A few months ago, DWS learned that there is an organization called "The Work Number" that provides employment verification services to employers, human resources staff, State and County social service agencies and other publicly funded agencies. The service is managed by the TALX Corporation and is accessible via the Internet. WDB staff asked if this service could be used as an acceptable resource for documentation and verification of supplemental employment data. There may be other entities that provide similar services.
The Work Number verifies employment histories and status for individuals employed by a large number of private and public sector employers. It was originally created as a way for private sector employers to exchange employment history information about prospective employees. The Work Number has expanded to allow representatives from a variety of agencies, including WIA, to use the service. In February 2006, there were two levels of service: Express, which is free and Enhanced which provides more detailed information for a fee.
DWS had a number of concerns regarding this service because it requires the disclosure of social security numbers to obtain employment information. Staff consulted with U.S. DOL, other States, DWD Legal Counsel and the TALX Corporation's sales representative. Based on these discussions DWS has come to the following conclusions:
1. There is no specific prohibition under current State or Federal confidentiality laws that addresses the sharing of a social security number with an organization that has been granted permission by employers to disclose information about its employees.
2. Local staff who subscribe to services such as The Work Number do so at their own risk. DWS will not intercede or advocate on behalf of a local board if the service fails to provide promised services to the WDB.
3. Most citizens likely have no idea that such a service exists and that it is accessible by a wide variety of program operators.
4. Unemployment Insurance representatives in other States that have received employment information from these resources indicate that the earnings information isn't reliable. Employers are not compelled to be truthful when they disclose employee information to these organizations.
5. Organizations that provide these services can be used by WIA and TAA staff as a resource for obtaining supplemental employment data and documentation on exited participants, subject to the conditions listed below:
- Release of information forms signed and dated by program participants must specifically reference the organization that will be contacted and what information will be exchanged. The participant must be advised that this contact will occur and why.
- All information must be treated the same way as other confidential information that is stored locally in participant folders.
- A copy of the signed and dated release, as well as any employment information obtained, must be placed in the participant folders and made available for DWS monitoring and validation, since this data will be used in performance measure computations. The verification from the service must contain the participant's name, dates of employment and the employer's name and contact information (mailing address is acceptable).
- While earnings information is often provided as part of the verification process, only UI Wage Record and Wage Record Interchange System (WRIS) data will be used for computing earnings-related performance measures. Disputes over performance results will be resolved based on data obtained from the UI Wage Record and WRIS, regardless of reported earnings obtained through alternative resources such as The Work Number.