Accepting the Substitute Address
Program participants use the substitute address when interacting with state and local government agencies. When presented an authorization card, state and local government agencies must accept the substitute address as the participant’s address when creating a public record. The substitute address may be used in place of the participant’s home, work, school, or mailing address. Agencies cannot require the participant to disclose her or his real address.
Examples of public records where program participants may use the substitute address:
- Driver license/identification card/vehicle registration
- Voter registration
- Public schools
- Public library cards
- Social services (nutrition assistance, child support, AHCCCS, cash assistance, etc.)
- Police reports
Upon a participant’s request, a government agency must redact the real address of an ACP participant from any agency record that was created up to 90 days prior to the ACP enrollment date. The enrollment date is reflected on the authorization card as DOI.
An employee shall not intentionally or knowingly disclose a program participant’s real address or telephone number unless the disclosure is permissible by law. This prohibition only applies if the information was obtained during the course of the employee’s official duties and at the time of disclosure, the employee had specific knowledge the address or telephone number belonged to a program participant. A violation of this law is a class 1 misdemeanor.
State or local government agencies must have a bona fide statutory or administrative need for a program participant’s real address in order to request a disclosure. Participants will have an opportunity to be heard before her/his address is released, unless the participant is a suspect in a crime. Disclosure requests can be made to the executive director Monday- Friday, 8 a.m. – 5 p.m. Allow 5-7 business days for the request to be completed.
A criminal justice agency or official may request the expedited release of a program participant’s address if the request is regarding a criminal justice investigation, hearing, proceeding or trial. Any person who requests an emergency release shall certify the agency has a system in place to protect the real address from the public and from personnel who are not involved in the trial, hearing, proceeding, or investigation. In cases of an emergency, program staff is available to law enforcement on a 24 hour basis by calling the ACP government agency phone line.
A state or local government agency that makes a request for a participant’s real address must have adopted procedures for protecting the confidentiality of the participant’s real address before the address will be disclosed. Staff can assist agencies in providing feedback, suggestions, or review of any adopted procedure.