"Caring For Those In Need Of Shelter"

Audrain County Shelter Resource Coalition
Homeless Missourians Information System (HMIS)

Privacy and Security Notice

A written copy of this Policy is available to all who request it. You may do so by contacting us at ravae@acsrcmo.org or clicking here to download.

I. PURPOSE:
This notice describes the privacy policy of this agency. The policy may be amended at any time. We may
use or disclose your information to provide you with services and to comply with legal and other
obligations. We assume that, by requesting services from our agency, you agree to allow us to collect
information and to use or disclose it as described in this notice and as otherwise required by law.

The Homeless Missourians Information System (HMIS) was developed to meet a data collection
requirement made by the United States Congress and the Department of Housing and Urban
Development (HUD). Congress passed this requirement in order to get a more accurate count of
individuals who are homeless and to identify the need for and use of different services by those
individuals and families. We are collecting statistical information on those who use our services and
report this information to a central data collection system.

In addition, many agencies in this area use HMIS to keep computerized case records. This information
may be provided to other HMIS participating agencies. The information you may agree to allow us to
collect and share includes: basic identifying demographic data, such as name, address, phone number
and birth date; the nature of your situation and the services and referrals you receive from this agency.
This information is known as your Protected Personal Information or PPI. All agencies using the HMIS
share their data with other participating agencies, with the exception of Blind Service Providers. These
blind agencies serve specific protected client populations, such as domestic abuse, sexual abuse,
HIV/AIDS, alcohol and/or substance abuse, and mental health, and do not share client information.

GENERALLY, all personal information we maintain is covered by this policy. Generally, your personal
information will only be used by this agency and other agencies to which you are referred for services.

Information shared with other HMIS agencies helps us to better serve our clients, to coordinate client
services, and to better understand the number of individuals who need services from more than one
agency. This may help us to meet your needs and the needs of others in our community by allowing us
to develop new and more efficient programs. Sharing information can also help us to make referrals
more easily and may reduce the amount of paperwork.

Maintaining the privacy and safety of those using our services is very important to us. Information
gathered about you is personal and private. We collect information only when appropriate to provide
services, manage our organization, or as required by law.

II. CONFIDENTIALITY RIGHTS:
This agency has a confidential policy that has been approved by its Board of Directors. This policy
follows all HUD confidentiality regulations that apply to this agency, including those covering programs
that receive HUD funding for homeless services. Separate rules apply for HIPPA privacy and security
regulations regarding medical records.
This agency will use and disclose personal information from HMIS only in the following circumstances:

To provide or coordinate services to an individual.

For functions related to payment or reimbursement for services.

To carry out administrative functions including, but not limited to legal, audit, personnel,
planning, oversight, or management functions.

Databases are used for research, where all identifying information has been removed.

Contractual research where privacy conditions are met.

Where a disclosure is required by law and disclosure complies with and is limited to the
requirements of the law. Instances, where this might occur, are during a medical emergency, to
report a crime against staff of the agency or a crime on agency premises, or to avert a serious
threat to health or safety, including a person’s attempt to harm himself or herself.

To comply with government reporting obligations.

In connection with a court order, warrant, subpoena, or other court proceeding where disclosure
is required.

III. YOUR INFORMATION RIGHTS:
As a client receiving services at this agency, you have the following rights:

Access to your record. You have the right to review your HMIS record. At your request, we will
assist in viewing the record within five working days.

Correction of your record. You have the right to request to have your record corrected so that
information is up-to-date and accurate to ensure fairness in its use.

Refusal. Our ability to assist you depends on having certain personal identifying information. If
you choose not to share the information we request, we reserve the right to decline to provide
you with services, as doing so could jeopardize our status as a service provider.

Agency’s Right to Refuse Inspection of an Individual Record. Our agency may deny you the
right to inspect or copy your personal information for the following reasons
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• • information is compiled in reasonable anticipation of litigation or comparable
    proceedings;

  • information about another individual other than the agency staff would be disclosed;

  • information was obtained under a promise of confidentiality other than a promise from
    this provider and disclosure would reveal the source of the information or

  • information, the disclosure of which would be reasonably likely to endanger the life or
    physical safety of any individual.

• Harassment. The agency reserves the right to reject repeated or harassing requests for access or
  correction. However, if the agency denies your request for access or correction, you will be
  provided written documentation regarding your request and the reason for denial. A copy of that
  documentation will also be included in your client record.

• Grievance. You have the right to be heard if you feel that your confidentiality rights have been
  violated, if you have been denied access to your personal records, or if you have been put at
  personal risk, or harmed. Our agency has established a formal grievance process for you to use
  in such a circumstance. To file a complaint or grievance you should contact our Executive
  Director Ra’Vae Moore at: 573-567-5160 or by email at ravae@acsrcmo.org

IV. HOW YOUR INFORMATION WILL BE KEPT SECURE:
Protecting the safety and privacy of individuals receiving services and the confidentiality of their records
is of paramount importance to us. Through training, policies, procedures and software, we have taken
the following steps to make sure your information is kept safe and secure:

• The computer program we use has the highest degree of security protection available.

• Only trained and authorized individuals will enter or view your personal information.

• Your name and other identifying information will not be contained in HMIS reports that
  are issued to local, state or national agencies.

• Employees receive training in privacy protection and agree to follow strict confidentiality
  standards before using the system.

• The server/database/software only allows individuals access to the information. Only
  those who should see certain information will be allowed to see that information.

• The server/database will communicate using 128-bit encryption-an Internet technology
  intended to keep information private while it is transported back and forth across the
  Internet. Furthermore, identifying data stored on the server is also encrypted or coded
  so that it cannot be recognized.

• The server/database exists behind a firewall-a device meant to keep
  hackers/crackers/viruses/etc. away from the server.

• The main database will be kept physically secure, meaning only authorized personnel
  will have access to the server/database.

• System Administrators employed by the HMIS and the agency support the operation of
  the database. The administration of the database is governed by agreements that limit
  the use of personal information to providing administrative support and generating reports
  using aggregated information. These agreements further insure the confidentiality of your personal information.

VI. COMPLIANCE WITH OTHER LAWS
This agency complies with all other federal, state and local laws regarding privacy rights. Consult with an
attorney if you have questions regarding these rights.

VII. PRIVACY NOTICE AMENDMENTS:
The policies covered under this Privacy Notice may be amended over time and those amendments may
affect information obtained by the agency before the date of the change. All amendments to the Privacy
Notice must be consistent with the requirements of the Federal Standards that protect the privacy of
consumers and guide HMIS implementation and operation.

VIII. Website
We maintain a copy of the Privacy Notice on our website at: https://acsrcmo.org/