Standardizing Federal PII Breach Response: OMB Updates Guidance for Agencies, Contractors, and Grant Recipients
Client Alert | 1 min read | 01.11.17
On January 3, 2017, the Office of Management and Budget (OMB) issued M-17-12, which updates and supersedes 2006 and 2007 OMB memoranda on preparing for and responding to breaches of personally identifiable information (PII) by imposing minimum standards on agencies for incident response programs, training and awareness, reporting, and documentation, coupled with requiring use of a flexible framework to assess and mitigate the risk of harm to individuals potentially affected by a PII breach. While making clear that a PII breach does not necessarily indicate an absence of adequate safeguards, the updated guidance also requires agencies to impose specific requirements, such as encryption, training, and incident-response obligations, on all contractors and subcontractors (at any tier); identifies PII-related requirements for federal grant recipients; and directs the FAR Council to “promptly… create appropriate contract clauses and regulatory coverage.”
Contacts
Insights
Client Alert | 3 min read | 04.24.24
On April 12, 2024, the Tenth Circuit issued a decision in I DIG Texas LLC v. Kerry Creager, which analyzed country-of-origin claims in a manner that diverged from the well-established Federal Trade Commission’s “Made in USA” policy.
Client Alert | 2 min read | 04.24.24
FTC Continues Focus on Tracking Technologies and Personal Health Data
Client Alert | 9 min read | 04.24.24
Client Alert | 4 min read | 04.24.24
Muldrow Case Recalibrates Title VII “Significant Harm” Standard