HMIS Notice of Privacy Practices

Effective 06-01-04, Sheltering Wings Center for Women

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.

ICHHI's Hoosier Management Information System (HMIS)

When you request services from this agency, we enter information about you and members of your family that are with you into a computer system called HMIS, or Hoosier Management Information System. HMIS is a project of the Indiana Coalition on Housing and Homeless Issues, Inc. (ICHHI). HMIS is used by many agencies in Indiana that provide services to persons and families in need. The information collected in the HMIS will help us do things like reduce duplicate intakes, document the need for services, and generate reports such as the number of persons who are homeless in Indiana.

How your information in the HMIS may be used or disclosed without your consent

Unless restricted by other laws, the information can be used by or disclosed to the following without your specific written consent:

• Authorized people who work in this agency for administrative purposes related to providing services to you or your family, or for billing or funding purposes.
• Auditors or others who review the work of this agency or need to review the information to provide services to this agency.¹
• The HMIS system administrator, ICHHI, and its designees, and the HMIS developer, Foothold Technology, Inc. They may see the information for administrative purposes (for example, to check data errors).
• Individuals performing academic research who have signed a research agreement with this agency or ICHHI. Your name, social security number or other identifying information will not appear in any research report.²
• This agency or ICHHI may use your information to create data that has your identifying information removed. Also, this agency may disclose to a third party your information so that the third party can create data that has your identifying information removed.
• Government or social services agencies that are authorized to receive reports of abuse, neglect or domestic violence, when such reports are required by law or standards of ethical conduct.
• A coroner or medical examiner or funeral director to carry out their duties.
• Authorized federal officials for the conduct of certain national security or certain activities associated with the protection of certain officials.
• Law enforcement officials, but the disclosure must meet the minimum standards necessary for the immediate purpose and not disclose information about other individuals. A court order or search warrant may be required.
• Others, to the extent that the law requires a specific use or disclosure of information.
• Information may be released to prevent or lessen a serious and imminent threat to the health or safety of a person or the public; if the disclosure is made to a person or persons reasonably able to prevent or lessen the threat or harm, including the target of a threat.

Other uses and disclosures of your information will be made only with your written consent. You may revoke your consent at any time in writing, except if the agency has already released information as a result of your consent.

Your rights regarding your information in the HMIS

• You have the right to inspect and obtain a copy of your own protected personal information for as long as it is kept in the HMIS, except for information compiled in reasonable anticipation of, or for use in, a legal proceeding.
• You have the right to correct your protected personal information when the information in the record is inaccurate or incomplete.
• You have a right to request that your personal information be provided to you by alternative means, (such as by mail or telephone), or at alternative locations (such as at your home or place of work). This agency will accommodate reasonable requests.
• You have the right to receive a list of disclosures of protected personal information made by this agency or ICHHI during the six years prior to the date you request this information, except for disclosures for national security or intelligence purposes or to correctional institutions or law enforcement officials. If a law enforcement official or health oversight agency requests that we temporarily suspend giving you an accounting of disclosures made to them, the request must be time-limited and given to us in writing.

Exercising your rights regarding your information in the HMIS

You can exercise these rights by making a written request to this agency, or by making a written request to ICHHI. The addresses are listed at the end of this Notice.

Enforcement of your privacy rights

If you believe your privacy rights have been violated, you may send a written complaint to this agency. If your complaint is not resolved to your satisfaction, you may send your written complaint to ICHHI. Addresses are listed at the end of this Notice. You will not be retaliated against for filing a complaint.

This agency is required by law to maintain the privacy of your protected personal information, and to display a copy of the most recent Notice of Privacy Practice. This Agency reserves the right to change the Notice from time to time, and if it does, the change will affect all of the information in the HMIS, not just the information entered after the change. The revised Notice will be posted in this Agency. You may request a copy of it from this Agency or ICHHI.

This Form may not be amended except by ICHHI. Proposals for amendments may be sent to info@ichhi.org.

¹Only agencies covered under 42 CFR Part 2 would use this clause in its Notice of Privacy Practices.

²HIPAA covered entities or entities covered under 42 CFR Part 2 would omit this clause. For a HIPAA covered entity, its Notice of Privacy Practices under HIPAA would cover research.