HomeMy WebLinkAboutAgreement A-24-373 Career Nexus MOU.pdf 00 Agreement No. 24-373
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FREER NE S
Advancing People,Business&Comity
Memorandum Of Understanding
Agreement between Career Nexus and
The County of Fresno
PARTIES:
This Memorandum of Understanding ("Agreement") is made and entered into by and between the Career
Nexus (also referred to as "CN"), a nonprofit work connection internship program, whose address is 700 Van
Ness Avenue, Fresno, CA 93721 and The County of Fresno ("County") whose address is 2281 Tulare Street,
Suite 304, Fresno CA,93721.CN and County may be referred to in this agreement individually as a "Party" or
collectively as "the Parties".
PURPOSE:
Through the Career Nexus Internship Program, the Parties desire a more effective and engaged workforce by
providing a work-based learning experience through internships. In pursuit of this goal,this Agreement is to
establish the parameters of responsibilities for the implementation of these internships.
TERM:
This Agreement is effective upon the date signed and executed by the Parties for a standard term of three
years with two optional one-year extensions.
TERMINATION:
• Non-Allocation of Funds-The terms of this Agreement, and the services to be provided thereunder,
are contingent on the approval of funds by the appropriating government agency. Should sufficient
funds not be allocated,the services provided may be modified, or this Agreement terminated at any
time by giving CN (30) days advance written notice.
• Breach of Contract—County or CN may immediately suspend or terminate this Agreement in whole or
in part, where in the determination of County there is:
1) A failure to comply with any term of this Agreement;
2) A substantially incorrect or incomplete report submitted to County.
• Without Cause- Under circumstances other than those set forth above, this Agreement may be
terminated by CN or County, upon the giving of three (3) months advance written notice of an
intention to terminate.
STATEMENT OF WORK AND RESPONSIBILITIES:
The Parties will work together to provide a work-based learning experience for interns through the Career
Nexus Internship program.This program is focused on providing quality internship opportunities to diverse
young adults between the ages of 18 and 28 while developing a valuable employee applicant pool for the
County. Any County department can provide internships as needed.
RECRUITMENT AND SUPERVISION:
• County shall retain exclusive control and oversight over the recruitment and acceptance of intern(s)to
the County.
700 Van Ness#116, Fresno, CA 93720 ■ 559-272-3880 ■ connect@careernexus.org
careernexus.org
• The County shall be solely responsible for the supervision and control of the intern(s) in the
performance of the intern(s)'s work pursuant to this Agreement and shall solely control the method,
manner and means of the intern(s)'s performance of such work.
CAREER NEXUS SHALL,WITH RESPECT TO THE COUNTY:
• Serve as the County's point of contact for all project-related questions and concerns.
• Assess, prepare, and match young adults to the County. CN will also provide coaching for the intern
during the internship.
• Assume the role as the "Employer of Record"for each intern and provide payment for the County's
intern(s). CN shall also provide workers compensation insurance for each intern at all times during the
internship.
• Complete a 60-90-minute onboarding process to review, discuss, and agree on internship expectations
and community values. During this session, CN will assist the County in the design of the County's
internship project.
COUNTY SHALL,WITH RESPECT TO CAREER NEXUS:
• Have a maximum of ten interns per cohort. A new cohort will not begin until all interns have
completed their cohort.
• Participate in two check-in sessions per month facilitated by CN to ensure the internship(s) are going
well and discuss any opportunities for improvement.
• Comply with all OSHA and Cal-OSHA safety standards along with the additional safety requirements
listed in the Addendum.
• Ensure that interns will work directly with assigned staff.
COUNTY SHALL,WITH RESPECT TO EACH INTERN:
• Provide interns with an orientation to the work setting upon initiation of each new internship work
experience, as appropriate.
• Provide interns with meaningful work assignments which, within the confines of employer needs and
timetables,will enhance and complement the interns' abilities.
• Grant interns reasonable access to the premises for the purpose of working toward the mutual goals
enumerated herein.
• Grant CN and its representatives reasonable access to County's premises, work sites, and the interns,
upon prior request. County shall, within the limits of its resources, provide whatever equipment,
supplies, and assistance necessary for the care of County's customers in the course of CN's interns'
learning experience and consistent with County's purpose. Notwithstanding anything else in this
Agreement,the County has no obligation to provide free parking to any interns or other persons
connected with CN.
• County shall reserve the absolute right to review, authorize, and in its sole discretion, deny access or
admission by any intern or CN representative into County facilities.
• Appoint at least one employee of the County with the appropriate skills, ability, and training to
supervise the intern while on the premises of the County or in the performance of work for the
County.
• Provide and explain to the intern all applicable County protocols and procedures necessary for the
Intern's work for County, including those related to the health, safety, and security of the Intern and
County's clients and provide Intern with requisite training on the foregoing.
• Evaluate the intern's work performance once during each internship. Discuss the evaluation with the
intern and complete the internship evaluation form.
• County shall agree to allow access to existing dining room space for interns' break and meal periods.
CN's interns shall be responsible for their own meals; no special arrangements for food will be made.
• Exercise flexibility to accommodate schedule when available.
• Complete an annual Program evaluation report form, which shall be provided by Career nexus.
• Notify Career Nexus immediately if there are any problems or concerns regarding the Intern or Intern's
work or activities.
• Be responsible for participating in the biweekly evaluation of his or her supervised internship
experience.
WORK SCHEDULE
• Assign interns' work experience schedules reasonably and fairly.
• Interns MUST be provided with a minimum, 30-minute unpaid rest period, uninterrupted if the intern
is working more than five hours in a day.This rest period MUST be taken before the intern's 5t" hour.
• Interns are prohibited from working more than 7.5 hours in a day.
• Interns are prohibited from working OVERTIME for any reason.
• Any overtime hours accrued by the intern will be expensed back to the County.
PERMANENT EMPLOYMENT:
• Although a desired outcome of CN, neither the County nor the intern is bound by this agreement to
offer or accept an intern's permanent employment with the County. CN placements are not intended
to displace current full/part-time permanent employees of the County.
EMPLOYMENT RELATIONSHIP:
CN (or any of its officers, agents, subcontractors, interns, or employees), shall have absolutely no right to
employment rights and benefits available to County employees. CN shall be solely liable and responsible for
providing to, or on behalf of, its employees all legally-required employee benefits. In addition, CN shall be
solely responsible and hold County harmless from all matters relating to payment of CN's employees, including
compliance with Social Security,withholding, and all other regulations governing such matters.As between
County and CN, should the interns be deemed employees by any governmental or regulatory body,the interns
shall be the employee of CN for Worker's Compensation purposes and shall be a member of CN's workforce
for purposes of the Health Insurance Portability and Accountability Act (HIPAA). In consideration of the
benefits the CN derives from this Agreement and subject to the provisions herein, CN shall not consider the
interns to be employees of, or claim the interns are employees of,the County for the purposes of determining
liability for any and all costs and expenses, including attorney fees and court costs, damages, liabilities, claims
and losses occurring or resulting to the CN or to any person, firm or corporation who may be injured or
damaged by any act or failure to act, of any intern or person participating in or connected with the programs
that are the subject of this Agreement. It is acknowledged that during the term of this Agreement, CN may be
providing services to others unrelated to County or to this Agreement.
