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

Posted November 17, 2015 in Office of Management and Budget (OMB), Privacy Act of 1974, Public Comments, Public Policy

New Report: Risky Analysis: Assessing and Improving AI Governance Tools

We are pleased to announce the publication of a new WPF report, “Risky Analysis: Assessing and Improving AI Governance Tools.” This report sets out a definition of AI governance tools, documents why and how these tools are critically important for trustworthy AI, and where these tools are around the world. The report also documents problems in some AI governance tools themselves, and suggests pathways to improve AI governance tools and create an evaluative environment to measure their effectiveness. AI systems should not be deployed without simultaneously evaluating the potential adverse impacts of such systems and mitigating their risks, and most of the world agrees about the need to take precautions against the threats posed. The specific tools and techniques that exist to evaluate and measure AI systems for their inclusiveness, fairness, explainability, privacy, safety and other trustworthiness issues — called in the report collectively AI governance tools – can improve such issues. While some AI governance tools provide reassurance to the public and to regulators, the tools too often lack meaningful oversight and quality assessments. Incomplete or ineffective AI governance tools can create a false sense of confidence, cause unintended problems, and generally undermine the promise of AI systems. The report contains rich background details, use cases, potential solutions to the problems discussed in the report, and a global index of AI Governance Tools.
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Report: From the Filing Cabinet to the Cloud: Updating the Privacy Act of 1974

This comprehensive report and proposed bill text is focused on the Privacy Act of 1974, an important and early Federal privacy law that applies to the government sector and some contractors. The Privacy Act was written for the 1970s information era -- an era that was characterized by the use of mainframe computers and filing cabinets. Today's digital information era looks much different than the '70s: smart phones are smarter than the old mainframes, and documents are now routinely digitized and stored and perhaps even analyzed in the cloud, among many other changes. The report focuses on why the Privacy Act needs an update that will bring it into this century, and how that could look and work. This work was written by Robert Gellman, and informed by a two-year multi-stakeholder process.