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Privacy for Everyone! New FAR Rule Imposes Mandatory Training Requirements for Employees Handling PII


After years of consideration, DoD, GSA, and NASA have published a final rule requiring contractor employees who handle personally identifiable information (PII) or work with a system of records to complete initial and annual privacy training that addresses specified elements, including the Privacy Act, working with PII, and the contractor’s incident response plan. The final rule – effective January 19, 2017, and applicable to all contracts including those for commercial items and those below the Simplified Acquisition Threshold – also requires contractors to identify each covered employee, maintain records indicating that its employees have completed the requisite training, and to provide these records to contracting officers upon request.

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Gail D. Zirkelbach
Partner – Los Angeles
Phone: +1 213.443.5549

Peter Eyre
Partner – Washington, D.C.
Phone: +1 202.624.2807

Evan D. Wolff
Partner – Washington, D.C.
Phone: +1 202.624.2615

Maida Oringher Lerner
Senior Counsel – Washington, D.C.
Phone: +1 202.624.2596

Kate M. Growley, CIPP/G, CIPP/US
Partner – Washington, D.C.
Phone: +1 202.624.2698

Nkechi Kanu
Counsel – Washington, D.C.
Phone: +1 202.624.2872

Crowell & Moring LLP is an international law firm with approximately 550 lawyers representing clients in litigation and arbitration, regulatory and policy, and transactional matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation, as well as its ongoing commitment to pro bono service and diversity, equity and inclusion. The firm has offices in Brussels, Doha, London, Los Angeles, New York, Orange County, San Francisco, Shanghai, and Washington, D.C.

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