FINANCIAL AGREEMENT:
• Sponsorship Cost Policy:
• All activities, resources and services provided by both parties shall be at no cost to the other.
• Any expenses incurred by either party in the performance, delivery, or execution of the terms
of this Agreement shall be sole responsibility of the encumbering party.
• Any overtime pays or other additional pay beyond the scope of this agreement will be paid by
the County.
• Financial Liability:
• Each party holds the other free of any financial commitment through the fulfillment of the
terms of this Agreement.
AUDITS AND INSPECTIONS:
CN shall at any time during business hours, and as often as County may deem necessary, make available to
County for examination all of its records and data with respect to the matters covered by this Agreement. CN
shall, upon request by County, permit County to audit and inspect all such records and data necessary to
ensure CN compliance with the terms of this Agreement.
MODIFICATION:
Any matters of this Agreement may be modified from time to time by the written consent of all the parties
without, in any way, affecting the remainder.
NON-ASSIGNMENT:
Neither party shall assign, transfer or subcontract this Agreement nor their rights or duties under this
Agreement without the written consent of the other party.
INDEMNITY:
CN shall indemnify, save, hold harmless and at the County's request, defend the County (including its officers,
agents, employees, and volunteers)from any and all costs and expenses, including attorney fees and court
costs, against all claims, demands, injuries, damages, costs, expenses (including attorney fees and costs),fines,
penalties, and liabilities of any kind to the County, CN, its interns, or any third party that arise from or relate to
the performance or failure to perform by CN (or any of its officers, agents, subcontractors, interns, or
employees) under this Agreement.The County may conduct or participate in its own defense without affecting
CN's obligation to indemnify and hold harmless or defend the County. Additionally, CN agrees to indemnify
County for Federal, State of California, and/or local audit exceptions resulting from noncompliance herein on
the part of CN.
• This section survives the termination of this Agreement.
INSURANCE:
• CN shall comply with all the insurance requirements in Exhibit A to this Agreement.
SPECIAL ACCOMODATION:
• The Americans with Disabilities Act of 1990 (ADA) requires that employers with fifteen or more
employees to make reasonable accommodations in the workplace for employees with disabilities.
Accommodation is to be made on a case-by-case basis and may not be required when costs create an
undue hardship.
• The employee or intern is responsible for providing personal accommodation, such as hearing aids,
wheelchairs, and personal attendants. In most cases, it is the County's responsibility to provide on-site
job accommodation for an employee who has a disability.
COMPLIANCE WITH LAWS:
Each Party shall perform this Agreement in compliance with all applicable laws, regulations, rules, and
ordinances and represents that it shall have obtained all licenses and permits required by law to engage in the
activities necessary to perform its obligations under this Agreement.
CONFIDENTIALITY:
All services performed by CN under this Agreement shall be in strict conformance with all applicable Federal,
State of California and/or local laws and regulations relating to confidentiality, including but not limited to,
California Revenue and Taxation Code sections 408,408.2,451, 481 and California Government Code sections
6254(i) and 6254.21(a). CN shall submit to County's monitoring of said compliance with all State and Federal
statutes and regulations regarding confidentiality. CN shall ensure that no list of persons receiving services
under this contract is published, disclosed, or used for any other purpose except for the direct administration
of the program or other uses authorized by law that are not in conflict with requirements for confidentiality.
CN shall submit to County's monitoring of said compliance with all State of California and Federal statutes and
regulations regarding confidentiality.
NON-DISCRIMINATION:
The County and CN agree that neither will discriminate unlawfully against a beneficiary of services in the
performance of this Agreement based on gender, race, color, national origin, creed, religion,veteran's status,
or disability.The parties agree to follow all applicable federal, state, and local laws and regulations, including
but not limited to laws prohibiting discrimination and harassment.
NOTICES:
The persons having authority to give and receive notices under this Agreement and their addresses
include the following:
1. Department of Human Resources, County of Fresno, 2220 Tulare St, 141" Floor, Fresno, CA 93721
Email: HREmploymentServices@fresnocountyca.gov
2. Career Nexus, 700 Van Ness Avenue, Fresno, CA 93721
Email: connect@careernexus.org
Any and all notices between County and CN provided for or permitted under this Agreement shall be
in writing and shall be deemed duly served when personally delivered to one of the parties, or in lieu
of such personal service, when deposited in the United States Mail, postage prepaid, addressed to
such party. For all claims arising from or related to this agreement, nothing in this agreement
establishes, waives, or modifies any claims presentation requirements or procedures provided by law,
including but not limited to the Government Claims Act (Division 3.6 of Title 1 of the Government
Code, beginning with section 810).
VENUE AND GOVERNING LAW:
The parties agree, that for the purposes of venue, performance under this Agreement is to be in
Fresno County, California. The rights and obligations of the parties and all interpretation and
performance of this Agreement shall be governed in all respects by the laws of the State of California.
SEVERABILITY:
The provisions of this Agreement are severable.The invalidity or unenforceability of any one
provision in the Agreement shall not affect the other provisions.
AUTHORITY:
Each individual executing this Agreement on behalf of CN represents and warrants that such
individual is duly authorized to execute and deliver this Agreement on behalf of CN and that this
Agreement is binding upon CN in accordance with its terms.
ENTIRE AGREEMENT:
• This Agreement, including any other documents referred to herein which form a part hereof,embodies
the entire agreement and understanding of the Parties.This Agreement supersedes all prior
agreements and understandings between the Parties with respect to the subject matter of this
Agreement.
• This Agreement constitutes the entire understanding of the Parties with respect to their relationship
and may be modified only by a written agreement signed by each Party.
IN WITNESS WHEREOF,
the parties to this Agreement through their duly authorized representatives have executed this Agreement on
the days and dates set out below,and certify that they have read, understood,and agreed to the terms and
conditions of this Agreement as set forth herein.
