Operational Guidance | OG 17-2021 Electronic File Storage and Protecting Personally Identifiable Information (PII)

  • Date: May 28, 2021
  • Subject: Electronic File Storage and Protecting Personally Identifiable Information (PII)
  • From: Chet Mottershead, Assistant Secretary for Workforce

Purpose:

To provide guidance on the use of electronic file storage, protecting PII and retrieval of workforce and other federal funds’ participant, program and financial documents and to rescind PS 08-2017.

Background:

Local Workforce Development Areas (Local Areas) and the North Carolina Division of Workforce Solutions (DWS) must maintain many forms of documentation and data for federal funds purposes. These documents and data may be stored electronically and must have the ability to be retrieved as per this Operational Guidance.

U.S. Department of Labor (USDOL) Training and Employment Guidance Letter (TEGL) No. 39-11 provides additional “Guidance on the Handling and Protection of Personally Identifiable Information.”

Action:

Local Areas and DWS offices using electronic file storage and retrieval systems must meet the minimum requirements as outlined in Attachment 1 of this Operational Guidance to maintain and protect information. Local Areas must also protect consumer PII as outlined in Attachment 2. Effective July 1, 2015, all WIOA Title I and Title III Wagner-Peyser participant and program-related documents must be scanned in and stored in NCWorks.gov, unless stated differently, for a DWS initiative or activity. Attachment 3 outlines the processes and procedures that must be followed when scanning documents into the system. In addition to NCWorks.gov data, all customer information must be protected as outlined in this Operational Guidance and referenced TEGL.

DWS must use all preventive measures to ensure that the confidentiality and integrity of all PII remains intact. It is expected that all Local Area Workforce Development Boards (WDB), their representatives, and DWS staff will take necessary steps to protect PII data collected from individuals and employers. This includes redacting any unnecessary PII data when using for verification. Further, all PII data collected for use in Workforce Innovation and Opportunity Act (WIOA) programs must comply with the Statewide Security Information Manual.

https://files.nc.gov/ncdit/documents/Statewide_Policies/Statewide-Information_Security_Manual.pdf                                      

Effective Date:               

Immediately

Expiration:

Indefinite

Contact:

DWS Program Monitor 

Attachments:

  1. North Carolina Guidance for WIOA and Other Federal Funds Electronic Image Storage
  2. North Carolina Guidance for WIOA and Other Federal Funds Protection of Personally Identifiable Information (PII)
  3. North Carolina Guidance for WIOA and Other Federal Funds Scanning Procedures for Consumer Documents in NCWorks.gov
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