WPF Comments to OMB regarding public participation draft memorandum
The World Privacy Forum has filed comments to the U.S. Office of Management and Budget in response to its Request for Feedback on Draft Guidance: Broadening Public Participation and Community Engagement with the Federal Government.
WPF made three suggestions:
- A proposal that a Privacy Act of 1974 notification service might be provided on a government-wide basis or on an agency-by-agency basis. Today, this functionality can be cobbled together ad-hoc, but there could be a much more streamlined approach that would save time for those working to respond to PA notices.
- We noted that the function we proposed could alternatively be managed by the Federal Privacy Council (https://www.fpc.gov/ ) which could potentially act to provide notice earlier in the process. Any agency that begins planning an activity affecting privacy likely to result in a change to a Privacy Act of 1974 notice, an entirely new notice, or a significant consequence for privacy interests could notify the privacy community of what the agency is planning well before the Privacy Act of 1974 notice stage. The Federal Privacy Council could develop simple standards to guide the timing and content of advance agency notices. This would be extremely helpful for NGOs.
- Another suggestion was that each agency’s Privacy Officer might be tasked with the responsibility of identifying relevant agency activities and to draft a public notice. The notice of an agency activity affecting privacy could be part of the notification system we proposed above about the Privacy Act of 1974, or it could be a separate topic with a separate notice system.