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Are JobNet/TAXIS converted records considered TAXIS records and therefore unable to merge because the system recognizes them as TAXIS/TAXIS records? (05/22/07)

Converted TAXIS records are considered TAXIS records and can not merge. We initially received a full dump of TAXIS created Employers when SKIES went into production. From that point forward, records are received through the regularly scheduled interface. That is the difference between converted TAXIS and interface TAXIS. All still originated from TAXIS.

What about data conversion records (not specified as JobNet)? Are they TAXIS records and cannot merged – or – can they merge? (05/22/07)

As long as the originating system was not TAXIS or through the interface with Go2Worksource.com, the system allows them to merge.

How to keep other counties, WDAs, people, from having access to a particular office or area’s employer record? (05/22/07)

Currently, there is no policy or statewide practice to prohibit WDAs from sharing an employer record. This concern will be presented at the next SKIES Change Control Board meeting to assist with identifying the appropriate entity for resolution.

Data Access

Who is responsible for system access approval, record keeping and monitoring in centralized WDAs?

In Centralized WDAs, the State (ESD) has responsibility for approving user access as well as maintaining records of MOUs, Data Sharing Contracts, user profiles and supervisor approval. Local partner offices are responsible for keeping the signed Notice of Non-Disclosure and certification of training completion for each user.

Who generates the Data Sharing Agreement (DSA)?

Since the WDC, ESD and partner agencies are all involved, the development of SKIES Data Sharing Contracts must be coordinated. We have asked the SKIES Steering Committee member from each area to facilitate the coordination. In decentralized areas, it is up to the WDA to develop a procedure for tracking the Non-Disclosure statements.

Who tracks Non-disclosure statements; (does the State need a copy of each signed statement)?

They can either be kept centrally at the WDA, or be retained at the local partner office, as long as an auditor can retrieve them. In centralized areas, all Non-Disclosure statements will be retained at the local office. The State does not need a copy of the signed statement.

Is a Data Sharing Agreement (DSA) required for each site?

Each “SKIES Data Recipient” (WorkSource Partner, WDC or WIA Contractor who is authorized to have access to or receives SKIES data) is required to have a SKIES Data Sharing Contract with ESD. A regional partnership area may have a single Data Sharing Contract with ESD that lists multiple parties (each Requesting Entity in the partnership area), or it may have separate contracts with ESD for each partner.

Must a Centralized WDA maintain local user records?

No. The only record keeping requirement for centralized WDAs is that local offices retain signed Non-Disclosure statements and certification of training completion for each user.

Who grants data sharing authority?

Each “Requesting Entity” (WorkSource Partner, WDC or WIA Contractor) must have a Data Sharing Contract with ESD. WDAs choosing the decentralized option must include the special provision for “Decentralized Security Administration” in their contract with ESD. This provision grants authority to the WDA to authorize user access to the system. Access can only be authorized to individuals employed by an agency that has a SKIES Data Sharing Contract with ESD.  For WDAs choosing the centralized option, ESD will authorize user access, but only to individuals employed by an agency that has a SKIES Data Sharing Contract with ESD.

Who certifies that signed Non Disclosure statement is on file for the user?

ESD identified a “System Access Approver” for each local centralized office. Only this individual will be authorized to access a secure on-line SKIES User Access request form. On the form, the System Access Approver will be required to certify that signed Non Disclosure statements are on file for the user, the type of access granted (user profile) is justified and is approved by the user’s supervisor, and that SKIES training has been completed. Upon receipt of the request, ESD will verify that a valid SKIES Data Sharing Contract is in place for the requesting agency and that the agency is party to a WorkSource Memorandum of Agreement (WorkSource Partner) or is a WDC contractor for services under the Workforce Investment Act. ESD will have a system to track Data Sharing Contract expiration dates so that user access will be revoked when contracts expire. The System Access Approvers will be required to notify ESD immediately when users are no longer employed so access can be revoked.

Where are records maintained?

In decentralized areas, the WDA must develop procedures to keep records of each individual authorized to access the system. This should include user’s office location, access profile, certification of training completion, supervisor approval, and evidence that Non-Disclosure statement is signed,  For each agency (Requesting Entity), evidence to document a current Data Sharing Agreement and MOU (or WIA contractor status) will be needed. A procedure will also be needed to ensure that user access is immediately revoked when the user is no longer employed with the agency, or if the Data Sharing Contract expires. These records can be maintained at the WDA or at the local office, as long as they are retrievable for audit or monitoring. In centralized areas, most of these records will be maintained by ESD. Only the signed Non-Disclosure statements and certification of training completion needs to be maintained at the local office.

