OC HMIS Privacy Notice

About this notice

Recovery Road, Inc. takes part in the Orange County Continuum of Care Homeless Management Information System (OC HMIS) for its housing services. Below is the county's privacy notice for that system, as the OC HMIS wrote it. It covers the information we enter into HMIS when you get housing or homeless services from us. Our Privacy Policy covers everything else.

Where the notice says "this organization," it means Recovery Road. Send written requests and grievances to Recovery Road Inc., 2220 East Winston Road, Anaheim, CA 92806, or email admin@recoveryroad.org. You can also ask for a printed copy at our office.

Privacy Notice

This privacy notice explains under what circumstances we may share and disclose your information from the OC HMIS. This notice also explains your rights regarding your confidential information. Please read it carefully.

Our organization collects and shares information about individuals who access our services. The information is confidentially stored in a local electronic database called the Orange County Homeless Management Information System (OC HMIS). The OC HMIS securely records information (data) about persons accessing housing and homeless services in Orange County.

Confidential personal information that we collect about you and your family is referred to as Protected Personal Information (PPI). We are required to protect the privacy of your PPI by complying with the privacy practices described in this Privacy Notice.

Why We Collect and Share Information

The information we collect and share in the HMIS helps us to efficiently coordinate the most effective services for you and your family. It allows us to complete one universal intake per person; better understand homelessness in your community; and assess the types of resources needed in your local area.

By collecting your information for HMIS, we are also able to generate aggregate statistical reports requested by the Department of Housing and Urban Development (HUD).

The Type of Information We Collect and Share in the HMIS

We collect and share both PPI and general information obtained during your intake and assessment, which may include but is not limited to:

• Name and contact information
• Social security number
• Birthdate
• Demographic information such as age and race/ethnicity
• History of homelessness and housing (including current housing status and where and when services have been accessed)
• Self-reported medical history including any mental health and substance abuse issues
• Case notes and services
• Case manager's contact information
• Income sources and amounts; and non-cash benefits
• Veteran status
• Disability status
• Household composition
• Emergency contact information
• Domestic violence history
• Photo (optional)

How Your Personal Information Is Protected in the HMIS

Your information is protected by passwords and encryption technology. Each HMIS user and participating organization must sign an agreement to maintain the security and privacy of your information. Each HMIS user or participating organization that violates the agreement may have access rights terminated and may be subject to further penalties.

How PPI May Be Shared and Disclosed

Unless restricted by other laws, the information we collect can be shared and disclosed without your consent under the following circumstances:

• To provide or coordinate services.
• For payment or reimbursement of services for the participating organization.
• For administrative purposes, including but not limited to HMIS system administrator(s) and developer(s), and for legal, audit personnel, and oversight and management functions.
• For creating de-identified PPI.
• When required by law or for law enforcement purposes.
• To prevent a serious threat to health or safety.
• As authorized by law, for victims of abuse, neglect, or domestic violence.
• For academic research purposes.
• In a situation where you have requested access to your HMIS records through the Client Record Request process, and an agency will be providing you with those records.
• Other uses and disclosures of your PPI can be made with your written consent.

Providing Your Consent for Sharing PPI in the HMIS

Generally, to share your PPI in the OC HMIS, we must have your written consent. Exception:

• In a situation where we are gathering PPI from you during a phone screening, street outreach, or community access center sign-in, your verbal consent can be used to share your information in HMIS. If we obtain your verbal consent, you will be requested to provide written consent during your initial assessment. If you do not appear for your initial assessment, your information will remain in HMIS until you revoke your consent in writing.

You have the right to receive services even if you do not consent to share your PPI in the OC HMIS.

How to Revoke Your Consent for Sharing Information in the HMIS

You may revoke your consent at any time. Your revocation must be provided either in writing or by completing the Revocation of Consent form. Upon receipt of your revocation, we will remove your PPI from the shared HMIS database and prevent further PPI from being added. The PPI that you previously authorized to be shared cannot be entirely removed from the HMIS database and will remain accessible to the limited number of organization(s) that provided you with direct services.

Your Rights to Your Information in the HMIS

You have the right to receive the following, no later than five (5) business days of your written request:

• A correction of inaccurate or incomplete PPI;
• A copy of your consent form;
• A copy of the OC HMIS Privacy Notice;
• A copy of your HMIS records; and
• A current list of participating organizations that have access to your HMIS data.

You can exercise these rights by making a written request to this organization.

Your Privacy Rights Regarding Your Information in the HMIS

If you believe your privacy rights have been violated, you may send a written grievance to this organization. You will not be retaliated against for filing a grievance.

If your grievance is not resolved to your satisfaction, you may send a written grievance appeal to the HMIS Lead, Orange County United Way.

Amendments to this Privacy Notice

The policies in this notice may be amended at any time. These amendments may affect information obtained by this organization before the date of the change. Amendments regarding use or disclosure of PPI will apply to information (data) previously entered in HMIS, unless otherwise stated. All amendments to this privacy notice must be consistent with the requirements of the federal HMIS privacy standards. This organization must keep permanent documentation of all privacy notice amendments.