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45 CFR 309.80 Safeguarding and Tribal data system

Hi everyone,

Our Tribe is in the process of implementing a new database system for several of our programs, i.e., TANF, Enrollment, ICWA Social Services, etc.  The proposal is for the client and/or intake technician to enter the client’s address, phone number, etc. into a global database system that could potentially be viewed by other agencies within the Tribe.  For example, TANF caseworkers would see updated addresses for mutual TCSU clients.  Each “client” would have access to a web-portal that allowed them to update their address and contact information.   Tribal enrollment would have access to all persons enrolled as well as clients who apply for services.  Note:  Some of the clients are not enrolled because they are either enrolled in another federally recognized Tribe and/or they are noncustodial parents who have a child support case with the Tribe. 

45 CFR 309.80, requires safeguarding procedures under which the use or disclosure of personal information (names, addresses, phone numbers, etc.) received or maintained by the Tribal IV-D agency is limited to purposes directly connected with the administration of the IV-D program ( or titles IV-A and XIX with the administration of other programs or purposes prescribed by the Secretary in the regulations).  


Question for discussion:   Do you think that a Tribes’ global data base system for clients addresses, phone numbers, as described above,  would be considered a breach of safeguarding procedures for Tribal IV-D agencies? 


Thanks in advance to all who are willing to express an opinion on this topic. 




One Response

  1. I would not put client’s database anywhere in the tribe’s general database. I would keep it separate and maintained by the IV-D and or IV-B (ICW) program staff. In my case my department runs both programs.

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