The effective date of this Agreement is the date of the signature last affixed to this page.
r
6/24/24
Kurt Madden Date
Career Nexus CEO
-7/g 1 Z"
Signature Date
Fresno County, Nathan Magsig, Board Chairman
ATTEST:
BERNICE E.SEIDEL
Clerk of the Board of Supervisors
County of Fresno,State of California
By Deputy
Exhibit A
Insurance Requirements
1. Required Policies
Without limiting the County's right to obtain indemnification from CN or any third parties, CN, at its sole
expense,shall maintain in full force and effect the following insurance policies throughout the term of
this Agreement.
(A) Commercial General Liability. Commercial general liability insurance with limits of not less than
Two Million Dollars ($2,000,000) per occurrence and an annual aggregate of Four Million Dollars
($4,000,000).This policy must be issued on a per occurrence basis. Coverage must include
products/completed operations, property damage, bodily injury, personal injury, and advertising
injury. CN shall obtain an endorsement to this policy naming the County of Fresno, its officers,
agents, employees, and volunteers, individually and collectively, as additional insureds, but only
insofar as the operations under this Agreement are concerned. Such coverage for additional
insureds will apply as primary insurance and any other insurance, or self-insurance, maintained
by the County is excess only and not contributing with insurance provided under CN's policy.
(B) Automobile Liability. Automobile liability insurance with limits of not less than One Million
Dollars ($1,000,000) per occurrence for bodily injury and for property damages. Coverage must
include any auto used in connection with this Agreement.
(C) Workers Compensation. Workers compensation insurance as required by the laws of the State
of California with statutory limits.
(D) Employer's Liability. Employer's liability insurance with limits of not less than One Million
Dollars ($1,000,000) per occurrence for bodily injury and for disease.
(E) Professional Liability. Professional liability insurance with limits of not less than One Million
Dollars ($1,000,000) per occurrence and an annual aggregate of Three Million Dollars
($3,000,000). If this is a claims-made policy,then (1)the retroactive date must be prior to the
date on which services began under this Agreement; (2) CN shall maintain the policy and
provide to the County annual evidence of insurance for not less than three years after
completion of services under this Agreement; and (3) if the policy is canceled or not renewed,
and not replaced with another claims-made policy with a retroactive date prior to the date on
which services begin under this Agreement,then CN shall purchase extended reporting
coverage on its claims-made policy for a minimum of three years after completion of services
under this Agreement.
(F) Molestation Liability. Sexual abuse/molestation liability insurance with limits of not less than
Two Million Dollars ($2,000,000) per occurrence,with an annual aggregate of Four Million
Dollars ($4,000,000).
(G) Cyber Liability. Cyber liability insurance with limits of not less than Two Million Dollars
($2,000,000) per claim. Coverage must include claims involving Cyber Risks.
Definition of Cyber Risks. "Cyber Risks" include but are not limited to (i) Security Breach, which
may include Disclosure of Personal Information to an Unauthorized Third Party; (ii) data breach;
(iii) breach of any of CN's obligations under this Agreement; (iv) system failure; (v) data
recovery; (vi)failure to timely disclose data breach or Security Breach; (vii)failure to comply
with privacy policy; (viii) payment card liabilities and costs; (ix) infringement of intellectual
property, including but not limited to infringement of copyright,trademark, and trade dress; (x)
invasion of privacy, including release of private information; (xi) information theft; (xii) damage
to or destruction or alteration of electronic information; (xiii) cyber extortion; (xiv) extortion
related to CN's obligations under this Agreement regarding electronic information, including
Personal Information; (xv) fraudulent instruction; (xvi)funds transfer fraud; (xvii) telephone
fraud; (xviii) network security; (xix) data breach response costs, including Security Breach
response costs; (xx) regulatory fines and penalties related to CN's obligations under this
Agreement regarding electronic information, including Personal Information; and (xxi) credit
monitoring expenses.
2. Additional Requirements
(A) Verification of Coverage. Within 30 days after CN signs this Agreement, and at any time during
the term of this Agreement as requested by the County, CN shall deliver, or cause its broker or
producer to deliver,to the County Risk Manager, at 2220 Tulare Street, 16th Floor, Fresno,
California 93721, or HRRiskManagement@fresnocountyca.gov, and by mail or email to the
person identified to receive notices under this Agreement, certificates of insurance and
endorsements for all of the coverages required under this Agreement.
(B) Acceptability of Insurers. All insurance policies required under this Agreement must be issued
by admitted insurers licensed to do business in the State of California and possessing at all times
during the term of this Agreement an A.M. Best, Inc. rating of no less than A-: VII.
(C) Notice of Cancellation or Change. For each insurance policy required under this Agreement, CN
shall provide to the County, or ensure that the policy requires the insurer to provide to the
County,written notice of any cancellation or change in the policy as required in this paragraph.
For cancellation of the policy for nonpayment of premium, CN shall, or shall cause the insurer
to, provide written notice to the County not less than 10 days in advance of cancellation. For
cancellation of the policy for any other reason, and for any other change to the policy, CN shall,
or shall cause the insurer to, provide written notice to the County not less than 30 days in
advance of cancellation or change.The County in its sole discretion may determine that the
failure of CN or its insurer to timely provide a written notice required by this paragraph is a
breach of this Agreement.
(D) County's Entitlement to Greater Coverage. If CN has or obtains insurance with broader
coverage, higher limits, or both,than what is required under this Agreement,then the County
requires and is entitled to the broader coverage, higher limits, or both.To that end, CN shall
deliver, or cause its broker or producer to deliver,to the County's Risk Manager certificates of
insurance and endorsements for all of the coverages that have such broader coverage, higher
limits, or both, as required under this Agreement.
(E) Waiver of Subrogation. CN waives any right to recover from the County, its officers, agents,
employees, and volunteers any amounts paid under any insurance policies required by this
Agreement. CN is solely responsible to obtain any policy endorsement that may be necessary to
accomplish that waiver, but CN waiver of subrogation under this paragraph is effective whether
or not CN obtains such an endorsement.
(F) County's Remedy for CN's Failure to Maintain. If CN fails to keep in effect at all times any
insurance coverage required under this Agreement,the County may, in addition to any other
remedies it may have, suspend or terminate this Agreement upon the occurrence of that failure.
Exhibit B
Data Security
1. Definitions
Capitalized terms used in this Exhibit B have the meanings set forth in this section 1.
(A) "Authorized Employees" means the Contractor's officers, agents, subcontractors, interns, or
employees who have access to Personal Information.
(B) "Authorized Persons" means: (i) any and all Authorized Employees; and (ii) any and all of the
Contractor's subcontractors, representatives, agents,outsourcers, and consultants, and
providers of professional services to the Contractor,who have access to Personal Information
and are bound by law or in writing by confidentiality obligations sufficient to protect Personal
Information in accordance with the terms of this Exhibit B.
