Privacy Training
FAR Subpart 24.3 requires contractors to provide privacy training to employees handling personally identifiable information and mandates inclusion of a privacy training clause in applicable contracts.
Overview
Subpart 24.3 of the FAR establishes requirements for privacy training for contractor employees who handle personally identifiable information (PII) or have access to a system of records on individuals. It outlines the obligations for agencies to ensure that contractors receive appropriate privacy training and mandates the inclusion of a specific contract clause to enforce these requirements. The subpart aims to protect sensitive personal data and ensure compliance with federal privacy laws and regulations.
Key Rules
- Privacy Training Requirement
- Contractors whose employees have access to PII or systems of records must ensure those employees complete privacy training as specified by the agency.
- Contract Clause Inclusion
- Agencies must include a designated privacy training clause in applicable contracts to formalize the training requirement and outline contractor responsibilities.
Responsibilities
- Contracting Officers: Must ensure the privacy training clause is included in relevant contracts and verify contractor compliance.
- Contractors: Must provide and document privacy training for applicable employees and comply with agency-specific training requirements.
- Agencies: Oversee contractor compliance and may specify additional training content or frequency.
Practical Implications
- This subpart exists to mitigate risks of privacy breaches and ensure contractors understand their obligations regarding PII.
- It impacts daily operations by requiring ongoing training, documentation, and oversight.
- Common pitfalls include failing to provide timely training, inadequate documentation, or omitting the required contract clause.