First 5 Alameda County Statement on the Use of Hubbe

About First 5 Alameda County

First 5 Alameda County is a state-funded agency that provides training and quality improvement support for early care and education (ECE) Quality Counts centers and Family Child Care homes, and funds programs and services operated by contracted agencies. 

To evaluate the effectiveness of our programs and to comply with mandatory state reporting, First 5 Alameda County collects data from contracted agencies and program participants. Some data is required by Quality Counts California (QCC), a collaboration between First 5 California, the California Department of Education (CDE) and the California Department of Social Services (CDSS) and/or other annual report submissions as required by regulatory entities in accordance with First 5 Alameda County funding. First 5 Alameda County also uses data collected to inform agency policies and program planning. 

First 5 Alameda County takes the collection and protection of personal information and data that agencies and program participants submit seriously. When obtaining personally identifiable information, we notify participants of the purpose of the data collection and only collect personal data relevant to this purpose. We are committed to maintaining the security and integrity of personal data and information. This privacy statement informs agencies and program participants how First 5 Alameda County stores, collects, shares, and protects data and personal information. 

A. How data and information are stored 

First 5 Alameda County stores collected data and information in the following systems/platforms: 

  • First 5 Alameda’s Azure cloud tenant operating Microsoft Office 365- provides secure document and data receipt access and storage. 
  • High 5 Salesforce – Cloud-based Customer Relationship Management (CRM) platform that manages the entire contract lifecycle, designed to provide funding to nonprofits, service providers, early childhood agencies, contractors, and more. The platform stores key contract data, including budgets, Results-Based Accountability (RBA), contracts, invoices, and other reporting information. 
  • Hubbe – Web-based Quality Rating and Improvement System (QRIS) data collection and program management system for designated early childhood education providers, centers and/or agencies. 
  • AirTable- a cloud-based tool used to collect applications for Measure C grants. 
B. How we use data and information that we collect

First 5 Alameda County uses data and information for the following reporting purposes: 

  • External/State Reporting 
    • Verification of California State Preschool Program (CSPP) Block Grant, QCC Quality Improvement Grant and Improve and Maximize Program so All Children Thrive (IMPACT) Legacy program compliance. 
    •  Verification of Quality Rating and Improvement System (QRIS) participation and site rating; evaluation of CDE, CDSS and First 5 California investment(s). 
    • Reporting to the Governor’s Office, CA Department of Finance, Legislative Analyst’s Office, CA State Legislature, First 5 CA Commission, regional county partners, and/or other stakeholders as identified by the State. 
    • Mandatory reporting to First 5 California as required for the annual performance report. 
  • Internal/First 5 Alameda County Reporting 
    • Publishing reports and summaries of aggregate data that may be used in specific ways to describe First 5 Alameda County programs included in official agency reports and/or publications. 
    • Conducting analyses of program effectiveness in combination with other data sources held by First 5 Alameda County. 
    • Track and analyze county-wide child care subsidy utilization, by age, funding stream, and setting. 
    • Identify opportunities for outreach and provider participation in Measure C funded programs for countywide coverage. 
C. What type of data and personal information we collect 

Data collected may include first and last name, email address, street address, city, zip code of residence or child care business, phone number(s), Federal Employee Identification Number (FEIN), social security number, vendor number, source of payment and/or funding for child care services, race/ethnicity, language(s) spoken, income level, date of birth, age, gender, relationship to child(ren), and child care subsidy utilization. 

Data collected on children may include total children in care, date of birth, age, gender, name, language(s) spoken, race/ethnicity, number of children with an IFSP (Individualized Family Service Plan), number of children with an IEP (Individualized Education Plan), number of Homeless Children, and number of children in foster care. 

Other data commonly collected include, but are not limited to, ECE site information such as types of funding received, classroom data, teacher/staff names, language(s) of instruction, Workforce Registry IDs, educator wage, compensation, and licensing data. 

