HOUSE OF HOPE CDC PRIVACY POLICY

 
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DATA PRIVACY STATEMENT

 
The RICoC has executed a Memorandum of Understanding with Rhode Island Coalition for the Homeless (RICH) to act the HMIS Lead Agency, administering the HMIS on behalf of RICoC, is governed by the RICoC HMIS Steering Committee. As a CHO (Covered Homeless Organization or Participating Agency), House of Hope CDC has adopted the following privacy policy related to the use of the RICoC HMIS. As an agency with access to the HMIS, House of Hope CDC is required to sign and Agency Partnership Agreement. All HMIS Lead Agency personnel (including employees, volunteers, affiliates, contractors and associates), and all participating agencies and their personnel, are required to comply with this notice. All personnel in the RICoC with access to HMIS must receive and acknowledge receipt of a copy of this Notice, agree in writing to comply with it, and receive training on this Privacy Policy before being given access to HMIS.
 

This Privacy Policy applies to all Personally Identifiable Information that is collected and maintained in the RICoC HMIS, including electronic and hard copies derived from HMIS. Personally, Identifying Information, also known as Protected Personal Information (PPI), is defined by the 2004 HUD Data and Technical Standards as:
“Any information maintained by of for a Covered Homeless Organization about a living homeless client or homeless individual that:

Identifies, either directly or indirectly, a specific individual;
can be manipulated by a reasonably foreseeable method to identify a specific individual; or
can be linked with other available information to identify a specific individual.”
 
The RICoC HMIS will use only unidentified, aggregated data for homeless policy and planning decisions, in preparing federal, state, or local applications for homelessness funding, to demonstrate the need for and effectiveness of programs, and to obtain a system-wide view of program utilization in the state. In accordance with federal law, all participating agencies are required to post the HMIS Data Statement at their intake desks, offices, or website, as applicable, explaining the reasons information is requested.
 
The RICoC has adopted an approach to client consent for use and disclosure of information consistent with regulations set forth by HUD in Federal Register/ Vol. 69, No. 146 / Friday, July 30, 2004 / Notices and with the Coordinated Entry Management and Data Guide (published October 2018):
“Use” means, with respect to PII, the sharing, employment, application, utilization, examination, or analysis of such information internally within the HMIS participating agency that maintains such information or within the HMIS Lead.
“Disclosure” means, with respect to PII, the release, sharing, transfer, provision of access to, or divulging of information to an organization outside the HMIS participating agency holding the information or outside the HMIS Lead Agency. Disclosure of any information to any entity that has not signed a Data Sharing MOU and is not required by law can only occur with written client consent.
Only information that is needed for

coordination of services and case management,
administration,
billing, and
analytics are collected.
 
Uses and disclosures are further defined below:

Coordination of services and case management: Agencies may use or disclose client information for case management purposes to provide or coordinate services for you and your family to help you end your homelessness. Participating agencies may use or disclose your information to locate suitable services or housing, to conduct referrals and assessments, to determine program eligibility, and to otherwise collaborate to address your specific needs and circumstances.
 
Administrative Uses: Agencies may use client information to carry out administrative functions internally including but not limited to legal, audit, personnel, oversight, and management functions.
 
Billing Use: Agencies may use client information for functions related to payment or reimbursement for services if required by the funder/ billing agency.
 
To carry out maintenance and operation of the RICoC HMIS;
 
To create reports for the RICoC that include your data but only in a manner in which your identity is not disclosed
 
Research Use: Agencies may use client information for internal analysis including but not limited to evaluating program effectiveness, creating an unduplicated database on clients’ service within the system, understanding local and regional needs and trends in homelessness, and assessing an agency’s progress towards achieving goals and objectives. PII that could be sued to identify a client should never be included in these reports. The release of aggregate HMIS data to an entity that is not a CHO/Participating Agency must be approved by the RICoC Data and HMIS Committee and RICoC Board of Directors.