(C) "Director" means the County's Director of Internal Services/Chief Information Officer or his or
her designee.
(D) "Disclose" or any derivative of that word means to disclose, release,transfer, disseminate, or
otherwise provide access to or communicate all or any part of any Personal Information orally,
in writing, or by electronic or any other means to any person.
(E) "Person" means any natural person, corporation, partnership, limited liability company,firm, or
association.
(F) "Personal Information" means any and all information, including any data, provided, or to
which access is provided, to the Contractor by or upon the authorization of the County, under
this Agreement, including but not limited to vital records,that: (i) identifies, describes, or relates
to, or is associated with, or is capable of being used to identify, describe, or relate to, or
associate with, a person (including, without limitation, names, physical descriptions, signatures,
addresses,telephone numbers, e-mail addresses, education,financial matters, employment
history, and other unique identifiers, as well as statements made by or attributable to the
person); (ii) is used or is capable of being used to authenticate a person (including,without
limitation, employee identification numbers,government-issued identification numbers,
passwords or personal identification numbers (PINS), financial account numbers, credit report
information, answers to security questions, and other personal identifiers); or(iii) is personal
information within the meaning of California Civil Code section 1798.3, subdivision (a), or
1798.80, subdivision (e). Personal Information does not include publicly available information
that is lawfully made available to the general public from federal, state, or local government
records.
(G) "Privacy Practices Complaint" means a complaint received by the County relating to the
Contractor's (or any Authorized Person's) privacy practices, or alleging a Security Breach. Such
complaint shall have sufficient detail to enable the Contractor to promptly investigate and take
remedial action under this Exhibit B.
(H) "Security Safeguards" means physical,technical, administrative or organizational security
procedures and practices put in place by the Contractor(or any Authorized Persons)that relate
to the protection of the security, confidentiality,value, or integrity of Personal Information.
Security Safeguards shall satisfy the minimal requirements set forth in section 3(C) of this Exhibit
B.
(1) "Security Breach" means (i) any act or omission that compromises either the security,
confidentiality,value, or integrity of any Personal Information or the Security Safeguards, or(ii)
any unauthorized Use, Disclosure, or modification of, or any loss or destruction of, or any
corruption of or damage to, any Personal Information.
(J) "Use" or any derivative of that word means to receive, acquire, collect, apply, manipulate,
employ, process,transmit, disseminate, access, store, disclose, or dispose of Personal
Information.
2. /incidents@fresnocountyca.gov(which telephone number and email address the County may update by
providing notice to the Contractor), of Care
(A) The Contractor acknowledges that, in the course of its engagement by the County under this
Agreement,the Contractor, or any Authorized Persons, may Use Personal Information only as
permitted in this Agreement.
(B) The Contractor acknowledges that Personal Information is deemed to be confidential
information of, or owned by, the County (or persons from whom the County receives or has
received Personal Information) and is not confidential information of, or owned or by,the
Contractor, or any Authorized Persons.The Contractor further acknowledges that all right,title,
and interest in or to the Personal Information remains in the County(or persons from whom the
County receives or has received Personal Information) regardless of the Contractor's, or any
Authorized Person's, Use of that Personal Information.
(C) The Contractor agrees and covenants in favor of the Country that the Contractor shall:
i. keep and maintain all Personal Information in strict confidence, using such degree of
care under this section 2 as is reasonable and appropriate to avoid a Security Breach;
ii. Use Personal Information exclusively for the purposes for which the Personal
Information is made accessible to the Contractor pursuant to the terms of this Exhibit B;
iii. not Use, Disclose, sell, rent, license, or otherwise make available Personal Information
for the Contractor's own purposes or for the benefit of anyone other than the County,
without the County's express prior written consent,which the County may give or
withhold in its sole and absolute discretion; and
iv. not, directly or indirectly, Disclose Personal Information to any person (an
"Unauthorized Third Party") other than Authorized Persons pursuant to this Agreement,
without the Director's express prior written consent.
(D) Notwithstanding the foregoing paragraph, in any case in which the Contractor believes it, or any
Authorized Person, is required to disclose Personal Information to government regulatory
authorities,or pursuant to a legal proceeding, or otherwise as may be required by applicable
law, Contractor shall (i) immediately notify the County of the specific demand for, and legal
authority for the disclosure, including providing County with a copy of any notice, discovery
demand, subpoena, or order, as applicable, received by the Contractor, or any Authorized
Person,from any government regulatory authorities,or in relation to any legal proceeding, and
(ii) promptly notify the County before such Personal Information is offered by the Contractor for
such disclosure so that the County may have sufficient time to obtain a court order or take any
other action the County may deem necessary to protect the Personal Information from such
disclosure, and the Contractor shall cooperate with the County to minimize the scope of such
disclosure of such Personal Information.
(E) The Contractor shall remain liable to the County for the actions and omissions of any
Unauthorized Third Party concerning its Use of such Personal Information as if they were the
Contractor's own actions and omissions.
3. Information Security
(A) The Contractor covenants, represents and warrants to the County that the Contractor's Use of
Personal Information under this Agreement does and will at all times comply with all applicable
federal, state, and local, privacy and data protection laws, as well as all other applicable
regulations and directives, including but not limited to California Civil Code, Division 3, Part 4,
Title 1.81 (beginning with section 1798.80), and the Song-Beverly Credit Card Act of 1971
(California Civil Code, Division 3, Part 4,Title 1.3, beginning with section 1747). If the Contractor
Uses credit, debit or other payment cardholder information,the Contractor shall at all times
remain in compliance with the Payment Card Industry Data Security Standard ("PCI DSS")
requirements, including remaining aware at all times of changes to the PCI DSS and promptly
implementing and maintaining all procedures and practices as may be necessary to remain in
compliance with the PCI DSS, in each case, at the Contractor's sole cost and expense.
(B) The Contractor covenants, represents and warrants to the County that, as of the effective date
of this Agreement,the Contractor has not received notice of any violation of any privacy or data
protection laws, as well as any other applicable regulations or directives, and is not the subject
of any pending legal action or investigation by, any government regulatory authority regarding
same.
