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thirty (30) days of employment; (2) thereafter, providing annual refresher <br />training or reminders of the PH privacy and security safeguards to all <br />Contractor's staff; (3) maintaining records indicating each Contractor's <br />staff name and the date on which the privacy and security awareness <br />training was completed; and (4) retaining training records for a period of <br />three (3) years after completion of the training. <br />Contractor agrees to provide documented sanction policies and <br />procedures for Contractor's staff who fail to comply with privacy policies <br />and procedures or any provisions of these requirements, including <br />termination of employment when appropriate. <br />Contractor agrees that all Contractor's staff performing services under this <br />Agreement sign a confidentiality statement prior to accessing PH and <br />annually thereafter. The signed statement shall be retained for a period of <br />three (3) years, and the statement include at a minimum: (1) general use; <br />(2) security and privacy safeguards; (3) unacceptable use; and (4) <br />enforcement policies. <br />Contractor agrees to conduct a background check of Contractor's staff <br />before they may access PH with more thorough screening done for those <br />employees who are authorized to bypass significant technical and <br />operational security controls. Contractor further agrees that screening <br />documentation shall be retained for a period of three (3) years following <br />conclusion of the employment relationship. <br />g. Contractor agrees to conduct periodic privacy and security reviews of work <br />activity, including random sampling of work product by Contractor's staff <br />by management level personnel who are knowledgeable and experienced <br />in the areas of privacy and information security in the administration of <br />County's programs and the use and disclosure of PII. Examples include, <br />but are not limited to, access to data, case files or other activities related <br />to the handling of PII. <br />h. Contractor shall ensure that PI is used and stored in an area that is <br />physically safe from access by unauthorized persons at all times and <br />safeguard PH from loss, theft, or inadvertent disclosure by securing all <br />areas of its facilities where Contractor's staff assist in the administration of <br />the County's programs and use, disclose, or store PII. <br />Contractor shall ensure that each physical location, where PII is used, <br />disclosed, or stored, has procedures and controls that ensure an individual <br />who is terminated from access to the facility is promptly escorted from the <br />facility by an authorized employee of Contractor and access is revoked. <br />Template Version Date—August 26,1016 <br />Page 7 <br />