Privacy Training as Fringe Benefits
Under the Davis-Bacon Act, prevailing wage contractors are required to provide fringe benefits to workers. This is an obligation that must be complied with. Otherwise, prevailing wage contractors will be subject to penalties and fines.
Prevailing wage contractors need to comply with privacy training rules in order for their workforce to be protected by personally identifiable information (PII) rules. PII is any information linked to trace the identity of an individual. It is the federal contractor’s role to safeguard PII or a system of records pertaining to employees’ identity. It is for this reason that we enumerate steps covered in the mandatory privacy training.
Role of Prevailing Wage Contractors
A new process was introduced by the Department of Defense (DOD), National Aeronautics and Space Administration (NASA) and General Services Administration (GSA). Tthe highlights of the mandatory new process include:
1. Identification
Those individuals that are now subject to the privacy training rules are identified. These include workers who access PII or a system of records. Basically, all aspects in developing, designing and handling of PII are covered in this phase.
2. Training
Identified individuals are required to undergo training on privacy obligations. To ensure safeguarding of PII, topics include provisions of the Privacy Act of 1974. The training method in itself is expected to be role-based, measurable and following a knowledge testing system to ascertain the level of learning acquired by its learners. It is also expected that training are conducted annually.
3. Records Management
Contractors maintaining records serves as tangible proof that identified employees have participated in the required training.
4. Flowing Down
This phase of the process is intended for prime contractors who hold subcontractors so they pass on rules and requirements to all applicable subcontractors.
5. Prohibition
Unless privacy training has been completed, contractors must prohibit access to information or prohibit employees from performing certain tasks.
ARCHER JORDAN Guides you towards the Path of Compliance
At ARCHER JORDAN, we assist prevailing wage contractors to ensure compliance with state and federal regulations through our Arrow Contractors’ Trust Program. Our fringe benefit plans comply with the Service Contract Act and Davis Bacon Act, and can even be customized to address specific needs of your prevailing wage workers.
With these concepts in mind, we give you the assurance that ARCHER JORDAN can help provide fringe benefit solutions that are compliant with regulations – all while maximizing employee benefits.
