OMB deserves much praise for this novel privacy initiative, but it has more work to do. The evaluation of the first private sector database in the Do Not Pay Initiative needs to be accomplished in the open with full participation by all interested parties. The OMB memo provides for that. We need to see how well that process works.
The best starting point for understanding the OMB Do Not Pay memo is with the legal framework behind the Do Not Pay Initiative. The Initiative derives from a combination of little-noticed executive orders and updates to existing laws.
In 2009, Executive Order 13520, Reducing Improper Payments,  directed agencies to identify “ways in which information sharing may improve eligibility verification and pre-payment scrutiny.” This was the start of the current Do Not Pay Initiative.
Today the World Privacy Forum published a report discussing the US federal government’s use of commercial data brokers, the implications for that usage, and what needs to be done to address privacy problems. The report argues that the government must bring itself fully to heel in the area of privacy, explaining that when government outsources its data needs to commercial data brokers, it needs to also attach the privacy standards it would have been held to if it had collected the data itself. Outsourcing can no longer be an excuse for evading privacy obligations.
You are reading the Executive Summary of Data Brokers and the Federal Government: A New Front in the Battle for Privacy Opens Report Links: Report Home & Executive Summary Download the full report (PDF) Jump to other sections of the report: Executive Summary | I. Introduction | II. Discussion | III. Recommendations | IV. Conclusion | Appendices Executive Summary The US federal government
You are reading Appendices A, B, and C of Data Brokers and the Federal Government: A New Front in the Battle for Privacy Opens Report Links: Report Home & Executive Summary Download the full report (PDF) Jump to other sections of the report: Executive Summary | I.Introduction | II. Discussion | III. Recommendations | IV. Conclusion | Appendices Appendix A: Chronology of the