WPF suggests solutions to OMB for handling Commercially Available Information, including exploring a formal, inclusive Voluntary Consensus Standards process to address challenges

WPF submitted comments regarding how commercially available information (CAI) — also known as data broker data — will be handled by U.S. Executive Agencies. The Request for Information from OMB was an important opportunity to comment on a topic that has only rarely been opened for public comment. OMB Request for Information regarding Executive Branch Agency Handling of Commercially Available Information Containing Personally Identifiable Information is part of OMB’s implementation of Executive Order 14110, Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence.

In our comments, we focused on solutions to the problems the RFI raised,

We recommended better Privacy Impact Assessments, and that OMB expand existing requirements to describe CAI as a new category of sources of information in a Privacy Act System of Records.

We discussed the non-personal data problem in the comments; that is, when personally identifiable information is de-identified, it often leaves the boundary of regulation. This is particularly problematic in a variety of AI contexts, including research in genetic biobanks, where de-identified data can be re-identified. In order to find cooperative solutions to this and other difficult problems, we suggested that OMB use its Circular A-119 rules regarding Voluntary Consensus Standards to undertake creating inclusive, consensus-based VCS standards for CAI procurement, use, and transparency.

In the comments, we discussed details about how Voluntary Consensus Standards work, and some of the Federal agencies that have been using VCS for decades.

The comments also included technical comments about how agency obligations could be enhanced.

Related Documents:

Read WPF’s Comments (PDF, 11 pages)

Posted December 20, 2024 in AI, AI and Privacy, Data Brokers, Genetic Privacy, National Institutes of Health (NIH), OMB, Privacy Act of 1974

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