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.
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Partner and Crowell Global Advisors Senior Director
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Insights
Client Alert | 7 min read | 05.27.26
Colorado Hits Reset on AI Regulation: SB 26-189 Repeals and Reenacts the Colorado AI Act
Colorado’s original AI Act (SB 24-205), signed in May 2024, imposed broad obligations on developers and deployers of “high-risk AI systems” — including requiring risk management programs, impact assessments, and affirmative steps to prevent algorithmic discrimination across employment, housing, lending, insurance, health care, and education decisions. The operative date for SB 24-205 was extended twice, and a court temporarily suspended enforcement in early 2026, following a lawsuit filed by xAI, which the U.S. Department of Justice (DOJ) intervened to support. Industry feedback on SB 24-205 was generally negative. In response to this environment, Colorado’s legislature undertook a rewrite, drafting and passing SB 26-189 in a matter of weeks. SB 26-189 reflects the legislature’s effort to preserve the policy goal of filling the AI oversight vacuum given the lack of a comprehensive federal law, but within a more workable compliance framework.
Client Alert | 3 min read | 05.27.26
Don’t Get Left in the Doghouse: The Federal Circuit’s Global K9 Case and the Duty to Intervene
Client Alert | 3 min read | 05.26.26
Client Alert | 5 min read | 05.26.26