(C) Without limiting the Contractor's obligations under section 3(A) of this Exhibit B,the
Contractor's (or Authorized Person's) Security Safeguards shall be no less rigorous than
accepted industry practices and, at a minimum, include the following:
i. limiting Use of Personal Information strictly to the Contractor's and Authorized Persons'
technical and administrative personnel who are necessary for the Contractor's, or
Authorized Persons', Use of the Personal Information pursuant to this Agreement;
ii. ensuring that all of the Contractor's connectivity to County computing systems will only
be through the County's security gateways and firewalls, and only through security
procedures approved upon the express prior written consent of the Director;
iii. to the extent that they contain or provide access to Personal Information, (a) securing
business facilities, data centers, paper files, servers, back-up systems and computing
equipment, operating systems, and software applications, including, but not limited to,
all mobile devices and other equipment, operating systems, and software applications
with information storage capability; (b) employing adequate controls and data security
measures, both internally and externally, to protect(1)the Personal Information from
potential loss or misappropriation, or unauthorized Use, and (2)the County's operations
from disruption and abuse; (c) having and maintaining network, device application,
database and platform security; (d) maintaining authentication and access controls
within media, computing equipment, operating systems, and software applications; and
(e) installing and maintaining in all mobile, wireless, or handheld devices a secure
internet connection, having continuously updated anti-virus software protection and a
remote wipe feature always enabled, all of which is subject to express prior written
consent of the Director;
iv. encrypting all Personal Information at advance encryption standards of Advanced
Encryption Standards (AES) of 128 bit or higher(a)stored on any mobile devices,
including but not limited to hard disks, portable storage devices, or remote installation,
or(b)transmitted over public or wireless networks (the encrypted Personal Information
must be subject to password or pass phrase, and be stored on a secure server and
transferred by means of a Virtual Private Network(VPN) connection, or another type of
secure connection, all of which is subject to express prior written consent of the
Director);
V. strictly segregating Personal Information from all other information of the Contractor,
including any Authorized Person, or anyone with whom the Contractor or any
Authorized Person deals so that Personal Information is not commingled with any other
types of information;
vi. having a patch management process including installation of all operating system and
software vendor security patches;
vii. maintaining appropriate personnel security and integrity procedures and practices,
including, but not limited to, conducting background checks of Authorized Employees
consistent with applicable law; and
viii. providing appropriate privacy and information security training to Authorized
Employees.
(D) During the term of each Authorized Employee's employment by the Contractor, the Contractor
shall cause such Authorized Employees to abide strictly by the Contractor's obligations under
this Exhibit B.The Contractor shall maintain a disciplinary process to address any unauthorized
Use of Personal Information by any Authorized Employees.
(E) The Contractor shall, in a secure manner, backup daily, or more frequently if it is the
Contractor's practice to do so more frequently, Personal Information received from the County,
and the County shall have immediate, real time access, at all times,to such backups via a secure,
remote access connection provided by the Contractor,through the Internet.
(F) The Contractor shall provide the County with the name and contact information for each
Authorized Employee (including such Authorized Employee's work shift, and at least one
alternate Authorized Employee for each Authorized Employee during such work shift) who shall
serve as the County's primary security contact with the Contractor and shall be available to
assist the County twenty-four(24) hours per day, seven (7) days per week as a contact in
resolving the Contractor's and any Authorized Persons' obligations associated with a Security
Breach or a Privacy Practices Complaint.
(G) The Contractor shall not knowingly include or authorize any Trojan Horse, back door,time
bomb, drop dead device,worm,virus, or other code of any kind that may disable, erase, display
any unauthorized message within, or otherwise impair any County computing system, with or
without the intent to cause harm.
4. Security Breach Procedures
(A) Immediately upon the Contractor's awareness or reasonable belief of a Security Breach,the
Contractor shall (i) notify the Director of the Security Breach, such notice to be given first by
telephone at the following telephone number, followed promptly by email at the following
email address: (559) 600-6200/ incidents@fresnocountyca.gov (which telephone number and
email address the County may update by providing notice to the Contractor),(which telephone
number and email address the County may update by providing notice to the Contractor), and
(ii) preserve all relevant evidence (and cause any affected Authorized Person to preserve all
relevant evidence) relating to the Security Breach.The notification shall include, to the extent
reasonably possible,the identification of each type and the extent of Personal Information that
has been, or is reasonably believed to have been, breached, including but not limited to,
compromised, or subjected to unauthorized Use, Disclosure, or modification, or any loss or
destruction, corruption, or damage.
(B) Immediately following the Contractor's notification to the County of a Security Breach, as
provided pursuant to section 4(A) of this Exhibit B,the Parties shall coordinate with each other
to investigate the Security Breach.The Contractor agrees to fully cooperate with the County,
including, without limitation:
i. assisting the County in conducting any investigation;
ii. providing the County with physical access to the facilities and operations affected;
iii. facilitating interviews with Authorized Persons and any of the Contractor's other
employees knowledgeable of the matter; and
iv. making available all relevant records, logs, files, data reporting and other materials
required to comply with applicable law, regulation, industry standards, or as otherwise
reasonably required by the County.
To that end,the Contractor shall,with respect to a Security Breach, be solely responsible, at its
cost,for all notifications required by law and regulation, or deemed reasonably necessary by the
County, and the Contractor shall provide a written report of the investigation and reporting
required to the Director within 30 days after the Contractor's discovery of the Security Breach.
(C) County shall promptly notify the Contractor of the Director's knowledge, or reasonable belief, of
any Privacy Practices Complaint, and upon the Contractor's receipt of that notification,the
Contractor shall promptly address such Privacy Practices Complaint, including taking any
corrective action under this Exhibit B, all at the Contractor's sole expense, in accordance with
applicable privacy rights, laws, regulations and standards. In the event the Contractor discovers
a Security Breach,the Contractor shall treat the Privacy Practices Complaint as a Security
Breach. Within 24 hours of the Contractor's receipt of notification of such Privacy Practices
Complaint,the Contractor shall notify the County whether the matter is a Security Breach, or
otherwise has been corrected and the manner of correction, or determined not to require
corrective action and the reason for that determination.
(D) The Contractor shall take prompt corrective action to respond to and remedy any Security
Breach and take mitigating actions, including but not limiting to, preventing any reoccurrence of
the Security Breach and correcting any deficiency in Security Safeguards as a result of such
incident, all at the Contractor's sole expense, in accordance with applicable privacy rights, laws,
regulations and standards.The Contractor shall reimburse the County for all reasonable costs
incurred by the County in responding to, and mitigating damages caused by, any Security
Breach, including all costs of the County incurred relation to any litigation or other action
described section 4(E) of this Exhibit B.
(E) The Contractor agrees to cooperate, at its sole expense, with the County in any litigation or
other action to protect the County's rights relating to Personal Information, including the rights
of persons from whom the County receives Personal Information.
S. Oversight of Security Compliance
(A) The Contractor shall have and maintain a written information security policy that specifies
Security Safeguards appropriate to the size and complexity of the Contractor's operations and
the nature and scope of its activities.
