The World Privacy Forum filed a pair of comments about a US Department of Justice proposal regarding treatment of insider threat records at the FBI. Our first comments respond to a Systems of Records notice, our second comments respond to a Notice of Proposed Rulemaking on the same issue. In our first set of comments
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
This report focuses on government use of commercial data brokers, the implications for that usage, and what needs to be done to address privacy problems. The government must bring itself fully to heel in the area of privacy. If it is going to outsource its data needs to commercial data brokers, it needs to attach the privacy standards it would have been held to if it had collected the data itself. Outsourcing is not an excuse for evading privacy obligations. Report authors: Bob Gellman and Pam Dixon.
The US federal government uses commercial data brokers  extensively for a wide variety of governmental activities. It is unquestioned that the government provides considerable revenue to commercial data brokers. How much? A reasonable and conservative estimate is that the number ranges in the billions of dollars. Over the course of the last 20 years, the extent of the relationship has become clear through a series of detailed investigations and scholarly research. For background purposes, we reference a leading study and discuss a newer use. This report does not seek to reinvestigate and re-document known uses.
Recommendations for the Office of Management and Budget:
OMB should establish privacy standards that are at least a good as those in and recommended for the Do Not Pay Initiative to cover all government purchases of commercial databases with personal information. OMB should consider accomplishing an expansion by establishing a task force that includes representatives of consumer and privacy groups.