Office of Management and Budget (OMB)

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Privacy Forum has filed comments to the U.S. Office of Management and Budget in response to its Request for Feedback on Draft Guidance: Broadening Public Participation and Community Engagement with the Federal Government.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 specific suggestions to OMB regarding how Privacy Act notices might be managed in a way that facilitates better feedback from those interested specifically in Privacy Act of 1974 notices, which have meaningful bearing on matters relating to data governance, privacy, and data protection.

The World Privacy Forum has filed detailed comments to the U.S. Office of Management and Budget (OMB) in response to its Request for Information on Privacy Impact Assessments. Specifically, OMB requested information about how the U.S. Federal government should update or adjust its requirements for Privacy Impact Assessments (PIAs) in regards to changes to data ecosystems brought about by Artificial Intelligence (AI). WPF provided substantive recommendations regarding administrative provisions of the Privacy Act, scalable automated AI governance tools for privacy and trustworthy AI, ensuring nimble processes for privacy and AI assessments, and ensuring balanced, skillful socio-legal-technical decisionmaking.

Today the Biden-Harris Administration published a Memorandum that sets forth how U.S. Federal Agencies and Executive Departments will govern their use of Artificial Intelligence. The OMB memorandum provides an extensive and in some ways surprising articulation of emergent guardrails around modern AI. There are many points of interest to discuss, but the most striking includes the thread of biometrics systems guidance throughout the memorandum and continuing on in the White House Fact Sheet and associated materials. Additionally, the articulation of minimum practices for safety -impacting and rights- impacting AI will likely become important touch points in regulatory discussions in the U.S. and elsewhere. The guidance represents a significant policy shift for the U.S. Federal government, particularly around biometrics.

In December 2023, WPF submitted detailed comments to the U.S. Office of Management and Budget regarding its Request for Comments on Advancing Governance, Innovation, and Risk Management for Agency Use of Artificial Intelligence Memorandum.  OMB published the request in the Federal Register on November 3, 2023. This particular Memorandum is of historic importance, as it articulates the establishment of new agency requirements in the areas of AI governance, innovation, and risk management, and would direct agencies to adopt specific minimum risk management practices for uses of AI that impact the rights and safety of the public.

The World Privacy Forum submitted comments today on an important proposal from the US Executive Office of the President, Office of Management and Budget regarding a circular directing agencies how to write, post, review, and generally handle Privacy Act notices. The proposal, called Circular A-108 Federal Agency Responsibilities for Review, Reporting, and Publication under the