(B) Upon the County's written request,to confirm the Contractor's compliance with this Exhibit B,
as well as any applicable laws, regulations and industry standards,the Contractor grants the
County or, upon the County's election, a third party on the County's behalf, permission to
perform an assessment, audit, examination or review of all controls in the Contractor's physical
and technical environment in relation to all Personal Information that is Used by the Contractor
pursuant to this Agreement.The Contractor shall fully cooperate with such assessment, audit or
examination, as applicable, by providing the County or the third party on the County's behalf,
access to all Authorized Employees and other knowledgeable personnel, physical premises,
documentation, infrastructure and application software that is Used by the Contractor for
Personal Information pursuant to this Agreement. In addition,the Contractor shall provide the
County with the results of any audit by or on behalf of the Contractor that assesses the
effectiveness of the Contractor's information security program as relevant to the security and
confidentiality of Personal Information Used by the Contractor or Authorized Persons during the
course of this Agreement under this Exhibit B.
(C) The Contractor shall ensure that all Authorized Persons who Use Personal Information agree to
the same restrictions and conditions in this Exhibit B.that apply to the Contractor with respect
to such Personal Information by incorporating the relevant provisions of these provisions into a
valid and binding written agreement between the Contractor and such Authorized Persons, or
amending any written agreements to provide same.
6. Return or Destruction of Personal Information. Upon the termination of this Agreement,the
Contractor shall, and shall instruct all Authorized Persons to, promptly return to the County all Personal
Information, whether in written, electronic or other form or media, in its possession or the possession of
such Authorized Persons, in a machine readable form used by the County at the time of such return, or
upon the express prior written consent of the Director, securely destroy all such Personal Information,
and certify in writing to the County that such Personal Information have been returned to the County or
disposed of securely, as applicable. If the Contractor is authorized to dispose of any such Personal
Information, as provided in this Exhibit B, such certification shall state the date,time, and manner
(including standard) of disposal and by whom, specifying the title of the individual.The Contractor shall
comply with all reasonable directions provided by the Director with respect to the return or disposal of
Personal Information and copies of Personal Information. If return or disposal of such Personal
Information or copies of Personal Information is not feasible,the Contractor shall notify the County
according, specifying the reason, and continue to extend the protections of this Exhibit B to all such
Personal Information and copies of Personal Information.The Contractor shall not retain any copy of
any Personal Information after returning or disposing of Personal Information as required by this section
6.The Contractor's obligations under this section 6 survive the termination of this Agreement and apply
to all Personal Information that the Contractor retains if return or disposal is not feasible and to all
Personal Information that the Contractor may later discover.
7. Equitable Relief.The Contractor acknowledges that any breach of its covenants or obligations set
forth in this Exhibit B may cause the County irreparable harm for which monetary damages would not be
adequate compensation and agrees that, in the event of such breach or threatened breach,the County
is entitled to seek equitable relief, including a restraining order, injunctive relief, specific performance
and any other relief that may be available from any court, in addition to any other remedy to which the
County may be entitled at law or in equity. Such remedies shall not be deemed to be exclusive but shall
be in addition to all other remedies available to the County at law or in equity or under this Agreement.
8. Indemnity.The Contractor shall defend, indemnify and hold harmless the County, its officers,
employees, and agents, (each, a "County Indemnitee")from and against any and all infringement of
intellectual property including, but not limited to infringement of copyright,trademark, and trade dress,
invasion of privacy, information theft, and extortion, unauthorized Use, Disclosure, or modification of, or
any loss or destruction of, or any corruption of or damage to, Personal Information, Security Breach
response and remedy costs, credit monitoring expenses,forfeitures, losses, damages, liabilities,
deficiencies, actions,judgments, interest, awards,fines and penalties (including regulatory fines and
penalties), costs or expenses of whatever kind, including attorneys'fees and costs,the cost of enforcing
any right to indemnification or defense under this Exhibit B and the cost of pursuing any insurance
providers, arising out of or resulting from any third party claim or action against any County Indemnitee
in relation to the Contractor's, its officers, employees, or agents, or any Authorized Employee's or
Authorized Persons, performance or failure to perform under this Exhibit B or arising out of or resulting
from the Contractor's failure to comply with any of its obligations under this section 8.The provisions of
this section 8 do not apply to the acts or omissions of the County.The provisions of this section 8 are
cumulative to any other obligation of the Contractor to, defend, indemnify, or hold harmless any County
Indemnitee under this Agreement.The provisions of this section 8 shall survive the termination of this
Agreement.
9. Survival.The respective rights and obligations of the Contractor and the County as stated in this
Exhibit B shall survive the termination of this Agreement.
10. No Third Party Beneficiary. Nothing express or implied in the provisions of in this Exhibit B is
intended to confer, nor shall anything in this Exhibit B confer, upon any person other than the County or
the Contractor and their respective successors or assignees, any rights, remedies, obligations or
liabilities whatsoever.
11. No County Warranty.The County does not make any warranty or representation whether any
Personal Information in the Contractor's (or any Authorized Persons) possession or control, or Use by
the Contractor(or any Authorized Person), pursuant to the terms of this Agreement is or will be secure
from unauthorized Use, or a Security Breach or Privacy Practices Complaint.
Exhibit C
Health Insurance Portability and Accountability Act(HIPAA)
1. The County is a "Covered Entity," and CN or any of its officers, agents,
subcontractors, interns, or employees), (for purposes of this Exhibit C shall hereafter be referred to
as "Contractor"), and is a "Business Associate," as these terms are defined by 45 CFR 160.103. In
connection with providing services under the Agreement, the parties anticipate that the Contractor
will create and/or receive Protected Health Information ("PHI")from or on behalf of the County. The
parties enter into this Business Associate Agreement (BAA)to comply with the Business Associate
requirements of HIPAA, to govern the use and disclosures of PHI under this Agreement. "HIPAA
Rules" shall mean the Privacy, Security, Breach Notification, and Enforcement Rules at 45 CFR
Parts 160 and 164. The parties to this Agreement shall be in strict conformance with all applicable
federal and State of California laws and regulations, including, but not limited to California Welfare
and Institutions Code sections 5328, 10850, and 14100.2 et seq.; 42 CFR 2; 42 CFR 431;
California Civil Code section 56 et seq.; the Health Insurance Portability and Accountability Act of
1996, as amended ("HIPAA"), including, but not limited to, 45 CFR Parts160, 45 CFR 162, and 45
CFR 164; the Health Information Technology for Economic and Clinical Health Act("HITECH")
regarding the confidentiality and security of patient information, including, but not limited to 42 USC
17901 et seq.; and the Genetic Information Nondiscrimination Act ("GINA")of 2008 regarding the
confidentiality of genetic information.
