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Tribal Systems Contract, OCSE request for additional info

Hi folks,

It looks like this year is our turn to experience issues with approval of our contracts.  Specifically, we are being asked for the following by August 26th with regards to our Tribal Systems Contract (we are using Eaglesun Systems Inc.).  

 

·         A security and privacy clause in accordance with 310.15, the Federal Information Security Management Act, and the Privacy Act 

·         A data ownership clause. 

I am in need of some verbiage and am asking for help.  Can people with approved and OCSE “maintenance only”-funded Tribal Systems please email me OR respond to this post with:

  1. A sample of what they have included in their contracts with regards to systems and security and privacy clause as well as data ownership clause?  I’m thinking verbiage from a non-MTS system would be best…
  2. Example of what your Tribe has in your P&P that detail the requirements in 310.15 (2) (see below)

 

 

Normally this is something I would have our contract atty. work with us on but he is not available and so this is something I need to do.  Any tips or examples are appreciated.  I hope you all receive your FY22 funds without hiccups like these.  Best wishes to you all.  

Malinda Beiler   malindab@apiai.org

Aleutian Pribilof Islands Association, Inc. Tribal Child Support

 

2 Responses

  1. Hi Malinda:
    You are not the only one that received their budget back due to the contracts not having the ownership clause included, Lac du Flambeau has to supply the ownership and confidentiality clause in order for the budget to be accepted. Lac du Flambeau uses the state system which most of the security issues are solved, although we need a tribal level security policy. Good Luck in getting your contracts put together.

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