Client Alerts & Newsletters

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

Dec.28.2016

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
Email: gzirkelbach@crowell.com

Peter Eyre
Partner – Washington, D.C.
Phone: +1 202.624.2807
Email: peyre@crowell.com

Evan D. Wolff
Partner – Washington, D.C.
Phone: +1 202.624.2615
Email: ewolff@crowell.com

Maida Oringher Lerner
Senior Counsel – Washington, D.C.
Phone: +1 202.624.2596
Email: mlerner@crowell.com

Kate M. Growley, CIPP/G, CIPP/US
Partner – Washington, D.C.
Phone: +1 202.624.2698
Email: kgrowley@crowell.com

Nkechi Kanu
Counsel – Washington, D.C.
Phone: +1 202.624.2872
Email: nkanu@crowell.com

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