Conflict of Interest

DCSS-POL-08-2 v.4

  1. POLICY STATEMENT
  2. The purpose of this policy is to provide employees and members of the public a working knowledge of the Department of Economic Security (DES) Division of Child Support Services' (DCSS) requirement that Employees do not access or view Title IV-D and/or Non-Title IV-D case information from the DCSS AZCARES, Tableau, and OnBase systems that contain case information for Title IV-D and/or Non-Title IV-D cases in which they may have a Personal Interest.
  1. APPLICABILITY
  2. This policy applies to all Arizona DCSS employees or contractors performing Title IV-D services.
  1. AUTHORITY
  2. Federal Authority
    42 USC 654 (A)(26) State plan for child and spousal support
    45 C.F.R. § 303.21 Safeguarding and disclosure of confidential information.
    45 C.F.R. § 307.13 Security and confidentiality for computerized support enforcement systems in operation after October 1, 1997.
     
    State Authority
    A.R.S. § 38-502 Definitions
    A.R.S. § 41-1959 Confidential information; permissible disclosure; rules; violation; classification
    A.A.C. R2-5A-501(B) Standards of Conduct
  1. DEFINITION
  1. STANDARDS
  2. Both federal and state laws require the DCSS to establish safeguards to protect against the unauthorized use or disclosure of confidential information in Title IV-D cases, 45 C.F.R. §307.13; A.R.S. §41-1959(F).
  3. A DCSS Employee with a Personal Interest in any Title IV-D or Non-Title IV-D case will not be involved in any aspect of any such case as part of official duties and will not access the case for any reason.
  4. Penalties - A violation of the Conflict of Interest Policy is a class 2 misdemeanor, A.R.S. §41-1959(E). Disciplinary action will be taken if it is found that an employee has released or misused information regarding a Title IV-D or Non-Title IV-D case.
  5. The DES has a separate administrative Conflict of Interest policy (DES 1-26-48) that all DCSS Employees are also required to review at least annually and/or when a change in circumstances results in a conflict of interest as defined in the DES policy. Employees should also disclose applicable conflicts as required by the department administrative policy. The DES Conflict of Interest policy can be found here DES-1-26-48.
  1. PROCEDURE
  • Employees complete the DCSS Conflict of Interest/Confidentiality Statement (CSE-0169A) form when hired, and annually thereafter. The form is available in the DES Document and Resource Center or by requesting it from DCSS HR.
  • If no identified conflicts exist, the employee shall indicate “None” in the Case Information Section.
  • If conflict(s) do exist, the employee shall enter as much known information on the Case Information Section.
  • If a new identified conflict arises during the year, the Employee must notify the DCSS of the new conflict of interest by completing an updated form.
  • The completed and signed form must be emailed to the Employee’s supervisor for review and signature.
  • The supervisor is responsible for meeting with the Employee to discuss any missing information and ensuring the Employee completes any blank fields in the form.
  • Once completed and signed by the supervisor, the instructions on the form should be followed. The form must be emailed to the DCSS HR email box, [email protected] and the DCSS Security Team, [email protected].
  • The DCSS HR team maintains a written electronic or physical record of the employee’s Conflict of Interest/Confidentiality Statement (CSE-0169A) form(s) in a secured file.
  • This policy is also supported by standardized work that identifies steps taken by the Enterprise Access Management Team (DCSS Security Team) and documents responsibilities, time frames, and required actions. Note: The standardized work document for this policy is being updated. When it is finalized, it will be linked in this policy.
 
  • Return to beginning of the Conflict of Interest Policy
Policy Revision Date: 05/04/2026
Policy Review Date: 05/04/2026
Policy Next Review Date: 05/04/2027

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