WPF files comments on federal information handling to the Office of Management and Budget

The World Privacy Forum filed comments today on the Office of Management and Budget’s proposed revision to a document that advises Federal agencies on how to handle the information they store. The document, OMB Circular A-130, Managing Information as a Strategic Resource, establishes policies for the management of federal information resources, including information the US holds on individuals. The issues and functions governed by A-130 have only grown in importance since the last revision. We applaud OMB’s initiative in revising and modernizing the Circular.

WPF has supported some OMB revisions, and has made recommended changes to other revisions. Some of our recommended changes include the following:

• The OMB needs to impose appropriate conditions on use, disclosure, and other processing of personally identifiable information.
• One section of the draft needs to be revised to expressly restrict federal agencies from charging fees or restricting reuse, resale, redissemination, of information unless specifically authorized by statute, per 44 U.S.C. 3506(d).
• The OMB needs to use a pre-existing definition of PII by NIST, or a previously published OMB definition instead of the version included in the draft.
• The Circular needs to be revised to use a standard version of Fair Information Practices instead of using the OMB’s rewording of the FIPPs.

The comment period for the OMB draft is open until Nov. 20, 2015. Our detailed comments are here.

Read the full WPF Comments on the A-130 draft Circular (PDF)

Background documents: Read the OMB Circular A-130 draft document