Who grants user access and maintains records of skies access in the centralized option?

Under the centralized option, responsibilities for granting user access and related record keeping (except as noted in question above) are assumed by the state. All WorkSource Partners, WDCs or WIA Contractors who need to have access to or receives SKIES data must have a SKIES Data Sharing Contract with ESD.

Who guards against inappropriate access?

The responsibility for guarding against inappropriate access is shared by all parties including the State, WDC and local offices (Requesting Entities). See LIMITATION ON ACCESS AND USE, PHYSICAL SAFEGUARDS and TERMINATION OF ACCESS provisions in the SKIES Data Sharing Contract.

Who approves access?

For centralized WDAs, “System Access Approvers” will submit access requests to ESD, but only ESD can actually add users in SKIES. The WDA System Administrator in centralized WDAs can maintain table information and perform other administrative tasks in SKIES, but cannot add users.

Who is the "Department Agreement Manager"?

Check with the ESD representative for your WDC

Where can I get a Data Sharing Notification?

See ESD Policy and Procedures for Data Sharing

Who is responsible for getting the Data Sharing Agreements signed?

This should be coordinated between the SKIES Steering Committee member, and the ESD representative for your WDC.

What about Volunteers? The Data Sharing Contract definitions - d. "WIA Contractor", includes the Contractor's ”volunteers". If a WorkSource office has Green Thumb volunteers manning the front desk, what organization is responsible for the volunteers? Does Green Thumb, as an organization, need to sign the Data Sharing Agreement?

A volunteer is considered an agent of the organization they are working (or volunteering) for. Green Thumb would not need to have a Data Sharing Contract unless it is a WorkSource partner. In this case, the volunteer would be an agent of the WorkSource office, so would be covered by its Data Sharing Contract. Like all users, the volunteer must sign the Notice of Non-Disclosure.

Who can answer questions about SKIES Data Sharing Contracts?

You can direct your questions to Tina Pendon

Confidentiality

May I mail a SKIES report that may contain customer information to an affiliate? (03/25/03)

If you mail the data, it should be on a CD in a file that is password protected. You can put the data in an excel file with password protection, or compress to a password protected zip file. The password should be transmitted separately to the recipient - preferably by phone. This protects the data from interception by someone who opens and processes the mail before the intended recipient actually gets it. You should never mail printed data.

Under the Data Sharing Contract we must properly secure, dispose, destroy or shred documents generated from SKIES in printed form.  Is a company that picks up and destroys confidential material that's stored in a locked container a proper form of destruction for SKIES printed data? (03/25/03)

Normally we would like to see shredding by the user, but the scenario you outlined would be OK.

How does SKIES address confidentiality?

Access to SKIES will require the following:

	Must be an employee of an agency that has signed a Memorandum of Agreement with the local Workforce Development Council.
	Must be an employee of an agency that has signed a data sharing agreement.
	Must be an employee of an agency with a resource sharing agreement (if applicable).
	Must have completed training in SKIES.
	Must have signed an Oath of Confidentiality.

SKIES is designed from the perspective of a “shared customer” for both jobseekers and employers. It is assumed that agencies working in the WorkSource delivery system need to share information about customers to better serve that customer, reduce redundancy in the collection of data and reduce the number of service points for the customer. Implied in that concept of “shared customer” is the notion that all agencies are working for the best interest of the customer in a professional manner. It is assumed that all professionals are concerned about maintaining a customer’s information in a way that will benefit and not harm the customer. In this shared system, no one agency owns the information. The customer owns the information; the agencies use the information to meet the needs of the customer. We are all learning new behaviors in the WorkSource delivery system. One of the new behaviors is trust among partners. We are all in the process of building that trust.

Access will be monitored and controlled. We want to ensure that only staff that have met the requirements have access. Audit reports will be available to supervisors, which will allow areas to check on any changes to information that is entered into the system. Those changes will be identified by user and by date.

I want to email a report containing customer and counselor names to an affiliate. No SSN's or anything else. Must I password protect or encrypt the report before I can email it to them?

Since the file will contain personal information, it will need to be transmitted in a secure way. If you are sending to a user that is inside the ESD network (DIS backbone), you can go ahead and send as a regular e-mail because our network is protected. If you need to send it outside the ESD network, you can protect it by sending as a password protected zip file (like win-zip or PK Zip). Let me know if you need help doing this. You will have to then give the recipient the password. Don’t send the password via e-mail - use the telephone for that. Another alternative is to write the data to a CD and hand deliver it. If you do so, make sure the CD is destroyed after use.

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