OMB Federal Agency Data Breach Guidelines – Considerations for Industry

Earlier in February, the Executive Office of Management and Budget ("OMB") issued Memorandum M-17-12 to federal agencies to set out guidelines and procedures for preparing for or responding to a breach involving the release of personally identifiable information ("PII"). The OMB's suggested framework specifically aims to "[assess] and mitigate the risk of harm to individuals potentially affected by a breach," and to provide "guidance on whether and how to provide notification and services to those individuals." The implementation of common federal agency standards and processes is oriented to not only streamline the way agencies deal with the release of PII, but to also ensure that the federal government is capable of handling data breaches in an effective and efficient manner.