3.2.1- Conflict of Interest Policy

State Authority:

Wyoming Statute

Wyo. Stat. § 9-21-101 - Data Policies

Wyo. Stat. § 20-4-162 - Nondisclosure of information in exceptional circumstances

Wyo. Stat. § 35-32-102(c) - Genetic Testing; prohibitions; exceptions

Wyo. Stat. § 40-12-502 - Computer Security Breach; Notice to Affected Persons

Wyoming Child Support Enforcement Rule

  Chapter 13 - Safeguarding and Disclosure of Confidential Information

Purpose

This purpose of this policy is to establish the rules related to a "conflict of interest" as it relates to the Wyoming Child Support Program (CSP).

Definition(s)

A. Conflict of Interest

A conflict of interest arises when a CSP worker or contractor, hereafter known as the employee, knowingly has access to or accesses a CSP case and payment information involving the employee, a co-worker, friend, acquaintance, or relative, and as such, may receive, or have the appearance of receiving, discriminatory treatment if the employee continues to have access to the case.  The appearance of conflict of interest can be as damaging or detrimental  as an actual conflict. 

Scope

This policy applies to all Wyoming Child Support Program child support workers including the State Office, State Disbursement Unity and all field staff including private contractors, public entities and any Clerk of Court staff that have access to POSSE or other child support applications. 

Policy

All child support workers including the State Office, State Disbursement Unit and all field staff including private contractors, public entities, any Clerk of District Court employee, and all Wyoming Department of Enterprise Technology Services employees with access to Wyoming Child Support Case information either logically or physically, are required to complete the WYDSA-003-Conflict of Interest Disclosure Form:

• Annually;

• As part of the "New Hire" documentation; and

• Upon discovery of any new actual or possible "Conflict of Interest"

All completed WYDSA-003-Conflict of Interest Disclosure forms are to be scanned and emailed to DFSPossehelp@wyo.gov.

Review

This policy shall be reviewed at a minimum, ever three (3) years or when changes are made to W.S. 7-19-201(a) or to IRS Publication 1075 background check requirements prior to the three (3) year review.

Responsible Party

The Child Support Program IT Security Officer is responsible for making sure these policies are maintained so as to meet federal, state, and agency regulations and requirements

Forms and Documents

WYDSA-003-Conflict of Interest Disclosure Form

Training

Training shall be maintained by CSP and made available to each employee of...

• The Child Support Program;

• Any contractor and subcontractor doing business with CSP whose job duties require access to logical and/or physical CSP FTI and PII;

• Any contractor and subcontractor doing business with another Wyoming state agency whose job duties require logical and/or physical CSP FTI and PII;

• The Wyoming Clerks of District Court whose job duties require logical and/or physical access to CSP FTI, and PII; and

• Any other Wyoming agency doing business with CSP whose job duties require access to logical and/or physical CSP FTI and PII.