The Treasury Department's approach to administering the Privacy Act is the most decentralized of all those examined by the Commission. Each of the Department's eleven bureaus is directly responsible for its own implementation and compliance, with little or no supervision by anyone at the Department level. However, the Internal Revenue Service, a major Treasury bureau, has developed a highly structured administrative program. "Disclosure officers" in the 65 regional and district offices bear the main responsibility for day-to-day administration of the Act. Before the Act took effect, each region sent one or two representatives to IRS headquarters for two days of training in Privacy Act procedures. The regional representatives then gave similar training in their districts. All IRS employees who were not expected to be directly involved in administering the Act were briefed through a program of tape/slide presentations. In addition, all disclosure officers received two weeks of intensive training.54 The Service estimates that 35,000 man-hours were invested in implementation training even before the Act took effect.55
A compliance handbook has been prepared and disseminated throughout the Service. Compliance by IRS field units is audited by the Office of the Assistant Commissioner/Inspection, whose audits include an inspection of the accounting each unit keeps of its disclosures of information about individuals.