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Documented Privacy and Information Security Policy

​​​​​Positive Workforce, Inc.




At the Center it is of utmost importance to us that learner information is safe and secure. We are committed to maintaining and using learner information responsibly. All Center staff, as well as contractors, vendors, consultants and affiliates performing services for the Center are required to maintain the confidentiality of Center learner training records and data entrusted to the Center, except when disclosure is authorized by the training administrator of the Center or required by law. Center learner training records, data and other information may only be used for Center purposes. In accordance with the law and Center policy, confidential records should never be disclosed without appropriate authorization, and should be maintained and secured according to the following principles:

  1.  Documents and files (both electronic and hard copy) containing confidential information are to be accessed, used, and disclosed only with explicit authorization and only on a need-to-know basis for the purpose of a job function, contract, volunteer or paid service to the Center.
  2.  Confidential information regarding any learner acquired during the course of employment at, or providing services to, the Center must never be divulged to anyone outside of the Center without authorization or to anyone within the Center except on a need to know basis.
  3.  The Center will utilize a standardized and centralized record management system for filing and storing learner personal and course information. This system will assure ease of retrieval, availability and accessibility of confidential information without sacrificing the confidentiality of the learner training record.
  4.  All confidential electronic records of must be secured through restricted password access and firewall secure to prevent internal and external theft of such data.  Paper records are maintained in locked and restricted access areas.
  5. All Center learners, with appropriate identification verifying learner’s identity and signature, have the right to request their course records via email, phone and walk-ins. There are no fees for obtaining course records. 
  6. Learners who request their course records will not be charged a fee.  
  7. The Center will never share a learner’s confidential information with any third party. No third party may obtain a learner’s confidential information without the written authorization of the learner and appropriate identification verifying learner’s identity and signature.  
  8.  Learner records must be maintained and kept on file for at least seven years and totally destroyed by shredding when disposed of.
  9.  Records may only be received, secured, maintained, accessed or transmitted on Center resources by the training director or training administrator.
  10.  Upon conclusion of staff employment or services concluded by volunteers, contractors, vendors, consultants and affiliates or upon request of the training director or training administrator, all originals and copies of confidential records, whether electronic or hard-copy, must be returned to the Center and all further access to and use of such information will be relinquished.
  11.  If in doubt about whether a record is confidential, the user should treat as confidential any
  12. Center record which is not already within the public domain, until directed otherwise.
  13. The Center takes no responsibility for the unauthorized collection, storage or transmittal of third-party information regarding any individual or entity by learners, staff, volunteers’ contractors, vendors, consultants and affiliates, that if owned by Center would be subject to this policy.
  14.  Hiring personnel are responsible for informing individuals who will be working or volunteering in or for the Center of their specific responsibilities under this policy.

Additional Information

Violations of this policy will be treated seriously. Staff failure to comply with this policy may lead to discipline, up to and including termination. Volunteers, contractors, vendors, consultants and affiliates hired by the Center who violate this policy may be terminated.  Others covered by this policy may lose the opportunity to contract with, volunteer for, or otherwise provide service to the Center. Violations might also subject the violator to criminal or civil prosecution under the law.