Privacy for Everyone! New FAR Rule Imposes Mandatory Training Requirements for Employees Handling PII
Client Alert | less than 1 min read | 12.28.16
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.
Contacts
Partner and Crowell Global Advisors Senior Director
- Washington, D.C.
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- Washington, D.C. (CGA)
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Insights
Client Alert | 2 min read | 07.15.26
CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations
As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements (Level I and II self assessments are still permitted). Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights.
Client Alert | 3 min read | 07.15.26
Client Alert | 3 min read | 07.14.26
Client Alert | 3 min read | 07.13.26
Amici Rally Behind Liberty Global, Urging Tenth Circuit to Rein in Economic Substance Doctrine