D. How we protect data and personal information 

To protect personal information from unauthorized access and use, First 5 Alameda County employs a variety of security measures. These measures include digital safeguards, such as secure cloud services and encrypted data, as well as physical safeguards, such as secure files and buildings. 

E. How we collect data and personal information 

We collect data and personal information from the following: 

  • Hubbe 
  • Workforce Registry  
  • Sparkler app 
  • Program data collection 
  • High 5 
  • First 5 Stipend application 
  • Measure C Provider Relief Grants portal 
  • Other survey tools 
F. How we share data and information 

Data may be shared with, but not limited to, First 5 California, the California Department of Education, and the California Department of Social Services and/or other identified entities for mandatory reporting purposes.  

Data may also be shared when the law or a court requires disclosure. As a government agency, First 5 Alameda County is subject to the California Public Records Act, and some of the (program and aggregate) data provide may be considered a public record and may be subject to public inspection and copying if not otherwise protected by federal or state law. Similarly, we may share data in response to subpoenas, search warrants, judicial proceedings, court orders, legal process, or other law enforcement measures, to establish or exercise our legal rights, or to defend against legal claims. 

First 5 Alameda County also partners with contracted external agencies that have limited access to Hubbe in order to perform essential functions such as Resource & Referral (R&R) Agencies for coaching and training, WestEd for assessments, and Alameda County Office of Education (ACOE) for CSPP contracts, quality improvement services, rating and funding. 

Data may also be shared with third parties for the purposes of data validation, such as the California Early Care & Education Workforce Registry and Alameda County Alternative Payment agencies, in addition to other contracted consultants and evaluators for the purposes of program evaluation and planning. System partners may receive data from First 5 Alameda for the purposes of service delivery, such as the disbursement of grants and stipends to individuals. 

About Hubbe 

First 5 Alameda County contracts with Hubbe Inc. (Hubbe) to provide a Web-based data collection and program management system for designated ECE sites and/or agencies (Educators) participating in First 5 Alameda County programs and certain funding opportunities.  

The First 5 Alameda County Statement on Use of Hubbe explains First 5’s requirements for the use of Hubbe with respect to the personally-identifiable data collected through the Hubbe site.  

First 5 Alameda County Statement on Use of Hubbe and Hubbe’s Privacy Policy and Terms of Use shall be made accessible to all users of Hubbe Applications via link on Sign-in screens or appropriate location. 

A. Purpose of Hubbe

Hubbe is a program management and reporting system with features designed for use by a wide variety of early education stakeholders, including family child care providers, staff at ECE centers, funders, assessors, and professional development coaches. Some features of Hubbe are designed for and available only to the ECE sites and their authorized staff (“Educators”). First 5 Alameda County staff and County Authorized Users are able to access other features of Hubbe that are specifically designed for their use.  

The purpose of the Hubbe features for Educators is to facilitate the reporting requirements, participate in quality improvement activities, and update data about their programs such as child/student enrollment and demographics, staff data, licensing and other program data on Educator and caregiver’s agency, site and classroom information. Hubbe collects and uses personally identifiable data through the Hubbe site in accordance with, and for the purpose of fulfilling its contract with First 5 Alameda County. Hubbe’s workflow for data submittals includes an administrative review by Educators before data is submitted to First 5 Alameda County.  

