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Security

Saint Louis County Department of Human Services
Homeless Missourians Information System (HMIS)
Privacy and Security Notice

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 are applicable 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:

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:
a. information is compiled in reasonable anticipation of litigation or comparable
proceedings;
b. information about another individual other than the agency staff would be
disclosed

  1. To provide or coordinate services to an individual.

2. For functions related to payment or reimbursement for services.

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

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

5. Contractual research where privacy conditions are met.

6. 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.

7. To comply with government reporting obligations.

8. 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:

1. 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.

2. 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.

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

4. 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 Homeless Program Manager, Chaunceia Mayfield at
cmayfield@stlouisco.com.

5. 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.

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:

  1. The computer program we use has the highest degree of security protection available.
  2. Only trained and authorized individuals will enter or view your personal information.
  3. Your name and other identifying information will not be contained in HMIS reports that
    are issued to local, state or national agencies.
  4. Employees receive training in privacy protection and agree to follow strict confidentiality
    standards before using the system.
  5. 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.
  6. 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.
  7. The server/database exists behind a firewall-a device meant to keep
    hackers/crackers/viruses/etc. away from the server.
  8. The main database will be kept physically secure, meaning only authorized personnel
    will have access to the server/database.
  9. System Administrators employed by the HMIS and the agency support the operation of
    the database. 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

V. BENEFITS OF HMIS AND AGENCY INFORMATION SHARING:
Information you provide us can play an important role in our ability and the ability of other
agencies to continue to provide the services that you and others in the community are requesting.
Allowing us to share your name results in a more accurate count of individuals and the services
they use. Obtaining an accurate count is important because it can help us and other agencies:

Allowing us to share your name results in a more accurate count of individuals and the services
they use. Obtaining an accurate count is important because it can help us and other agencies:

  1. Better demonstrate the need for services and the specific types of assistance needed in
    our area.
  2. Obtain more money and other resources to provide services.
  3. Plan and deliver quality services to you and your family.
  4. Assist the agency to improve its work with families and individuals who are homeless.
  5. Keep required statistics for state and federal funders, such as HUD.

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. Web Site
We adhere to the St. Louis County government requirements. They maintain a copy here: https://stlouiscountymo.gov/st-louis-countydepartments/human-services/county-homeless-programs