INTERNAL DATA SHARING AGREEMENT EQUUS 2024.PDF

Rev.2020 
 
 
INTERNAL DATA SHARING AGREEMENT    DSA No.       
 
This Internal Data Sharing Agreement (the “Agreement”) will become final and effective on the date of 
the final signature, by and between Maricopa County administered by its Human Services Department 
(“Public Official”) and Arbor E&T, LLC dba Equus Workforce Solutions (“EWS”) (“Agent”). Public Official 
and Agent are referred to herein together as the “parties” and individually as “party.” 
RECITALS 
 
Arizona Department of Economic Security (“AZDES”) Unemployment Insurance program (“UI”) discloses 
certain confidential Unemployment Compensation (“UC”) information to Maricopa County, Jack Sellers is 
the Chief Elected Official and is recognized therefore as a public official under the meaning described in 20 
C.F.R. §603.2. Maricopa County is authorized to receive confidential UC information from UI pursuant to 20 
C.F.R. §603.5(e). 
Maricopa County desires to share confidential UC information with Agent to carry out the functions of Youth 
Services Provider and One-Stop Operator under the Workforce Innovation and Opportunity Act. Maricopa County 
designates Agent as Maricopa County’s agent authorized to access and receive confidential Unemployment 
Compensation (UC) information for the purposes stated herein. 
TERMS AND CONDITIONS 
 
In exchange for the promises set forth herein and for other good and valuable consideration, the receipt 
and sufficiency of which are hereby acknowledged, the parties hereby agree as follows: 
1. The term “confidential UC information” means any information in the records of a State or State 
UC agency (i.e. UI) that pertains to the administration of the State UC law. This term includes State 
wage reports collected under the Income and Eligibility Verification System (IEVS) that are obtained 
by the State UC agency for determining UC monetary eligibility or are downloaded to the State UC 
agency’s files as a result of a cross match but does not otherwise include those wage reports. The 
term does not include information in a State’s Directory of New Hires, but does include any such 
information that has been disclosed to the State unemployment agency for use in the UC program. 
It also does not include the personnel or fiscal information of a State UC agency.   
2. Purpose and duties. Maricopa County may disclose or authorize access to confidential UC 
information in the form of quarterly wage data stored within the Arizona Job Connection (AJC) 
Internet application. This will include actual amount earned (in dollars) by quarter. The requested 
earnings include three quarters prior to participation in the program(s) and up to five quarters after 
exiting from the program(s) to the extent the wages are available.  The information will be made 
available to Agent for use in performance of Agents’ duties under this Agreement and which are 
consistent with 20 C.F.R. §603.5(e). Agent’s duties shall be limited to viewing and sharing 
information for eligibility verification for enrollment into Workforce Innovation Opportunity Act 
(WIOA) program services.  Agent will also utilize UI Wage records to meet performance reporting 
requirements and to cooperate with DOL reporting. In addition, agent will also verify and sign off 
on UI Benefits/approved training weekly forms. Confidential UC information shared under this 
Agreement shall not be used for any purpose other than those described in this Agreement. 
3. Confidentiality. To maintain the security of confidential UC information consistent with the 
requirements of 20 C.F.R. §§ 603.9 and 603.10, Agent agrees Agent will: 
a. Use the disclosed confidential UC information only for purpose authorized by law as needed 
to perform the legitimate duties of Maricopa County, consistent with this Agreement.

Rev.2020 
 
 
b. Appropriately safeguard confidential UC information. 
c. Store confidential UC information in a place physically secure from access by unauthorized 
persons, including storing confidential UC information maintained in electronic format in 
such a way that it is reasonably secure from access by unauthorized persons. 
d. Use appropriate security measures and undertake precautions to ensure that only 
authorized Agent personnel are given access to confidential UC information. 
e. Ensure confidential UC information is disclosed only to those with a need to access it for 
purposes listed in this Agreement or any other applicable agreement between Maricopa 
County and AZDES, or if required by law. 
f. 
Instruct all Agent’s personnel with access to confidential UC information about the 
confidentiality requirements of 20 C.F.R. Part 603, Subpart B, and the sanctions specified 
by Arizona law for unauthorized disclosure of information. See A.R.S. §23‐722.01(G) (civil 
penalty of $1,000 for unauthorized disclosure of confidential UC information). 
g. Dispose of confidential UC information after its purpose is served by either returning the 
confidential UC information to AZDES or destroying the confidential UC information 
consistent with the records retention schedules required by law. Disposal includes deletion 
of personal identifiers by AZDES in lieu of destruction. 
h. Maintain a system sufficient to allow AZDES, the U.S. Department of Labor, or any other 
authorized entity, to perform an audit of compliance with the requirements of 20 C.F.R. § 
603.9(b)(1)(vii) 
i. 
Comply with on-site inspections by AZDES, the U.S. Department of Labor, or the Public 
Official to assure that the requirements of the State's law and the agreement or contract 
required by this section are being met per 20 C.F.R. §603.10 (b)(vi) 
 
4. Term. The term of this Agreement shall be the same as the term of Data‐sharing Agreement Number 
245501 between AZDES’ Division of Employment and Rehabilitation Services and the Public 
Official unless earlier terminated in accordance with this Agreement. 
5. Termination. This Agreement shall terminate immediately upon any violation by Agent of the 
confidentiality and nondisclosure provisions herein. Maricopa County may terminate this 
Agreement at its sole discretion, at any time, through written notice to Agent. 
6. Cancellation for Conflict of Interest. This Agreement is subject to cancellation pursuant to A.R.S. 
§ 38-511, the pertinent provisions of which are incorporated herein by reference. 
 
7. Choice of law. This Agreement shall be constructed under the laws of the State of Arizona, 
notwithstanding any conflict of law principles. 
 
IN WITNESS WHEREOF, the parties have executed this Agreement as of the date written below. 
 
PUBLIC OFFICIAL: MARICOPA COUNTY 
AGENT: ARBOR E&T, LLC D/B/A Equus 
Workforce Solutions 
By   
 
By   
 
Name: Jack Sellers 
Name: 
Title: Chairman, Board of Supervisors 
Title: 
Date:   
 
Date:

Rev.2020 
 
 
_________________________________________________________________________  
Lesa Manning, DERS Data Sharing Unit Supervisor                                                      Date 
 
__________________________________________________________________________  
Anna Hunter, DERS Assistant Director                                                                            Date 
 
__________________________________________________________________________  
Dan Wilkins, DES Chief Information Security Officer                                                    Date