For the purposes of First 5 Alameda County’s use of Hubbe, Educators may include the following groups entering data for the purposes described below: 

  • County Authorized Users are First 5 Alameda County staff, staff at agencies that First 5 Alameda County contracts and partners with to implement a variety of services (e.g., coaching, training, communities of practice, rating, assessment, financial incentives), ECE Quality Counts (QC) centers and Family Child Care homes. Some county authorized users support QC sites to submit their annual data reporting using the Common Data File (CDF) Wizard in Hubbe that is required by Quality Counts California (a collaboration between First 5 California, California Department of Education, and the California Department of Social Services).  
  • Resource & Referral Agencies (4Cs of Alameda County, BANANAS Inc., and Hively) enter data about the support (e.g., coaching, technical assistance, community of practice meetings) that they provide to assigned QC sites and have access to the assigned sites’ information (e.g., contact information, staff names and position, ages served, rating and assessments).  
  • WestEd enters Classroom Assessment Scoring System (CLASS ®) assessment data and has access to assigned sites’ contact, location, classroom and staff information for the purpose of sampling and scheduling CLASS observations.  
  • The Alameda County Office of Education (ACOE) partners with First 5 Alameda County to implement QC services for all CSPP agency sites. ACOE has access to each CSPP agency site’s rating, assessment, staffing, quality improvement plans and activities participated in with QC staff (such as coaches), and rating in Hubbe. 
B. Compliance Requirements 

First 5 Alameda County follows Hubbe’s Privacy Policy and Terms of Use’s compliance with the following requirements: 

  • HIPAA – To improve the efficiency and effectiveness of the health care system, the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Public Law 104-191, included Administrative Simplification provisions that required HHS to adopt national standards for electronic health care transactions and code sets, unique health identifiers, and security.  
  • FERPA – The Family Education Rights and Privacy Act (FERPA) is a federal law enacted in 1974 that protects the privacy of student education records. FERPA applies to any public or private elementary, secondary or post-secondary school. It also applies to any state or local education agency that receives funds under an applicable program of the US Department of Education.  
  • CIS IG1 – CIS Controls v8 and v8.1 defines Implementation Group 1 (IG1) as essential cyber hygiene and represents an emerging minimum standard of information security for all enterprises. IG1 is the on-ramp to the CIS Controls and consists of a foundational set of 56 cyber defense Safeguards. 

Collectively, these requirements outline procedures that limit the use, disclosure, or request of protected health information and Personal Identifiable Information (PII) to the minimum necessary for the intended purpose. First 5 Alameda County Statement on Use of Hubbe and Hubbe’s Privacy Policy and Terms of Use shall be made accessible to all users of Hubbe Applications via link on Sign-in screens or appropriate location.  

C. Hubbe’s Privacy Policy and Terms of Use  

1. Access  

Access to the Hubbe Site is regulated by an Allowlist and Blocklist scheme used in conjunction with account password controls. This system features: 

  • Only users on an IP allowlist have full access to Hubbe. 
  • Users with authorized account credentials (account and password) that access Hubbe via a non-allowlist IP may have partial access to Hubbe. Personally-Identifiable Information (PII or PID) such as student name, address, or date of birth are masked by asterisks. 
  • IP’s from commonly known internet trouble regions are blocklisted and have no access to Hubbe. 
  • Strong passwords are required and enforced. 
  • Electronic access is via FIPS 140-2 compliant encryption using SSL/HTTPS. 
  • All users have role and organization-based restrictions. 

2. Information Access and Correction  

Only an authorized Educator may enter data on a student’s record through the Hubbe site. An authorized Educator may review the student record on the Hubbe site, make student record changes, review available assessment reports and otherwise track data for that student. An Educator may contact First 5 Alameda County if the Educator believes there may be an issue with a student record or encounters any issues in accessing or correcting information through the Hubbe site. 

3. Information Use or Disclosure  

Except for the limited exceptions set forth below, Hubbe will not share with, or disclose to, third parties, the names of users, staff, students or other personally identifiable information collected through or in connection with the Hubbe site. Hubbe may, however, use or disclose personally identifiable information: 

  • As requested or required by First 5 Alameda County for the Locally Funded and/or QRIS Programs or the user’s or student’s school or school district. 
  • In response to subpoenas, court orders or legal process, to the extent permitted or required by law. 
  • To protect student or user security, or the security of other persons, consistent with applicable laws. 
  • As required by law. 
  • In connection with the sale, joint venture or transfer of some or all of the assets of Hubbe, subject to written approval from the Funder. 
  • To affiliated companies and contractors providing services for the QRIS Program who are obligated to take appropriate commercially reasonable steps to maintain the confidentiality of such information and use it solely for the purposes specified in this Privacy Policy. 
  • Non-personally identifiable aggregated information collected through this website may be used for quality assurance and for research and development and may be disclosed to third parties in non-personally identifiable form upon receipt of written approval from First 5 Alameda County. 

