HMIS Notices

1. This notice describes the Homeless Management Information System (HMIS) privacy policy and practices of New Chapter Living. Our main office is located in Sacramento, CA.
2. The policy and practices in this notice cover the collection, use and maintenance of protected personal information for persons served by New Chapter Living, as an organization affiliated with the Sacramento Continuum of Care (CoC). If this agency is a covered entity under HIPAA, you may have additional rights regarding your protected health information and these rights will be described to you in the agency's Policy of Privacy Practices under HIPAA.
3. Personally Identifiable Information / Protected Personal information (hereby known as PPI) is any information we maintain about a client that:
   1. allows identification of an individual directly or indirectly;
   2. can be manipulated by a reasonably foreseeable method to identify a specific individual; or
   3. can be linked with other available information to identify a specific client.
4. We adopted this policy because of the U.S. Department of Housing and Urban Development (HUD) issued standards for Homeless Management Information Systems. We intend our policy and practices to be consistent with those standards. See 69 Federal Register 45888 (July 30, 2004).
5. This notice informs our clients, our staff, and others how we process personal information. We follow the policy and practices described in this notice.
6. We may amend this notice and our policy or practices at any time. Amendments may affect personal information that we obtained before the effective date of the amendment. Amendments to this privacy statement will be approved by the HMIS System Administrator.
7. We give a written copy of this privacy statement to any individual who asks.

1. We collect PPI only when appropriate to provide services or for another specific purpose of our organization or when required by law. We may collect information for these purposes:
   1. to provide or coordinate services to clients;
   2. to produce aggregate-level reports regarding use of services;
   3. to track individual project-level outcomes;
   4. to identify unfilled service needs and plan for the provision of new services;
   5. to conduct research for consulting and/or educational purposes; and
   6. to accomplish any and all other purposes deemed appropriate by the CoC.
2. We only use lawful and fair means to collect personal information.
3. We normally collect personal information with the knowledge or consent of our clients. If you seek our assistance and provide us with personal information, we assume that you consent to the collection of information as described in this notice.
4. We share this data with Sacramento Steps Forward (SSF); the agency appointed by the CoC to manage all personal information we record about our clients.
5. We post a Consumer Notice at our intake desk or other location explaining the reasons we ask for personal information.

We use or disclose personal information for activities described in this part of the statement. We may or may not make any of these uses or disclosures with your information. We assume that you consent to the use or disclosure of your personal information for the purposes described below and for other uses and disclosures that we determine to be compatible with these uses or disclosures:

1. to provide or coordinate services to individuals; data may be shared with other HMIS participating agencies (a copy of participating agencies can be found at www.sacramentostepsforward.org);
2. for functions related to payment or reimbursement for services;
3. to carry out administrative functions such as legal, audits, personnel, oversight, and management functions;
4. to create de-identified (anonymous) information that can be used for research and statistical purposes without identifying clients;
5. when required by law to the extent that use or disclosure complies with and is limited to the requirements of the law;
6. to avert a serious threat to health or safety when necessary to prevent or lessen a serious imminent threat to the health or safety of an individual or the public;
7. to report about an individual we reasonably believe to be a victim of abuse, neglect or domestic violence to a governmental authority authorized by law to receive such reports;
8. to a law enforcement official for a law enforcement purpose (if consistent with applicable law and standards of ethical conduct) under specific circumstances such as a lawful court order, subpoena, or written request meeting legal requirements;
9. to comply with government reporting obligations for HMIS and for oversight of compliance with the HMIS requirements.

Before we make any use or disclosure of your personal information that is not described here, we seek your consent first.

1. You may inspect and have a copy of your personal information that we maintain. We will offer to explain any information that you may not understand.
2. We will consider a request from you for correction of inaccurate or incomplete personal information that we maintain about you. If we agree that the information is inaccurate or incomplete, we may delete it or we may choose to mark it as inaccurate or incomplete and to supplement it with additional information.
3. We may deny your request for inspection or copying of personal information if the information was compiled in anticipation of litigation, is about another individual, was obtained under a promise of confidentiality, or disclosure would endanger the life or safety of any individual.
4. If we deny a request for access or correction, we will explain the reason for the denial and document the request and reason in your personal information.
5. We may reject repeated or harassing requests for access to or correction of personal information.

1. We collect only personal information that is relevant to the purposes for which we plan to use it. To the extent necessary for those purposes, we seek to maintain only personal information that is accurate, complete, and timely.
2. We will dispose of personal information not in current use seven (7) years after the information was created or last changed. As an alternative to disposal, we may choose to remove identifiers from the information.
3. We may keep information for a longer period if required to do so by an applicable statute, regulation, contract, or other requirement.

1. We accept and consider questions or complaints about our privacy and security policies and practices. Any questions or complaints should be addressed to the HMIS Site Administrator at New Chapter Living, Sacramento, CA — 916-577-6198 x1. The HMIS Site Administrator will respond in writing within 30 days. If the response is unsatisfactory, your original questions and/or complaints, along with the response, should be forwarded to the HMIS System Administrator, 1331 Garden Highway, Suite 100, Sacramento CA 95833. The HMIS System Administrator will respond in writing within 30 days to the question or complaint.
2. All members of our staff (including employees, volunteers, affiliates, contractors and associates) are required to comply with this privacy Policy. Each staff member must receive and acknowledge receipt of a copy of this privacy statement.

Version 2.0, Effective November 14, 2018, Original Version