Confidentiality Requirements for WIOA 
    Partners
    • Statute and Regulations
      • Workforce Innovation and Opportunity Act of 2014, §185(a)(4) 
         • Prohibits disclosure “…which would constitute a clearly unwarranted invasion of 
          personal privacy:
    • Training and Employment Guidance Letter (TEGL 39-11), June 28, 2012
          “Guidance on Handling and Protection of Personal Identifiable    
    Information (PII)” 
    https://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=7872
    What is Confidential Client Data?
    • Workforce Partners must protect two types of Confidential 
     Client Data (CCD):
      • Personal Identifiable Information (PII)
      The Office of Management and Budget (OMB) defines PII as 
      information that can be used to distinguish or trace an individual’s 
      identity, either alone or when combined in other personal or 
      identifying information that is linked to or linkable to a specific 
      individual
    What is Confidential Client Data?
    • Examples of PII (from TEGL 39-11):
      • Social security numbers
      • Unlisted telephone numbers, includes cellular telephone numbers
      • Financial account numbers (e.g. credit/debit cards, checking 
       accounts, etc.)
      • Age and Date of Birth
      • Marital Status 
    What is Confidential Client Data? 
    • Examples of Data which is NOT by itself PII, but if used in 
     combination with other data, may be used to compromise 
     an identity:
      • First and Last Name
      • Email Address
      • Business Address
      • Gender
      “Risk of Harm Analysis”
    What is Confidential Client Data?
    • Data which by law is confidential and must be protected:
      • Unemployment Insurance (UI)
        • USDOL Regulations, 20 CFR part 603
      • State Employment Security Law, Includes UI and Wagner-Peyser
        • O.C.G.A. §34-8-120, et. seq.
      • Education 
        • Family Education Rights and Privacy Act “FERPA”
      • Vocational Rehabilitation 
        • Health Insurance Portability and Accountability Act  “HIPAA”