THIS PRIVACY NOTICE EXPLAINS UNDER WHAT CIRCUMSTANCES WE MAY SHARE AND DISCLOSE YOUR INFORMATION FROM THE LA/OC HMIS. THIS NOTICE ALSO EXPLAINS YOUR RIGHTS REGARDING YOUR CONFIDENTIAL INFORMATION. PLEASE READ IT CAREFULLY.
Jamboree Housing Corporation collects and shares information about individuals who access our services. The information is confidentially stored in a local electronic database called the Greater Los Angeles/Orange County Homeless Management Information System (LA/OC HMIS). The LA/OC HMIS securely records information (data) about persons accessing housing and homeless services within the Los Angeles and Orange Counties.
We ask for your permission to share confidential personal information that we collect about you and your family. This confidential information is referred to as Protected Personal Information (PPI). We are required to protect the privacy of your PPI by complying with the privacy practices described in this Privacy Notice.
Why We Collect and Share Information
The information we collect and share in the HMIS helps us to efficiently coordinate the most effective services for you and your family. It allows us to complete one universal intake per person; better understand homelessness in your community; and assess the types of resources needed in your local area.
By collecting your information for HMIS, we are able to generate statistical reports requested by the Department of Housing and Urban Development (HUD).
The Type of Information We Collect and Share in the HMIS
We collect and share both PPI and general information obtained during your intake and assessment, which may include but is not limited to:
How Your Personal Information Is Protected in the HMIS
Your information is protected by passwords and encryption technology. Each HMIS user and participating organization must sign an agreement to maintain the security and privacy of your information. Each HMIS user or participating organization that violates the agreement may have access rights terminated and may be subject to further penalties.
How PPI May Be Shared and Disclosed
Unless restricted by other laws, the information we collect can be shared and disclosed under the following circumstances:
Providing Your Consent for Sharing PPI in the HMIS
If you choose to share your PPI in the LA/OC HMIS, we must have your written consent. Exception: In a situation where we are gathering PPI from you during a phone screening, street outreach, or community access center sign-in, your verbal consent can be used to share your information in HMIS. If we obtain your verbal consent, you will be requested to provide written consent during your initial assessment. If you do not appear for your initial assessment, your information will remain in HMIS until you revoke your consent in writing.
You have the right to receive services even if you do not consent to share your PPI in the LA/OC HMIS.
How to Revoke Your Consent for Sharing Information in the HMIS
You may revoke your consent at any time. Your revocation must be provided either in writing or by completing the Revocation of Consent form. Upon receipt of your revocation, we will remove your PPI from the shared HMIS database and prevent further PPI from being added. The PPI that you previously authorized to be shared cannot be entirely removed from the HMIS database and will remain accessible to the limited number of organization(s) that provided you with direct services.
Your Rights to Your Information in the HMIS
You have the right to receive the following, no later than five (5) business days of your written request:
You can exercise these rights by making a written request to this organization.
Your Privacy Rights Regarding Your Information in the HMIS
If you believe your privacy rights have been violated, you may send a written grievance to this organization. You will not be retaliated against for filing a grievance.
If your grievance is not resolved to your satisfaction, you may send a written grievance appeal to your HMIS Administrator.
Amendments to this Privacy Notice
The policies in this notice may be amended at any time. These amendments may affect information obtained by this organization before the date of the change. Amendments regarding use or disclosure of PPI will apply to information (data) previously entered in HMIS, unless otherwise stated. All amendments to this privacy notice must be consistent with the requirements of the federal HMIS privacy standards. This organization must keep permanent documentation of all privacy notice amendments.
HMIS CONSUMER NOTICE
Sacramento CoC Homeless Management Information System
Approved 11.14.2018
This Agency receives funding from U.S. Department of Housing and Urban Development to provide services for homeless and near homeless individuals and their families. A requirement of this funding is that the Agency participates in the Sacramento Continuum of Care, Homeless Management Information System (HMIS), which collects basic information about consumers receiving services from this Agency. This requirement was enacted in order to get a more accurate count of individuals and families who are homeless, and to identify the need for different services.
