IDAHO – Privacy Policy

SMS Communications — Idaho Employment & Training Program

Community Connect Labs  |  Idaho Employment & Training  |  June 17, 2026

 

Community Connect Labs (“CCL,” “we,” “us,” or “our”) operates SMS communications for the Idaho Employment & Training (E&T) program on behalf of the Idaho Department of Health and Welfare. This Privacy Policy describes how we collect, use, and protect your personal information in connection with this program.

 

1. Information We Collect

When you participate in the Idaho E&T SMS program, we may collect:

  • Your mobile phone number
  • Your first and last name (as provided by the Idaho Department of Health and Welfare)
  • Your preferred language
  • Your program participation status and case identifiers
  • Message interaction data (e.g., whether you replied START, STOP, or responded to a prompt)
  • Hours-reporting data submitted via SMS

 

2. How We Use Your Information

We use your information solely for the following program purposes:

  • Sending program reminders, appointment notifications, and compliance notices
  • Processing opt-in and opt-out requests
  • Delivering hours-reporting prompts and collecting responses
  • Supporting case manager follow-up for at-risk participants
  • Improving program delivery and SMS flow performance

 

3. Data Sharing and Third Parties

We do not sell or share mobile or personal data with third parties, affiliates, or partners for marketing or promotional purposes. We only share data with third parties when it is strictly necessary to deliver our service and only under binding agreements that ensure confidentiality. Under no circumstances will mobile data be shared or sold for advertising or promotional use.

 

When sharing data is strictly necessary to deliver program services, we may share information with:

  • The Idaho Department of Health and Welfare (program administrator)
  • Twilio Inc. (SMS delivery infrastructure), under binding data processing terms
  • Amazon Web Services (cloud infrastructure), under binding confidentiality terms

All third-party service providers are contractually bound to use your data only for the specific purposes required to deliver this program and are prohibited from using your data for any other purpose.

 

4. Data Retention

We retain your mobile number and interaction data for the duration of your program enrollment plus up to 12 months, or as required by applicable law or the Idaho Department of Health and Welfare’s data retention policies. You may request deletion of your data at any time by contacting your case manager.

 

5. Data Security

CCL implements industry-standard technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. SMS messages are transmitted via Twilio’s secure platform, which complies with SOC 2 Type II standards.

 

6. Your Rights

You have the right to:

  • Opt out of SMS communications at any time by replying STOP
  • Request access to the personal data we hold about you
  • Request correction of inaccurate data
  • Request deletion of your data (subject to legal retention requirements)

To exercise these rights, contact your assigned case manager or CCL program support.

 

7. Children’s Privacy

The Idaho E&T program serves adult participants (18 years and older). We do not knowingly collect personal information from individuals under the age of 18.

 

8. Changes to This Privacy Policy

We may update this Privacy Policy periodically. The effective date at the top of this document indicates when it was last revised. Continued participation in the program following any update constitutes acceptance of the revised policy.

 

9. Contact Information

For questions about this Privacy Policy or your data, contact:

Community Connect Labs

Program: Idaho Employment & Training (E&T) SMS

On behalf of: Idaho Department of Health and Welfare

 

Effective Date: June 17, 2026  |  Community Connect Labs  |  Idaho Employment & Training Program