Issuance: 2019-03 – March 6, 2019

Issuance Number: 2019-03

Date: March 6, 2019

To: Workforce Partnership Subrecipients

From: Kai Jackson, Director of Finance & EO/Grievance Officer

Subject: Equal Opportunity Compliance

Purpose:

This informational issuance is to provide guidance on 1) ensuring medical or disability related information is removed from retention files and 2) If an individual’s driver license indicates corrective lenses, this information needs to be treated as medical or disability related information.  

Background:

Subrecipients must maintain records, whether they exist in electronic form (including email) or hard copy, for a period of not less than four (4) years from the date of the contract closeout.  

Any medical or disability-related information obtained about an individual, including information that could lead to the disclosure of a disability, must be collected on separate forms. All such information, whether in hard copy, electronic, or both, must be maintained in one or more separate files, apart from any other information about the individual, and treated as confidential. Whether these files are electronic or hard copy, they must be locked or otherwise secured (i.e., through password protection).  

Action:

Subrecipients are required to: 

  1. Review retention files (PY ‘14 through ‘18) to ensure that:  
  • No medical or disability related information is present in files. For example, an intake form asks, “are you a pregnant or parenting individual?”. If the answer is YES, the intake form must be redacted, or information must be collected in a separate file. If the answer is NO, since no medical or disability information is being disclosed no changes need to be made.   
  • If an individual’s driver license indicates corrective lenses, this information needs to be treated as medical or disability related information and information must be redacted or collected in a separate file.  

 If you have any questions regarding this issuance contact your Contract Administrator at (619) 228-2900. 

References: 

  1. To access the chapters and their attachments, go to workforce.org and click on the collapsed menu icon located on the top right hand side of the webpage.
  2. Click on “Operations Resources” section.
  3. Click on “Operations Manual” to see the list of chapters and operational issuances.
  4. Click on“Informational Issuances” next to any chapter to view the policy and attachments.