s *Pseudonym mailbox at pseudonym@irs.gov stating that the employee no longer requires a pseudonym. See IRM 10.5.7.5, Withdrawing from the Pseudonym Program.

    9. Maintaining documentation of pseudonym approval in the Employee Performance File (EPF).

    10. Managers must not open OS GetServices Tickets to request pseudonyms.

Program Management

  1. Program Reports: Statistics are provided in all IM&OEP quarterly Operational Reviews reflecting the number of new pseudonym requests received and the time frame for completion; the number of withdraws from the program and the number of pseudonym holders that have left the service. All information is derived from the Pseudonym Master List maintained by IM&OEP as well as the Human Resources Reporting Center (HRRC) for verification of those current pseudonym holders who have left the service due to resignation, retirement or termination.

  2. Program Effectiveness: Program goals are pseudonym processing within 5-10 business days after receipt of request and are measured via the quarterly information tracked and reported in the IM&OEP Operational Reviews.

  3. Annual Review: An annual review of all Pseudonym policies and guidance included in this manual will be conducted and any recommended changes will be submitted as needed.

Program Controls

  1. IM&OEP maintains the centralized electronic listing of approved/registered pseudonym users known as the Pseudonym Master List (PML). Maintaining and storing the legal name and pseudonym of an employee is required to ensure it is an approved and registered pseudonym. When employees no longer need a pseudonym, change jobs, or leave the Service, their names are removed from the 'active' list and recorded as no longer in the pseudonym program. The listing contains the legal name, the chosen pseudonym, the employee's SEID and the date the pseudonym was processed. It also contains the employee's POD, job title, email address and business unit.

  2. Information from the listing is protected and access to the PML is not provided to anyone outside of the Pseudonym program manager and their back-up. Information from the PML is only shared with designated employees with a verified need to know as determined by the IM&OEP office. This need to know would include: HRRC employees who need the information to maintain records for FOIA requests; TIGTA agents for law enforcement purposes; and FMSS for identity verification before issuing new credentials in the pseudonym.

  3. The PML is included in the IRS system of records, General Personnel and Payroll Records, Treasury/IRS 36.003, and must be treated accordingly for disclosure purposes. As such, IM&OEP will complete the required Privacy & Civil Liberties Impact Assessment (PCLIA) for the Pseudonym Master List as well as a System of Records Notice (SORN), that addresses the PII records contained in the PML.

Terms/Definitions/Acronyms

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

  2. Pseudonym. A fictitious name.

  3. Protection of Personal Safety. 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

  4. Harassment. The use of words, gestures, or actions that tend to alarm, disturb, or abuse another person.

  5. Reporting to TIGTA. 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.

  6. Adequate Justification. 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 employee

    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

  7. 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.

  8. Documentation of Credible Evidence. 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 listed under Adequate Justification.

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

  9. Acronyms. The table below lists commonly used acronyms and their definitions.

    Acronym Definition
    RRA 98 IRS Restructuring and Reform Act of 1998
    PML Pseudonym Master List
    HRRC Human Resources Reporting Center
    IM&OEP Incident Management & Office of Employee Protection
    PC Pocket Commission
    PCSS Pocket Commission & SmartID Support team

Related Resources

  1. IRS Internal Revenue Manuals.

    1. IRM 10.2.6, Non-Enforcement Pocket Commissions. This IRM provides purpose, authorities, directives and responsibilities for non-enforcement Pocket Commissions (PC) to include guidance for employees authorized to carry a pocket commission needing to obtain a new pocket commission in their approved pseudonym.

  2. Mailboxes.

    1. Pseudonym Mailbox. All requests for new pseudonyms or requests to withdraw from the program should be sent via encrypted email to the *Pseudonym mailbox at pseudonym@irs.gov . Any questions regarding the pseudonym program should also be sent to *Pseudonym.

    2. SmartID mailbox. All questions regarding obtaining a new Smart ID and/or Pocket Commission in the new pseudonym should be sent to the SmartID mailbox at awss.icam.smartid@irs.gov.

  3. Forms.

    1. Form 13716, Request for Media and/or Access Card for IRS Employees. To be completed by the new pseudonym holder and presented at the assigned credentialing station when the employee re-enrolls with their new pseudonym to obtain a SmartID in their pseudonym.

    2. Form 13716-B, Non-enforcement Pocket Commission Qualification and Request. To be completed by the new pseudonym holder to obtain a new pocket commission in their pseudonym per the instructions found in IRM 10.2.6, Non-Enforcement Pocket Commissions.

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.

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.

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 IM&OEP 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 adequate justification as defined by the term, Adequate Justification, in IRM 10.5.7.1.6, Terms/Definitions/Acronyms, 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).

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 IM&OEP. The manager will forward the request using encrypted email to IM&OEP’s *Pseudonym mailbox at pseudonym@irs.gov. 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 IM&OEP 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.

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.

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 IM&OEP’s *Pseudonym mailbox at: pseudonym@irs.gov 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. IM&OEP 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 IM&OEP’s *Pseudonym mailbox at pseudonym@irs.gov.

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 10.2.6.9, Use of Pseudonyms on Pocket Commissions.

  2. Please note that IRM 10.2.6.9 (4) states that, "A PC issued in a registered pseudonym may not be used as a retirement memento, for an honorary presentation, or for similar purpose. A registered pseudonym PC holder may not be reissued a PC in their legal name for memento purposes. The PC must be recovered by the employee's manager and sent to the PCSS team for destruction." (PCSS = Pocket Commission & SmartID Support (PCSS) team).

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.

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, IM&OEP 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 the SmartID mailbox at awss.icam.smartid@irs.gov.

  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.

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.

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.

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.

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.

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.

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 IM&OEP 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 has been coded PDT (Potentially Dangerous Taxpayer) an armed escort must be requested per (3) of IRM 5.1.3.5.1, When to Request Armed Escort. If the taxpayer(s) involved have been coded CAU (Caution Upon Contact), follow the provisions in IRM 5.1.3.5.1(4).

Pseudonym Holder's Government Travel Card

  1. A Travel Card is a credit card used to pay for authorized official IRS travel and allowable travel related expenses. Each Travel Card reflects an individual account established in the Travel Cardholder's name. The term "individually billed" is synonymous with Travel Card, Credit Card, government issued Travel Card, and IBA.

  2. Pseudonym holders may apply for a government Travel Card in their legal name or pseudonym name.

  3. Employees are required to use their legal name when purchasing airline tickets with their government Travel Card.

  4. During the government Travel Card application process, if applying using their pseudonym name, employees must NOT CONSENT to the credit check to avoid any potential connection to their legal name via their personal credit report.

    1. Employees must send an email to the *Pseudonym Mailbox indicating that they have applied for and received their government Travel Card in their pseudonym name. Employees must provide the following information in the email: Pseudonym name; SEID; and date card issued.

    2. The Pseudonym office will then notify CFO Credit Card Services to remove any restrictions on the Travel Card that may result from not consenting to the credit check.

  5. The pseudonym Travel Card can be used for all official travel, including IRS approved funding for travel expenses of employees performing NTEU business. In such cases, pseudonym holders are still required to comply with the Government bank card provisions regarding appropriate use and timely payment of charges. 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.

  6. See IRM 1.32.4, Service-wide Financial Policies and Procedures, Travel Card Program, for more information on the use of the government travel card or contact Credit Card Services via OS GetServices for any questions regarding use of the card.

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.

Mismatched Pseudonym Holder Names

  1. To ensure, other than for pertinent personnel matters, pseudonym names are properly used by all IRS employees, employee name lists and distribution groups 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.

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.

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].