SECTION 420 - DONATED DATA PROCESSING TRAINING

A. PURPOSE OF THIS PROCEDURE

The purpose of this procedure is to provide a method for County departments to accept reduced cost or free training without creating the appearance of a conflict of interest. Many hardware and software vendors provide data processing related training on a regular commercial basis and participants are expected to pay a competitive commercial fee for attendance. Many companies, however, also offer special training programs at reduced cost to potential customers, or present customers likely to make additional purchases. Attendance by a County staff member at such a training program could constitute acceptance of a gift under the State's Political Reform Act.

Board of Supervisors Resolution No. 578-84 provides authorization for the acceptance of such training; it also allows for the County Administrative Officer and/or the Information Services Director to assign County staff members to attend such free or reduced cost training on behalf of the County. Use of this procedure will eliminate the need for County staff and officials, including elected officials, to report such training as a gift under the Fair Political Practices Commission guidelines.

B. WHEN DOES THIS PROCEDURE APPLY?

This procedure applies only to training provided within the State of California by private companies or individuals that have, or might have, a business, financial or vendor relationship with the County. It does not apply to training provided by other governmental agencies, educational institutions or professional organizations associated with the County or County staff persons. It also does not apply to training offered on an open basis to the public, or to most training offered by private nonprofit organizations.

This procedure is intended to apply to training sessions or education of a substantial nature and does not apply to ordinary commercial sales presentations. It is not intended to apply to "seminars" which may have a significant educational component and which may be of substantial benefit to the County, but which are in fact sales presentations. Such events typically last one day or less and may include incidental food, beverages or lunch. Generally, their prominent advertising, clear commercial orientation, and focus on vendor products and services distinguish such presentations. As a precaution, any education, training or sales presentation, which lasts more than one day, should be handled under this procedure.

Training provided outside the State must be reviewed and approved by the Board of Supervisors in the same manner as any other out-of-state travel. It is advisable to obtain the recommendation of the Information Services Director when requesting Board approval for out-of-state training. Questions about specific training opportunities should be directed to the Information Services Director.

C. PROCEDURAL STEPS

Any training or educational opportunity of interest to a department or County staff member should be brought to the attention of the Information Services Director by interoffice memo.

The Information Services Director shall evaluate training or educational opportunities to determine whether the program is of benefit to the County.

The Information Services Director, in cooperation with the requesting department, will determine which County staff members and/or County officials, if any, should attend such educational or training program under consideration. The County Administrative Officer must approve any assignment that includes the Information Services Director.

The Information Services Director shall prepare a list of all assignments for training and submit this list to the Board of Supervisors on the agenda following the end of each calendar quarter.