Overview
This section mandates that federal contractors provide initial and annual privacy training to all employees who handle personally identifiable information (PII) or design, develop, or operate a system of records on behalf of the government. It establishes the minimum content requirements for such training and sets a strict "no training, no access" policy for contractor personnel.
Key Rules
- Applicability: Training is required for any contractor employee who handles PII, accesses a system of records, or is involved in the design/maintenance of such systems.
- Frequency: Contractors must ensure employees complete initial training before gaining access and recurring annual training thereafter.
- Mandatory Content: Training must cover the Privacy Act of 1974, safeguarding PII, authorized use of records, restrictions on unauthorized equipment, prohibitions on unauthorized disclosure, and breach response procedures.
- Training Standards: Programs must be role-based, provide both foundational and advanced levels, and include a mechanism to test the employee's knowledge.
- Documentation: Contractors are required to maintain records of training completion for all applicable employees and provide them to the government upon request.
- Access Control: No employee is permitted to handle PII or systems of records until they have successfully completed the required training.
Practical Implications
- Compliance Risk: Contractors must implement a robust tracking system to ensure 100% training compliance, as allowing an untrained employee to handle PII constitutes a direct violation of the FAR and may lead to the revocation of system access.
- Training Flexibility: While contractors can often use their own internal training modules, they must ensure their curriculum specifically maps to the six minimum elements required by FAR 24.301(b) unless the agency mandates the use of government-provided training.