FAR 52.224-3 — Privacy Training
This clause requires designated employees to complete privacy training before accessing a Privacy Act system of records or handling personally identifiable information under the contract, and annually thereafter.
- Clause
- FAR 52.224-3
- Applies to
- Contracts requiring access to a Privacy Act system of records or personally identifiable information
- Flows down to subs
- Yes
- Primary risk
- Untrained employees handling PII
Key takeaways
- Read the clause as incorporated in your contract — tailoring and alternates change obligations.
- Flowdown obligations are your responsibility; a noncompliant subcontractor is your problem.
- Document compliance contemporaneously; after-the-fact reconstruction rarely satisfies auditors.
- When a clause is unclear, ask the contracting officer in writing before award, not after.
What the clause requires
Employees who create, collect, use, process, store, maintain, disseminate, disclose, or dispose of PII, or who have access to a Privacy Act system of records, must complete initial and annual privacy training that meets the content requirements specified by the agency.
How to comply in practice
Identify every role with PII or system-of-records access, complete the agency's specified training before granting access, and track annual refresher completion in your compliance calendar alongside other recurring certifications.
Common mistakes
Contractors run generic internal privacy training instead of the agency-specified training content, which does not satisfy the clause even though it addresses similar subject matter.
FAQ
Who must be trained?
Employees with access to a Privacy Act system of records or who handle personally identifiable information under the contract.
Is training required annually?
Yes, initial training before access and annual refresher training thereafter.
Can I use my own training program?
Only if it meets the content requirements specified by the agency; otherwise use the agency-provided training.
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