Operational Roles and Responsibilities

The Operating Group and Data Integration Hub share responsibility in hosting and operating P20 WIN, with the Operating Group serving as the lead agency responsible for the operations and the Data Integration Hub responsible for hosting, linking and transmitting Data.

The Office of Policy and Management serves as the Operating Group for P20 WIN. The Department of Labor serves as the Data Integration Hub and provides data matching services for approved data requests.

Operating Group

The Operating Group facilitates smooth and efficient operation of P20 WIN for the benefit of the Participating Agencies and the greater benefit of the State of Connecticut. The Office of Policy and Management serves as the Operating Group for P20 WIN.

Responsibilities:

1. Develop a budget in collaboration with Participating Agencies to support costs associated with ongoing operation, maintenance and improvement of P20 WIN.
2. Develop and submit a budget request for the Operating Group and the P20 WIN Data Sharing process costs, based on recommendations from the Executive Board.
3. Develop legal documents to distribute funds for the P20 WIN Data Sharing system as defined in the approved budget.
4. Provide financial back-office support for managing the receipt and distribution of funds, such as costs related to data requests, according to the fully executed Data Sharing Agreements.
5. Provide program management to support the continued operation, maintenance and improvement of the Data Integration Hub as a resource for the Participating Agencies and the State.
6. Serve as the primary point of contact for incoming Data Sharing Requests and coordinate communication between Data Recipients and the Participating Agencies as necessary to support the completion of documents required by the Data Sharing process.
7. For each approved DSA, facilitates communication between the Data Recipient, Participating Agencies and the Data Integration Hub to ensure the process for fulfilling the terms of the DSA are progressing.
8. Provides meeting space and materials for meetings as needed.
9. Coordinate and prepare reports on Data Sharing activities and outcomes for legislative and funding stakeholders.
10. Facilitates any audits that are requested and required by any Party.
11. Implements the fee policy from Data Recipients.

Data Integration Hub

The Department of Labor serves as the Data Integration Hub and provides data matching services for approved data requests.

Responsibilities:

1. Enter into Data Sharing Agreements with Participating Agencies and Data Recipients for approved data requests.
2. Maintain a secure server that supports approved data matching software and/or methods so that matches can be conducted at optimum speed, privacy, security and accuracy.
3. Retain data matching software, implement procedures, and document data matching methods that have been approved by the Data Governing Board for the purpose of facilitating 4. Data requests using the Data Integration Hub.
4. Utilize the data matching software and/or methods approved by the Data Governing Board to conduct matches between Data sets from participating agencies for approved Data Sharing Requests.
5. Comply with the provisions of the applicable federal and state data security, confidentiality and privacy requirements. Nothing may be construed to allow the Data Integration Hub to maintain, use, disclose, or share data in a manner inconsistent with applicable federal and state laws and regulations or inconsistent with the terms of the eMOU.
6. Transmission and storage of all Data received by a Data Integration Hub shall be in full compliance with all state and federal legislative and regulatory requirements related to information security, including but not limited to, commercially-available and widespread precautionary measures, such as firewall implementation, virus scanning, security access control software, encryption of data as it leaves the data boundary, secure tunnels and limitation of physical access to confidential information and personally identifiable information. Upon the written request from a Party, the Data Integration Hub shall disclose and permit a Party to inspect and audit data confidentiality, privacy or security protocols, practices, and policies to ensure compliance with the terms of this E-MOU and applicable federal and state laws.
7. The Data Integration Hub shall:
   1. Only utilize Data received to fulfill an authorized Data Sharing Request pursuant to a Data Sharing Agreement in accordance with applicable federal and state laws and regulations. Authorization given by Participating Agencies via a Data Sharing Agreement to the Data Integration Hub to use Data for one purpose does not confer approval to use it for any other purpose.
   2. Not re-disclose, duplicate or disseminate (except as necessary to fulfill the stated purpose of a particular Data Sharing Agreement), or convey ownership of any portion of the shared Data and records in any media format without the prior written approval from the particular Participating Agency which provided the Data.
   3. Transmit all Data via a secure connection approved by the State Information Technology Policy, such as a Virtual Private Network (VPN) or Secure File Transfer Protocol (SFTP) connectivity.
   4. Only transmit, via electronic mail, Data Sets that have been appropriately de-identified according to applicable privacy, confidentiality, and security requirements, as outlined in the Data Sharing Agreement. No protected Data will be transmitted via electronic mail.
   5. Take all necessary steps to ensure that any protected identifiable information or other identifiable or confidential Data in the possession or control of the Data Integration Hub are destroyed in a timely fashion as provided in the Data Sharing Agreement; and
   6. Abide by policies and procedures recommended by the Data Governing Board and adopted by the Executive Board.

Participating Agencies

The State Department of Education (SDE), the Office of Early Childhood (OEC), the Department of Labor (DOL), the Connecticut State Colleges and Universities (CSCU), the University of Connecticut (UCONN), the Connecticut Conference of Independent Colleges (CCIC), the Department of Social Services (DSS), the Department of Children and Families (DCF), the Office of Higher Education (OHE) and the Connecticut Coalition to End Homelessness (CCEH) are actively collaborating to support the P20 WIN System. The system is designed with flexibility to expand and include additional state agencies or organizations such as the Department of Public Health and the Department of Housing. The process for an agency or state organization to join P20 WIN is defined in the “How to Become a Participating Agency” within this manual.

Each participating agency is responsible for the data that reside in their respective systems. The Data Governance Policy does not affect data that is not shared through P20 WIN. Rather, this policy covers only the data that is shared between organizations both at the unit and aggregate level through P20 WIN. While data will be transported, matched and eventually stored electronically, this manual covers the use of shared data in reports and documents whether electronic or in print.