4. Security and Confidentiality  

Subject to the other provisions of this Privacy Policy and contractual obligations, Hubbe will take commercially reasonable steps to maintain the confidentiality of all personal information and student records collected and managed through the Hubbe site.  

For example, the Hubbe site currently uses industry-standard SSL-encryption to protect user account and password information and uses a secure connection to Hubbe servers, which are protected by firewalls to prevent unauthorized break-ins. The administrative system and authentication mechanisms are protected through the use of SSL encryption of data transmitted via HTTP. As other security methodologies become commercially available, Hubbe may change its current security systems processes or substitute these systems with other security systems or processes.  

Unfortunately, no data transmission over the internet is guaranteed completely secure. Given the inherent operation and structure of the internet, all transmissions are done at your own risk. 

5. Precautions to be Taken by Users  

User Information and access to the Hubbe site is password protected for the privacy and protection of student personal and student assessment data. Educators, and other users are urged to keep confidential all user information and passwords. If storage of this information is required, it is recommended that it be kept in a secure location. To protect data, users should always logoff when exiting the Hubbe Site and not divulge or share user identification or passwords with anyone.  

6. Cookies    

The use of cookies is a common practice for Internet facing web applications. Cookies are small text files that a website transfers to your computer’s browser. Cookies will provide the website with non-personally identifiable information, but does identify your computer, browser and Internet specifications. The Hubbe site uses cookies to measure traffic patterns, personalize content, improve usability, and control security.  

7. IP Addresses  

An IP address is a number automatically assigned to your computer by your Internet service provider. The Hubbe site may collect IP addresses, the associated URLs, domain types, the browser type used to access the site, the country, state and telephone area code where the users’ Internet service provider’s servers are located, the pages of the Hubbe site that users viewed during their visit and any search terms entered on the site. Collection of IP addresses is generally for system administration purposes, to monitor the level of activity on the site and for security and access control reasons.  

8. Links to Other Sites    

The Hubbe site may contain links to other websites related to the QRIS Program on the Internet, which may include Funder sites, or other Hubbe websites. The information practices of those websites are not covered by this Privacy Statement or any other policies or terms applicable to the Hubbe site. You should read the terms and policies of those other websites before supplying information to that site or otherwise using the site.  

9. Site and Content Ownership    

The site is owned and operated by Hubbe. The content thereof is protected by copyrights owned by Hubbe and/or its licensors and/or the Funder. Copyright © 2012-2023 Hubbe Inc. or its affiliate(s). All rights reserved. Effective Date: April 5, 2013. 

10. Changes to the Privacy Policy    

This Privacy Policy for the Hubbe site may be revised from time to time through an updated posting. Revisions are effective upon posting and your continued use of the Hubbe site following the posting of such revisions will indicate your acceptance of such revisions.  

Following First 5 Alameda County’s annual CDF data collection process, Hubbe users are required to read and accept the First 5 Alameda County Statement on Use of Hubbe and Hubbe’s Privacy Policy and Terms of Use on an annual basis. 

By clicking “Accept” below, I agree to the terms, conditions and requirements of the First 5 Alameda County Statement on the Use of Hubbe and Hubbe’s Privacy Policy and Terms of Use. 

If you have any questions concerning the First 5 Alameda County Statement Use of Hubbe or Hubbe’s Privacy Policy and Terms of Use, please contact First 5 Alameda County at privacy@first5alameda.org.