Comment from Center for Democracy & Technology
Center for Democracy & TechnologySupportAdvocacy
Summary: The Center for Democracy & Technology (CDT) supports the OPM's effort to reduce improper payments but urges the agency to implement robust safeguards when sharing data with the Department of Treasury's Do Not Pay initiative. They specifically call for data minimization, strong security protocols, redisclosure limitations, and data quality mitigations to protect individuals from identity theft and wrongful denial of benefits.
Please see attached file