Privacy training
Contractors must ensure all employees handling personally identifiable information or systems of records complete initial and annual privacy training, and maintain documentation of completion.
Overview
FAR 24.301 establishes mandatory privacy training requirements for contractor employees who handle personally identifiable information (PII) or have access to systems of records on behalf of a federal agency. The regulation requires both initial and annual privacy training for relevant contractor personnel, ensuring they understand their responsibilities under the Privacy Act of 1974 and related agency policies. The training must be role-based, cover foundational and advanced topics, and include knowledge assessments. Contractors may use their own or another agency's training unless the contracting agency requires its own program. Contractors must maintain documentation of completed training and provide it upon request. Employees cannot access or handle PII or systems of records until they have completed the required training.
Key Rules
- Mandatory Privacy Training
- Contractors must ensure initial and annual privacy training for employees who access or handle PII or systems of records.
- Training Content Requirements
- Training must address the Privacy Act, proper handling of PII, authorized use, restrictions on equipment, prohibitions on unauthorized use/disclosure, and breach response procedures.
- Training Delivery
- Contractors may use their own or another agency's training unless the agency specifies otherwise.
- Documentation
- Contractors must maintain and provide documentation of training completion upon request.
- Access Restriction
- Employees cannot access or handle PII or systems of records without completing the required training.
Responsibilities
- Contracting Officers: Ensure contract clauses require privacy training and verify contractor compliance.
- Contractors: Provide, document, and ensure completion of privacy training for all applicable employees.
- Agencies: May require use of agency-specific training and may request training documentation.
Practical Implications
- This section exists to protect sensitive personal data handled by contractors and ensure compliance with federal privacy laws.
- It impacts daily operations by requiring ongoing training, documentation, and restricting access to PII until training is complete.
- Common pitfalls include failing to document training, using inadequate training content, or allowing untrained employees access to PII or systems of records.