CTCLink: Data Privacy Attestation

On July 8, 2022, the State implemented a "Data Privacy MOU" and "Data Privacy Attestation" to the CTCLink log-in process.  Our contracts require the State to give the Union notification at least 21 days in advance of any change that impacts members' working conditions. In this case, they did not do that and made the change without negotiating or meeting their obligation under the law.  Failing to following this process puts our members in a terrible situation because they are being required to attest to the State's Data Privacy Attestation in order to access CTCLink.  WPEA has filed a Demand to Bargain and notified the Office of Financial Management that we do not believe that any of our represented members have been provided the adequate training on the policies and procedures around data privacy, or have been allowed the opportunity to ask questions or seek clarification.  
 
At this time, WPEA is giving the following advice to our members:
 
If you have already agreed to the attestation: If you have not been adequately trained and allowed ample opportunity to answer any and all questions that you have, then you have attested to something that is not true or accurate.  This attestation is threatening you with civil/criminal litigation, or termination of your employment, and the WPEA recommends that you immediately notify your Human Resources Office, as well as your chain of command, of this discrepancy.  That notification should be in writing.  Here is an example of what that notification should include:
 
I was required to attest to the CTCLink data privacy agreement today.  I could not complete my assigned work duties without doing so.  My Union has advised me that I need to let both HR and my chain of command know that I have attested to something that is not true and accurate.  I have not been provided adequate training on all policies, procedures and guidelines, nor have I been given an ample opportunity to have any and all of my questions about my responsibilities answered.  
 
If you have not agreed to the attestation:  This attestation is threatening you with civil/criminal litigation, or termination of your employment, and the WPEA cannot advise you to agree to it until your College has met its obligation to adequately train you on ALL policies, procedures and guidelines, as well as give you ample opportunity to ask questions.  We recognize that this puts you in a difficult position if you need to regularly access CTCLink to complete your work duties.  If you run out of "Skip" options (you can skip a total of 5 times), and you are not comfortable attesting to this, we are recommending that you send the following email to your HR department and your chain of command:
 
CTCLink is asking me to attest to something that is not true and accurate.  I am not comfortable doing so until I have been adequately trained on all polices, procedures and guideline for data privacy, as well as given ample opportunity to answer any and all of my questions.  Until I have been adequately trained and afforded the opportunity for questions, I'm unable to log in to CTCLink and complete my work duties.  Please advise me on how to proceed with this.  
 
If you have specific circumstances you would like to discuss with your Union rep, please reach out to them directly.  WPEA will keep you informed on the status of our bargaining around this issue. 


As of 2:30 today, we were informally notified that the implementation of this is being pushed back to December. We strongly advise all members to continue as described here, until such time as this is documented and the change goes effective in CTCLink.