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The Global Collision Of Privacy & Homeland Security

Client Alert | 1 min read | 05.10.06

As the war on terrorism becomes increasingly dependent upon international cooperation and information sharing, Homeland Security contractors engaged in building these trans-border information pipelines face escalating risks of running afoul of more potent privacy regimes abroad where the Canadian Privacy Commissioner has described the "privacy landscape" as a "battlefield" in which "the world has become a more dangerous place." In their recent article "When Homeland Security Goes Abroad: The Global Collision of Privacy & Anti-Terrorism Laws" published in the Federal Contracts Report on April 25, 2006 (http://www.crowell.com/pdf/newsroom/ BNA_Bodenheimer-Meade.pdf), David Bodenheimer and Kris Meade of C&M examine the privacy requirements in the United States and abroad, identifying risks to Homeland Security contractors who may be caught in the global crossfire on the privacy battlefield.

Insights

Client Alert | 1 min read | 04.18.24

GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings

On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS).  Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:...