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Privacy Policy

We are committed to protecting your privacy online. When you visit our site, we may collect personal information from you such as your name and e-mail address. Our third party hosting company will collect additional information such as the URL you came from, your IP address, your domain name, your browser type, the country and state where your server is located, and the pages that were viewed during your visit to our site. All this information is kept on a secure server to protect it from outside parties.

We do not sell or rent personal information to others. We use your information only for the limited purposes of sending you updates and useful information about our programs, promotional information, enhancing the site operation, for statistical purposes, and for overall systems administration.

We understand and respect the right to privacy.

Amos House HMIS Policy

In Addition to Amos House’s PPI policy, all program staff members that work with RICoC HMIS data must adhere the following PPI policy standards set forth by the RICoC:

This Privacy Policy applies to all Personally Identifiable Information that is collected and maintained in the RICoC HMIS, including electronic and hard copies derived from the HMIS. Personally Identifying Information, also known as Protected Personal Information (PPI), is defined by the 2004 HUD Data and Technical Standards as: “Any information maintained by or for a Covered Homeless Organization about a living homeless client or homeless individual that: (1) Identifies, either directly or indirectly, a specific individual; (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 individual.” The RICoC HMIS will use only unidentified, aggregate data for homeless policy and planning decisions, in preparing federal, state, or local applications for homelessness funding, to demonstrate the need for and effectiveness of programs, and to obtain a system-wide view of program utilization in the state.

In accordance with federal law, Amos House will post the HMIS Data Statement at the intake desks, offices, and on the website, as applicable, explaining the reasons information is requested. The RICoC and the HMIS Lead Agency reserves the right to amend this Privacy Policy at any time.

RICoC has adopted an approach to client consent for use and disclosure of information consistent with regulations set forth by HUD in Federal Register/ Vol. 69, No. 146 / Friday, July 30, 2004 / Notices and with the Coordinated Entry Management and Data Guide (published October 2018) at https://files.hudexchange.info/resources/documents/coordinated-entrymanagement-and-data-guide.pdf. Disclosure of any information to any entity that has not signed a Data Sharing MOU and is not required by law can only occur with written client consent. Only information that is needed for 1) coordination of services and case management, 2) administration, 3) billing, and 4) analytics are collected as defined by the RICoC may be used or disclosed by Amos House.

The release of aggregate HMIS data to an entity that is not a CHO/Participant Agency must be approved by the RICoC Data and HMIS Committee and RICoC Board of Directors. Amos House may disclose client personal information that meets the minimum standard necessary for the immediate purpose to comply with legal requirements. Amos House will only disclose client information to law enforcement entities in response to appropriate legal requests including subpoena or court order. Amos House may disclose client PII to an agency authorized by law to receive reports of abuse, neglect, or domestic violence if it believes the clients are the victim of such treatment provided any of the following apply: 1) the disclosure is required by law, such as “mandated reporting” 2) Amos House believes the disclosure is necessary to prevent serious harm, or to lessen a serious or imminent threat to the health and safety of an individual or public and the information is given to law enforcement or other person reasonably able to prevent or reduce that threat.

In accordance with Amos House’s Client Refusal of Information Policy, clients have the right to get services even if they choose NOT to share data in the RICoC HMIS; this right is limited by the nature of the project; some projects are required by law or regulation to collect certain data to establish and document program eligibility. Clients have the right to ask who has seen their information. Clients have the right to see or receive a copy of their information and to change it if it is not correct. Requests to view or receive a copy of their information shall be in writing and clients must provide proof of identity; the request and proof of identity shall be maintained in the client file (electronic or hard copy). To change information, clients must show documentation verifying the correct information. If clients do not want their information shared with a specific agency, it is their responsibility to let their case manager or intake worker know, who must then take the proper action to honor that request. If a client has any questions about the use of their personal information or are concerned about client privacy or safety, they should share their questions or concerns with Amos House management. If a client feels that the security or integrity of their information has been violated by an end-user or the CHO itself, clients should file a complaint with the Amos House, using the Client Grievance Procedure. Clients may also file a complaint with the HMIS Lead Agency; Amos House and all CHOs/Participating Agencies are required to provide a client with a Grievance Filing Form at their request and submit the completed form to the HMIS Lead Agency; in instances where the HMIS Lead Agency is the subject of a grievance, it will be submitted to the RICoC Data and HMIS Committee for review and action. The HMIS Lead Agency, in conjunction with the RICoC Data and HMIS Steering Committee, will investigate each grievance and submit suggested actions to the CHO/Participating Agency within 30 days. Clients that submit a grievance filing form will not be retaliated against for filing a complaint. Clients may also ask for a copy and/or an explanation of the privacy and/ or the ROI policy.