We only collect information that we consider to be appropriate. The collection and use of all personal information is guided by strict standards of confidentiality. A copy of our Privacy Notice Statement describing our privacy practice is available to all consumers upon request. Agencies participating in HMIS share information with local agencies partnered in HMIS unless they serve a protected population, in compliance with applicable federal and state law. The list of HMIS Partner Agencies is available to consumers at intake upon request. Sharing information among agencies allows those agencies to work in a cooperative manner to provide you with better services.
You have the right to refuse certain data answers to be entered into the HMIS database. As such, we request every consumer whom we serve to sign a “Consumers Informed Consent & Release of Information Authorization”. Although you will receive services if you refuse to provide data answers, your eligibility to receive some specialized services may be impacted by not participating in HMIS.
You do have the ability to share your personal information with other area agencies that participate in the network by completing a “Consumers Informed Consent & Release of Information Authorization” form. This will allow those agencies to work in a cooperative manner to provide you with efficient and effective services.
THIS NOTICE DESCRIBES HOW INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
If you have any questions about this Notice, you may contact either your service provider, or:
Regional Task Force on Homelessness
4699 Murphy Canyon Rd., San Diego, CA 92123 858-292-7627
Your information is personal, and the Regional Task Force on Homelessness (RTFH) is committed to protecting it. Your information is also very important to our ability to provide you with quality services, and to comply with certain laws. This notice describes the privacy practices our employees and other personnel are required to follow in handling your information.
We are legally required to: Keep your information confidential, give you this notice of our legal duties and privacy practices with respect to your information, and comply with this notice.
CHANGES TO THIS NOTICE
We reserve the right to revise or change the terms of this Notice, and to apply those changes to our policies and procedures regarding your information. To obtain a copy of this notice you can either ask your treatment provider or any staff person, or go to the RTFH’s web site at http://www.rtfhsd.org/.
HOW WE MAY USE AND DISCLOSE YOUR INFORMATION
For Housing: We create a record of your information including housing services you receive at our partner agencies. We need this record to provide you with quality services and to comply with certain legal requirements.
Your service team may use or disclose your information to other personnel who are involved in providing services for you. For example, a housing navigator may need to know disability information to provide appropriate housing resources. Your service team may share your information in order to coordinate the different things you need, such as referrals and services.
We also may use and disclose your information to people outside this agency who may be involved in your service coordination when you access services from our partner agencies.
We may use and disclose your information to contact you with a reminder that you have an appointment and you have the right to tell us how you want to receive appointment reminders. At your request, a form will be provided to you for that purpose.
We may use and disclose your information to recommend service options or alternatives that may be of interest to you. Additionally, we may use and disclose your information to tell you about health-related benefits or services that may be of interest to you for example, Medi-Cal eligibility or Social Security benefits. You have the right to refuse this information.
For Service Corroboration: We may use or disclose basic information about you so that you do not have to provide information more than once. This sharing, only when you access one of the participating agencies, can help avoid duplication of services and referrals that you are already receiving.
For RTFH Operations: We may use and disclose information about you for administrative operations. These uses and disclosures are necessary to run our agency and make sure that all of our clients receive quality services. For example, we may use information to review our services and evaluate the performance of our staff in providing those services.
We may also combine information from our participating agencies to decide what additional services should be offered, what services are not needed, and whether certain new services might be effective.
We may also combine the information with information from other agencies to compare how we are doing and see where we can make improvements in the services we offer. We may de-identify your information so others may use it to study services delivery without learning who the specific clients are.
Unless you object, we may disclose your information to any other person identified by you who is involved in your services. Your objection must be in writing (at your request, a form will be provided to you for this purpose). We will not honor your objection in circumstances where doing so would expose you or someone else to danger.
In the event of a disaster we may disclose your information to a housing disaster relief agency.
USES AND DISCLOSURES THAT DO NOT REQUIRE YOUR AUTHORIZATION
Research: Under certain circumstances, we may use and disclose information about you for research purposes. For example, a research project may involve comparing your service levels and of all clients who received similar services. All research projects, however, are subject to a special approval process. This process evaluates a proposed research project and its use of information, trying to balance the research needs with clients’ need for privacy of their information. Before we use or disclose information for research, the project will have been approved through a research approval process, but we may, however, disclose information about you to people preparing to conduct a research project, for example, to help them look for clients with specific needs, so long as the information they review does not leave our agency.
As Required by Law: We will use and disclose information when required to do so by federal or state law or regulation.
