Navy Updates Kid Care Records Amid Cyber Rules—Ho-Hum
Published Date: 9/25/2026
Notice
Summary
The Department of the Navy is updating its records system for the Child and Youth Program to better protect kids' health info and keep family and staff data accurate. These changes follow new cybersecurity rules and expand how info is used, helping Navy and Marine families get the care they need. The updates take effect now, but the public can comment until October 26, 2026.
Analyzed Economic Effects
7 provisions identified: 2 benefits, 5 costs, 0 mixed.
Your income used to set childcare fees
The Department will collect Total Family Income (TFI) and use family information to calculate and administer Child and Youth Program fees under DoD's sliding scale fee policy. Income and family data are part of the records used to determine eligibility and fees.
Broader disclosure rules (routine uses A–K)
The notice incorporates DoD standard routine uses A through J and adds others, allowing disclosures to contractors, law enforcement (Federal, State, local, tribal, foreign), the Department of Justice, courts, NARA, congressional staff, breach-response entities, audit/Inspector General partners, and child-care officials for abuse reporting and investigations.
Privacy Act exemptions limit some access rights
The DoD has exempted records in this system from multiple Privacy Act provisions (including certain access, amendment, and notification sections) pursuant to 5 U.S.C. 552a(k)(2) and (j)(2), and those exemptions are detailed and published in 32 CFR part 310.
Stop using Social Security Numbers
The system will remove Social Security Numbers (SSNs) from records and stop using SSNs to retrieve records. Records will instead be retrieved by last name, DoD ID number, or DoD Benefits Number.
More people covered in the system
The system expands the categories of individuals covered to include sponsors, spouses, children, emergency contacts, staff, contractors, volunteers, Family Child Care (FCC) providers, and household family members. Those listed will have personal and professional information stored in the system.
Records retention stays for 3 years after eligibility
Child and Youth Program records are retained for 3 years after an individual is no longer in or eligible for the program or leaves the installation. Records are not destroyed for active patrons or providers and may be kept longer if there is an active legal investigation.
Improved cybersecurity and access controls
The system is updated to align with current DoD cybersecurity policies and uses access controls such as username/password, Common Access Card/Public Key Infrastructure (CAC/PKI), encryption, and restricted physical access for terminals and facilities hosting the web-based Child Youth Management Systems.
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Key Dates
Department and Agencies
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