Homeless Management Information System Privacy Notice

HMIS/SERVICE PROVIDER PRIVACY NOTICE

This notice applies to all service providers who utilize the ECHO West Texas Database, also known as HMIS, and addresses how information about clients may be used and disclosed as well as client rights over their information. This notice may be amended at any time, and amendments may affect information obtained before the date of the amendment.

Data Collection & Purpose

The Homeless Management Information System (HMIS) is an information gathering system used to collect data on housing and services provided to homeless individuals and families as well as information on persons at risk of homelessness. Participating providers are required to collect universal data elements from all clients, including personally identifiable information (PII), demographic information, and housing history. This information is used to better understand the extent and nature of homelessness in Lubbock County, evaluate effectiveness of agency responses, and improve future housing and service provisions. Some providers are required by their funders to obtain certain additional information to assess services, determine eligibility, and monitor outcomes.

Most federally funded homelessness programs require client information to be recorded in an HMIS database. The ECHO database has strict privacy measures and policies in place to ensure security of client information. We only collect information deemed appropriate and necessary for program operation or information that is required by law or required by funders of this site. We do not need your consent to enter a record of your visit into the HMIS; however, you may refuse to have your personal identifying information within said record and still be eligible to receive services.

If you have any questions or concerns about the information provided, please speak to an intake worker.

Permitted Data Uses and Disclosures

All HMIS participating agencies are held to strict federal, state, and local standards when it comes to the confidentiality of PII (‘Personally Identifying Information’, any information that can be used to identify an individual such as date of birth, social security number, client name). There are limitations to how your information can be used after collection and how it can be shared:

Required uses and disclosures:

1. Client must have access to their information; and

2. Disclosures for oversight of compliance with HMIS privacy and security standards.

Permitted uses and disclosures:

3. To provide and/or coordinate services to an individual or family;

4. For functions related to payment or reimbursement for services;

5. To carry out administrative functions, including but not limited to legal, audit, personnel, oversight and management functions;

6. For creating de-identified reporting from PII;

7. Uses and disclosures required by law;

8. Uses and disclosures to avert a serious threat to health or safety;

9. Uses and disclosures about victims of abuse, neglect or domestic violence;

10. Uses and disclosures for research purposes;

11. Uses and disclosure for law enforcement purposes;

Some providers may have more restrictive privacy policies which can be obtained upon request from such providers.

Client Control Over Data

We recognize every legal adult as the owner of all information about themselves, and any parent, legal guardian, or legal power of attorney as the designated owner of all information about any household members under their guardianship. By seeking assistance from the HMIS provider and consenting to your personal information being entered into a record to us, you transfer responsibility of your HMIS record to us, and we are responsible for handling your record in accordance with HMIS privacy policies and any applicable federal, state, or local requirements.

Client Rights

➢ You retain the right to ownership of your information within the HMIS

➢ You have the right to refuse to answer any question you do not feel comfortable answering and not have it recorded in the HMIS

➢ You have the right to view and correct any information gathered within the HMIS upon request

➢ You have the right to ask questions or submit grievances to your provider regarding privacy and security policies and practices

➢ You have the right to an anonymized record within the HMIS with a request from this service provider

➢ You have the right to choose if your information is shared outside of this agency and/or with outside researchers and other providers outside of the HMIS; NOTE: a decision not to share data does not prohibit this project from entering your data into HMIS. It only prohibits your information from being shared in accordance with your wishes.

If you do not understand any of the information within this form, you may ask your intake worker for further explanation or an alternative format. You can receive a copy of any and all HMIS policies and procedures from your intake worker.