Except as otherwise provided in this Agreement, the Contractor, as a business
associate of the County, may use or disclose Protected Health Information ("PHI") to perform
functions, activities or services for or on behalf of the County, as specified in this Agreement,
provided that such use or disclosure shall not violate HIPAA Rules. The uses and disclosures of
PHI may not be more expansive than those applicable to the County, as the "Covered Entity"
under the HIPAA Rules, except as authorized for management, administrative or legal
responsibilities of the Contractor.
2. The Contractor, including its subcontractors and employees, shall protect from
unauthorized access, use, or disclosure of names and other identifying information, including
genetic information, concerning persons receiving services pursuant to this Agreement, except
where permitted in order to carry out data aggregation purposes for health care operations [45
CFR §§ 164.504(e)(2)(i), 164.504(e)(2)(ii)(A), and 164.504(e)(4)(i)]. This pertains to any and all
persons receiving services pursuant to a County-funded program. This requirement applies to
electronic PHI. The Contractor shall not use such identifying information or genetic information for
any purpose other than carrying out the Contractor's obligations under this Agreement.
3. The Contractor, including its subcontractors and employees, shall not disclose any
such identifying information or genetic information to any person or entity, except as otherwise
specifically permitted by this Agreement, authorized by Subpart E of 45 CFR Part 164 or other law,
required by the Secretary of the United States Department of Health and Human Services
("Secretary"), or authorized by the client/patient in writing. In using or disclosing PHI that is
permitted by this Agreement or authorized by law, the Contractor shall make reasonable efforts to
limit PHI to the minimum necessary to accomplish intended purpose of use, disclosure or request.
4. For purposes of the above sections, identifying information shall include, but not be
limited to, name, identifying number, symbol, or other identifying particular assigned to the
individual, such as fingerprint or voiceprint, or photograph.
5. For purposes of the above sections, genetic information shall include genetic tests
of family members of an individual or individual(s), manifestation of disease or disorder of family
members of an individual, or any request for or receipt of genetic services by individual or family
members. Family member means a dependent or any person who is first, second, third, or fourth
degree relative.
6. The Contractor shall provide access, at the request of the County, and in the time
and manner designated by the County, to PHI in a designated record set (as defined in 45 CFR§
164.501), to an individual or to COUNTY in order to meet the requirements of 45 CFR § 164.524
regarding access by individuals to their PHI. With respect to individual requests, access shall be
provided within thirty (30) days from request. Access may be extended if the Contractor cannot
provide access and provides the individual with the reasons for the delay and the date when
access may be granted. PHI shall be provided in the form and format requested by the individual
or the County.
The Contractor shall make any amendment(s) to PHI in a designated record set
at the request of the County or individual, and in the time and manner designated by the County
in accordance with 45 CFR § 164.526.
The Contractor shall provide to the County or to an individual, in a time and
manner designated by the County, information collected in accordance with 45 CFR § 164.528,
to permit the County to respond to a request by the individual for an accounting of disclosures of
PHI in accordance with 45 CFR § 164.528.
7. The Contractor shall report to the County, in writing, any knowledge or
reasonable belief that there has been unauthorized access, viewing, use, disclosure, security
incident, or breach of unsecured PHI not permitted by this Agreement of which the Contractor
becomes aware, immediately and without reasonable delay and in no case later than two (2)
business days of discovery. Immediate notification shall be made to the County's Information
Security Officer and Privacy Officer and the County's Department of Public Health ("DPH")
HIPAA Representative, within two (2) business days of discovery. The notification shall include,
to the extent possible, the identification of each individual whose unsecured PHI has been, or is
reasonably believed to have been, accessed, acquired, used, disclosed, or breached. The
Contractor shall take prompt corrective action to cure any deficiencies and any action pertaining
to such unauthorized disclosure required by applicable federal and State laws and regulations.
The Contractor shall investigate such breach and is responsible for all notifications required by
law and regulation or deemed necessary by the County and shall provide a written report of the
investigation and reporting required to the County's Information Security Officer and Privacy
Officer and the County's DPH HIPAA Representative.
This written investigation and description of any reporting necessary shall be
postmarked within the thirty (30) working days of the discovery of the breach to the
addresses below:
County of Fresno County of Fresno County of Fresno
Department of Public Health Department of Public Health Department of Internal Services
HIPAA Representative Privacy Officer Information Security Officer
(559) 600-6439 (559) 600-6405 (559) 600-5800
P.O. Box 11867 P.O. Box 11867 2048 North Fine Street
Fresno, California 93775 Fresno, California 93775 Fresno, California 93727
8. The Contractor shall make its internal practices, books, and records relating to
the use and disclosure of PHI received from the County, or created or received by the
Contractor on behalf of the County, in compliance with Parts the HIPAA Rules. The Contractor
shall make its internal practices, books, and records relating to the use and disclosure of PHI
received from the County, or created or received by the Contractor on behalf of the County,
available to the Secretary upon demand.
The Contractor shall cooperate with the compliance and investigation reviews conducted
by the Secretary. PHI access to the Secretary must be provided during the Contractor's normal
business hours; however, upon exigent circumstances access at any time must be granted.
Upon the Secretary's compliance or investigation review, if PHI is unavailable to the Contractor
and in possession of a subcontractor of the Contractor, the Contractor must certify to the
Secretary its efforts to obtain the information from the subcontractor.
9. Safeguards
The Contractor shall implement administrative, physical, and technical safeguards as
required by the HIPAA Security Rule, Subpart C of 45 CFR Part 164, that reasonably and
appropriately protect the confidentiality, integrity, and availability of PHI, including electronic
PHI, that it creates, receives, maintains or transmits on behalf of the County and to prevent
unauthorized access, viewing, use, disclosure, or breach of PHI other than as provided for by
this Agreement. The Contractor shall conduct an accurate and thorough assessment of the
potential risks and vulnerabilities to the confidentiality, integrity and availability of electronic PHI.
The Contractor shall develop and maintain a written information privacy and security program
that includes administrative, technical and physical safeguards appropriate to the size and
complexity of the Contractor's operations and the nature and scope of its activities. Upon the
County's request, the Contractor shall provide the County with information concerning such
safeguards.
The Contractor shall implement strong access controls and other security safeguards
and precautions in order to restrict logical and physical access to confidential, personal (e.g.,
PHI) or sensitive data to authorized users only. Said safeguards and precautions shall include
the following administrative and technical password controls for all systems used to process or
store confidential, personal, or sensitive data:
A. Passwords must not be:
(1) Shared or written down where they are accessible or recognizable by anyone
else; such as taped to computer screens, stored under keyboards, or visible
in a work area;
(2) A dictionary word; or
(3) Stored in clear text
B. Passwords must be:
(1) Eight (8) characters or more in length;
(2) Changed every ninety (90) days;
(3) Changed immediately if revealed or compromised; and
(4) Composed of characters from at least three (3) of the following four (4)
groups from the standard keyboard:
a) Upper case letters (A-Z);
b) Lowercase letters (a-z);
c) Arabic numerals (0 through 9); and
d) Non-alphanumeric characters (punctuation symbols).
