Located in:
- III. Operational Planning Elements
The Unified or Combined State Plan must include an Operational Planning Elements section that supports the State’s strategy and the system-wide vision described in Section II(c) above. Unless otherwise noted, all Operational Planning Elements apply to Combined State Plan partner programs included in the plan as well as to core programs. This section must include—
- b. State Operating Systems and Policies
The Unified or Combined State Plan must include a description of the State operating systems and policies that will support the implementation of the State strategy described in section II Strategic Elements. This includes—
- b. State Operating Systems and Policies
III. b. 6. D. Privacy Safeguards
Describe the privacy safeguards incorporated in the State’s workforce development system, including safeguards required by section 444 of the General Education Provisions Act (20 U.S.C. 1232g) and other applicable Federal laws.
Current Narrative:
Michigan requires signed agreements from all local areas and from state staff who have access to confidential data. These agreements restrict access and the use of such data to those employees who require that information in the official performance of their job duties. The agreements require users to maintain data confidentiality and prohibits the disclosure of any confidential data to a third party, unless previously authorized in writing to do so. Each local area director signs a confidentiality agreement by which they acknowledge their obligation and commitment to keep confidential data secure and to use such data solely for the purposes related to their job duties.
Michigan follows confidentiality requirements for wage and education records as required by the Family Educational Rights and Privacy Act of 1974, as amended, the Workforce Innovation and Opportunity Act (WIOA), the Michigan Employment Security Act, and other applicable federal and state laws and regulations.
The One-Stop Management Information System and the Michigan Adult Education Reporting System are role-based systems with specific permissions granted, depending on an individual’s role. Confidential information is protected within the systems by restricting access to view, enter, or edit data to specific security roles or specific security privileges. Access to these systems is granted by users with specialized administrative rights and administrative users’ accounts are monitored periodically to ensure that rights have been granted to only appropriate staff.
Vocational Rehabilitation (VR) – Michigan Rehabilitation Services (MRS) and Bureau of Services for Blind Persons (BSBP)
The VR programs in Michigan reference 34 CFR §361.38, which is the confidentiality Federal regulation within the Vocational Rehabilitation Act as amended in 2014. Release of information forms are acquired when personal identifying information is necessary to be collected or shared to promote the success of the VR process, and only when agreed upon by the consumer. The Federal regulation is supported by agency policy from both MRS and BSBP agencies.