Advise on Data Privacy Issues Related to Workforce Portal
Assist a non-profit reducing recidivism rates by reviewing their informed consent practices, data sharing processes, and client data retention practices for their Workforce Portal.
Referred by:
FreeWorld is rapidly expanding partnerships with workforce development boards and American Job Centers (AJCs) across multiple states. In these partnerships, they serve clients jointly, with each entity contributing resources and programming. To streamline client management and enhance their service offerings, they’ve developed a digital “Workforce Portal.” This portal allows them to: (i) share relevant client data (with their consent) between organizations; (ii) track clients’ program progression; (iii) and monitor post-program outcomes for up to five years.
The FreeWorld team is now seeking assistance from an attorney to assess their current informed consent practices, data sharing processes, and client data retention practices to ensure they are compliant with GDPR (if applicable) and applicable U.S. state privacy laws, with a specific focus on states like Colorado that have implemented new regulations (e.g., CPA). They currently operate and/or are soon launching in the following states: (i) New Jersey; (ii) Colorado; (iii) Nevada; (iv) Minnesota; (v) Texas; (vi) Arizona; and (vii) California. However, they plan to further roll out their programming across the country over time. If an attorney cannot assist with every state listed, they would appreciate guidance in as many jurisdictions as the attorney has the expertise to handle.
If possible, they would also appreciate assistance identifying any potential compliance gaps or risks related to data sharing across state lines, particularly where regulations differ.