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.
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Commercial drone privacy – In comments filed with the FAA, the World Privacy Forum urged the agency to establish a robust privacy committee to focus on drone privacy and to clarify the applicability of the Privacy Act of 1974 to UAS test site operators. WPF also requested the FAA conduct mandatory Privacy Impact Assessments and provide a FIPS-compliant privacy notice. ”We have offered our comments to the FAA with the acknowledgement that everyone has much to learn in the area of commercial drone privacy. Our suggestions to the FAA seek to increase general knowledge about drones and their effect on privacy,” said Pam Dixon.