Government Contractors Now Required to Provide Privacy Training to Employees

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A new clause has been added to the Federal Acquisition Regulation (FAR) that requires certain contractors to provide “privacy training” to their employees. FAR 52.224-3 “Privacy Training” will be included in all contracts awarded after January 19, 2017, that involve access to a system of records or the handling of Personally Identifiable Information (PII). A system of records refers to records under the control of an agency from which information is retrieved by the name of an individual or by some other form of identifier assigned to that individual. Such contractors will now have to provide privacy training to employees that includes the following parameters.

  • The Privacy Act of 1974 including penalties
  • Appropriate handling and safeguarding of PII
  • The authorized use of the system of records or PII
  • Restrictions of the use of unauthorized equipment to receive, process or store PII, or a system of records
  • Prohibition against the unauthorized use of a system of records or PII
  • Procedures to be followed in the event of a potential or confirmed breach

Employees must receive privacy training prior to starting their assignment and annually thereafter. If Alternate I to the clause is used, the Government will provide the training. Otherwise, the contractor may obtain the training from a source of their own choosing. Regardless of the source, the training must include the items below.

  • Be role-based
  • Include foundational knowledge as well as more advanced information
  • Have measures in place to test the knowledge level of the employees

Contractors are required to generate and maintain documentation demonstrating compliance with the training requirement.

If you have any questions regarding this topic or other contract administration issues, please contact Tom Marcinko at 301.231.6237 or

About Thomas Marcinko

Thomas Marcinko is a Principal Consultant in Aronson’s Government Contract Services Group. He has over 25 years of government contracts experience, including proposal development, contract and subcontract administration, FAR compliance, small business programs, and government audits.

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