The Contractor shall implement the following security controls on each workstation or
portable computing device (e.g., laptop computer) containing confidential, personal, or sensitive
data:
1. Network-based firewall and/or personal firewall;
2. Continuously updated anti-virus software; and
3. Patch management process including installation of all operating system/software
vendor security patches.
The Contractor shall utilize a commercial encryption solution that has received FIPS
140-2 validation to encrypt all confidential, personal, or sensitive data stored on portable
electronic media (including, but not limited to, compact disks and thumb drives) and on portable
computing devices (including, but not limited to, laptop and notebook computers).
The Contractor shall not transmit confidential, personal, or sensitive data via e-mail or
other internet transport protocol unless the data is encrypted by a solution that has been
validated by the National Institute of Standards and Technology (NIST) as conforming to the
Advanced Encryption Standard (AES) Algorithm. The Contractor must apply appropriate
sanctions against its employees who fail to comply with these safeguards. The Contractor must
adopt procedures for terminating access to PHI when employment of employee ends.
10. Mitigation of Harmful Effects
The Contractor shall mitigate, to the extent practicable, any harmful effect that is
suspected or known to the Contractor of an unauthorized access, viewing, use, disclosure, or
breach of PHI by the Contractor or its subcontractors in violation of the requirements of these
provisions. The Contractor must document suspected or known harmful effects and the
outcome.
11. The Contractor's Subcontractors
The Contractor shall ensure that any of its contractors, including subcontractors, if
applicable, to whom the Contractor provides PHI received from or created or received by the
Contractor on behalf of the County, agree to the same restrictions, safeguards, and conditions
that apply to the Contractor with respect to such PHI and to incorporate, when applicable, the
relevant provisions of these provisions into each subcontract or sub-award to such agents or
subcontractors.
Nothing in this section 11 or this Exhibit C authorizes the Contractor to perform services
under this Agreement using subcontractors.
12. Employee Training and Discipline
The Contractor shall train and use reasonable measures to ensure compliance with the
requirements of these provisions by employees who assist in the performance of functions or
activities on behalf of the County under this Agreement and use or disclose PHI, and discipline
such employees who intentionally violate any provisions of these provisions, which may include
termination of employment.
13. Termination for Cause
Upon the County's knowledge of a material breach of these provisions by the Contractor,
the County will either:
A. Provide an opportunity for the Contractor to cure the breach or end the
violation, and the County may terminate this Agreement if the Contractor does not cure the
breach or end the violation within the time specified by the County; or
B. Immediately terminate this Agreement if the Contractor has breached a
material term of this Exhibit C and cure is not possible, as determined by the County.
C. If neither cure nor termination is feasible, the County's Privacy Officer will
report the violation to the Secretary of the U.S. Department of Health and Human Services.
14. Judicial or Administrative Proceedings
The County may terminate this Agreement if: (1) the Contractor is found guilty in a
criminal proceeding for a violation of the HIPAA Privacy or Security Laws or the HITECH Act; or
(2) there is a finding or stipulation in an administrative or civil proceeding in which the Contractor
is a party that the Contractor has violated a privacy or security standard or requirement of the
HITECH Act, HIPAA or other security or privacy laws.
15. Effect of Termination
Upon termination or expiration of this Agreement for any reason, the Contractor shall
return or destroy all PHI received from the County (or created or received by the Contractor on
behalf of the County) that the Contractor still maintains in any form, and shall retain no copies of
such PHI. If return or destruction of PHI is not feasible, the Contractor shall continue to extend
the protections of these provisions to such information, and limit further use of such PHI to those
purposes that make the return or destruction of such PHI infeasible. This provision applies to
PHI that is in the possession of subcontractors or agents, if applicable, of the Contractor. If the
Contractor destroys the PHI data, a certification of date and time of destruction shall be
provided to the County by the Contractor.
16. Compliance with Other Laws
To the extent that other state and/or federal laws provide additional, stricter and/or more
protective privacy and/or security protections to PHI or other confidential information covered
under this BAA, the Contractor agrees to comply with the more protective of the privacy and
security standards set forth in the applicable state or federal laws to the extent such standards
provide a greater degree of protection and security than HIPAA Rules or are otherwise more
favorable to the individual.
17. Disclaimer
The County makes no warranty or representation that compliance by the Contractor with
these provisions, the HITECH Act, or the HIPAA Rules, will be adequate or satisfactory for the
Contractor's own purposes or that any information in the Contractor's possession or control, or
transmitted or received by the Contractor, is or will be secure from unauthorized access,
viewing, use, disclosure, or breach. The Contractor is solely responsible for all decisions made
by the Contractor regarding the safeguarding of PHI.
18. Amendment
The parties acknowledge that Federal and State laws relating to electronic data security
and privacy are rapidly evolving and that amendment of this Exhibit C may be required to
provide for procedures to ensure compliance with such developments. The parties specifically
agree to take such action as is necessary to amend this agreement in order to implement the
standards and requirements of the HIPAA Rules, the HITECH Act and other applicable laws
relating to the security or privacy of PHI. The County may terminate this Agreement upon thirty
(30) days written notice in the event that the Contractor does not enter into an amendment
providing assurances regarding the safeguarding of PHI that the County in its sole discretion,
deems sufficient to satisfy the standards and requirements of the HIPAA Rules, and the
HITECH Act.
19. No Third-Party Beneficiaries
Nothing expressed or implied in the provisions of this Exhibit C is intended to confer, and
nothing in this Exhibit C does confer, upon any person other than the County or the Contractor
and their respective successors or assignees, any rights, remedies, obligations or liabilities
whatsoever.
20. Interpretation
The provisions of this Exhibit C shall be interpreted as broadly as necessary to
implement and comply with the HIPAA Rules, and applicable State laws. The parties agree that
any ambiguity in the terms and conditions of these provisions shall be resolved in favor of a
meaning that complies and is consistent with the HIPAA Rules.
21. Regulatory References
A reference in the terms and conditions of these provisions to a section in the HIPAA
Rules means the section as in effect or as amended.
22. Survival
The respective rights and obligations of the Contractor as stated in this Exhibit C survive
the termination or expiration of this Agreement.
23. No Waiver of Obligation
Change, waiver or discharge by the County of any liability or obligation of the Contractor
under this Exhibit C on any one or more occasions is not a waiver of performance of any
continuing or other obligation of the Contractor and does not prohibit enforcement by the County
of any obligation on any other occasion.