To Avert a Serious Threat to Health or Safety: We may use and disclose your information when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person.
Public Health Activities: We may disclose your information for public health activities such as to report the abuse or neglect of children, elders and dependent adults;
Abuse, Neglect or Domestic Violence: We may disclose your information when notifying the appropriate government authority if we believe you have been the victim of abuse, neglect or domestic violence. We will only make this disclosure if you agree or when required or authorized by law.
Oversight Activities: We may disclose your information to a federal oversight agency, such as the Department of Housing and Urban Development, for activities authorized by law. These oversight activities are necessary for the government to monitor government service programs, and compliance with civil rights laws.
Court Orders and Subpoenas: If you are involved in a lawsuit or a dispute, we may disclose your information in response to a court or administrative order. We may also disclose your information in response to a subpoena, discovery request, or other lawful process by someone else involved in a dispute.
Law Enforcement: We may disclose your information if asked to do so by law enforcement officials in any of the following circumstances:
OTHER USES OF YOUR INFORMATION
Other uses and disclosures of your information not covered by this Notice or the laws that apply to us will be made only with your written authorization. If you provide us authorization to disclose your information, you may revoke that authorization, in writing, at any time. If you revoke your authorization, we will no longer use or disclose your information for the reasons covered by the authorization, except that, we are unable to take back any disclosures we have already made when the authorization was in effect, and we are required to retain our records of the services that we provided to you.
YOUR RIGHTS REGARDING INFORMATION ABOUT YOU
Right to Inspect and Obtain Copies: With certain exceptions, you have the right to inspect and obtain copies of your information from our records. To inspect and obtain copies of your information, you must submit a request in writing to your service provider where you received services. If you request a copy of your information, they may charge a fee for the costs of copying, mailing or other supplies associated with your request.
We may deny your request to inspect and obtain copies of parts of your information. If you are denied the right to inspect and obtain copies of your information in our records, you may appeal this decision and request that another services professional designated by the RTFH, who was not involved in your treatment review the denial. (At your request, a form will be provided to you for this request.)
Right to Request an Amendment: If you feel that your information in our records is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as we keep the information. To request an amendment, you must submit a request in writing to your service provider. In addition, you must tell your provider the reason for the amendment, and at which agency you want your request to apply to. Your request will become part of your record. (At your request, a form and a list of participating agencies will be provided to you for this purpose.)
Right to Request Restrictions: You have the right to request that we follow additional, special restrictions when disclosing your information. We are not required to agree to your request. If we do agree, we will comply with your request unless the information is needed to provide you with emergency treatment as determined by a doctor. To request restrictions, you must make your request in writing to your service provider. In your request, you must tell us what information you want to limit, the type of limitation, and to whom you want the limitation to apply.
Right to Request Confidential Communications: You have the right to request that we communicate with you about appointments or other matters related to your services in a specific way or at a specific location. For example, you can ask that we only contact you at work, or by mail at a post office box. To request confidential communications, you must make your request in writing to your Agency case manager or the person in charge of your services. Your request must specify how or where you wish to be contacted.
Right to a Paper Copy of This Notice: You may ask us for a paper copy of this Notice at any time. Even if you have agreed to receive this Notice electronically, you are entitled to receive a paper copy of this Notice. To obtain a paper copy of this Notice, ask any staff person. You may also obtain a copy of this Notice at our website www.rtfhsd.org.
COMPLAINTS
You have the right to file a complaint if you believe that RTFH staff has not complied with the practices outlined in this notice. All complaints must be submitted in writing. You will not be penalized in any way for filing a complaint.
If you believe your privacy rights have been violated, you may file a complaint with the RTFH.
To file a complaint with the RTFH, contact:
Regional Task Force on Homelessness
4699 Murphy Canyon Rd., San Diego, CA 92123
858-292-7627
To file a complaint with the State of California, contact:
www.privacy.ca.gov
866-785-9663
800-952-5210
Our Notice of Privacy Practices is subject to change. If we change our notice, you may obtain a copy of the revised notice by accessing our web site, http://www.rtfhsd.org or by contacting any staff person involved in your services.
If you have any questions about our Notice of Privacy Practices, please contact:
Regional Task Force on Homelessness
4699 Murphy Canyon Rd., San Diego, CA 92123
858-292-7627