DWD-DET WIOA EO/CR FAQ - Element 6: Data and Information Collection and Maintenance

1. Documents:
   Career planners can upload medical and disability documents into ASSET and mark them as confidential. It is currently not possible to manually enter confidential data into individual ASSET screens and mark it as confidential, except for case notes.
   
   An entire PIN can be made confidential. PINs marked confidential by checking the "Make all information about this customer confidential" checkbox on the Customer Details page can ONLY be accessed by the "Confidential Manager," their supervisor (as defined on their staff record in JCS Admin), and the ASSET Admins. Any other staff (even those assigned to the customer's Case Team) will not access that customer record.


2. Case Notes:
   Career planners can retroactively mark "confidential" case notes if they have confidential information. Career planners always need to include the "minimum necessary" medical information. However, if titles in past case notes have confidential information, then a "staff request" needs to be submitted to remove the confidential words in the title.

Yes, as stated in WIOA Policy 5.7, any medical information, including pregnancy, that is case noted, should be marked confidential.

Yes, any form containing anything regarding a disability or medical should be marked confidential in ASSET.

Yes, marking an entire PIN as confidential limits who can view it. PINs marked confidential by checking the "Make all information about this customer confidential" checkbox on the Customer Details page can ONLY be accessed by the "Confidential Manager," their supervisor (as defined on their staff record in JCS Admin), and ASSET Admins. Any other staff (even those assigned to the customer's Case Team) cannot access that customer record.

1. Assuming the question refers to an actual ASSET web page:
   Currently, there are no options for redacting/blurring documents in ASSET. However, in ASSET, there are options to mark some things confidential and marking them as confidential uploaded documents. If there isn't an option to mark something confidential, then it is fine to leave it as is in ASSET.
2. Assuming you have a digital file, there are few options:
   1. Use a basic photo editor and overlay the sensitive information with a shape. Helpful Tips: Ensure the shape is set to 100% Opacity (or 0% transparency). Make sure to save the final image in a format that does not support layers. If available, use something like MSPaint over something like Photoshop. MS Paint saves files as "flat files," so you can't remove the black redact line. Programs like Photoshop or Microsoft Word have "layers," which someone could remove to see un-redacted data. If you use Photoshop, you will want to save it as a flat-file (like a png or jpg) instead of a Photoshop file.
   2. Acrobat Pro contains tools for redacting information on PDFs
      1. Choose Tools > Redact.
      2. On the Edit menu, choose Redact Text & Images.
      3. Select the text or image in a PDF, right-click, and select Redact.
      4. Select the text or image in a PDF, choose Redact in the floating context menu.
      How to Redact in Adobe Acrobat Pro
      1. Open the PDF that contains the text you want to black out.
      2. Go to the Tools menu and select the Redact tool to open the Secondary Tool Bar immediately above the PDF. ...
      3. Choose Mark for Redaction and select OK when prompted by the pop-up window.

Per WIOA Policy 5.7 – Collection and Maintenance of Medical and Disability-Related Information

1. 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.
2. All questions pertaining or alluding to an individual's disability, including the basic "Do you have a disability, Yes/No" question or disclosures of SSDI as a potential source of income, must be asked on a separate form.
3. Medical and disability-related information must be maintained in a separate, secure location, such as a locked physical file or a password-protected electronic record.

When a document includes medical or disability information/questions:

Any form containing medical, or disability information uploaded to ASSET must be marked as confidential.

ASSET users cannot mark notes as confidential for UI customers. There is no workaround to mark confidential customer notes when the "Share with UI" checkbox has been selected. If a customer note with a selected "Share with UI" checkbox is marked as confidential, the system will generate the following message:

Please correct the following: "Record cannot be saved. A note that is marked confidential cannot be shared with UI".

Per § 38.41 Collection and maintenance of equal opportunity data and other information, each recipient must record race/ethnicity, sex, age, and where known, disability status of every applicant, registrant, participant, terminee, applicant for employment, and employee. Each recipient must also record each applicant, registrant, participant, and terminee's limited English proficiency and preferred language.

Job fair staff should encourage attendees to register at the Job Center of Wisconsin, JCW, where equal opportunity information is collected. If an attendee does not register on JCW, they likely do not fall into the categories above.

The WIOA Policy 5.7 applies to active and exited files. Confidential information needs to remain in a secured location that is separate from the regular participant files and for as long as your records retention policy requires it to be kept (but no less than three years).

The WIOA Policy 5.7 applies to active and exited files. Confidential information needs to remain in a secured location that is separate from the regular participant files and for as long as your records retention policy requires it to be kept (but no less than three years).
DWD will be enforcing WIOA Policy 5.7 for all files that became active on or after July 1, 2020.

Concerning exited files, DWD strongly recommends reviewing files that you have stored and retained according to your local records retention policy, but not less than three years. However, DWD will only be monitoring compliance with WIOA Policy 5.7 for exited files that became active on or after July 1, 2020.

DWD-DET requires keeping confidential medical/disability information in a sealed envelope in a locked drawer different from the participant's file location.

Assuming you have a paper file, utilize the Sharpie Method: Print your digital document, use a black sharpie (or black paper pieces) to cross-out/cover/hide the sensitive information, re-scan the document, and then save it as a new, redacted version. Make sure to shred the physical paper that you end up scanning.

Per the WIOA Policy 5.7 – Collection and Maintenance of Medical and Disability-Related Information

1. 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.
2. All questions pertaining or alluding to an individual's disability, including the basic "Do you have a disability, Yes/No" question or disclosures of SSDI as a potential source of income, must be asked on a separate form.
3. Medical and disability-related information must be maintained in a separate, secure location, such as a locked physical file or a password-protected electronic record.

When a document includes medical or disability information/questions:

1. The medical or disability information/questions can be eliminated and transferred to a supplemental form that collects medical or disability information/questions. Recipients and subrecipients must keep this confidential supplemental form in a secured, separate location.
2. If the Board decides to keep the document as-is, it must be filed on a secured, separate location.