All tenant health care and personal identifying information is confidential with access governed by local, state, and federal law. Ability Housing, Inc. adheres to the most stringent law governing tenant records. In cases of discrepancy, the higher standard is to be maintained. Tenant identifying information includes name, address, medical, social and financial data (including Social Security number) and service(s) received. Data collection, as well as documentation of service delivery is to be conducted, reviewed and observed in a setting that protects the tenant’s identity from unauthorized individuals.
Tenant information is never to be discussed nor documentation released or transported from the agency without following protocol determined by state and federal law.

Employment Policy

All new hires are to receive confidentiality training prior to assuming their work duties. All employees sign a Confidentiality and Privacy Policy Agreement prior to assuming work duties.

A. What This Notice Covers

This notice describes the privacy policy and practices of Ability Housing, Inc. specifically in regards to the protection of information pertaining to tenants, sponsors, and vendors affiliated with the organization. The mailing address for Ability Housing, Inc. is 76 South Laura Street, Suite 303, Jacksonville, FL. 32202.
The policy and practices in this notice cover the processing of protected personal information for tenants participating in the Ability Housing programs for Northeast and Central Florida.

Protected Personal information (“PPI”) is any information we maintain about a tenant that:
a. allows identification of an individual directly or indirectly
b. can be manipulated by a reasonably foreseeable method to identify a specific individual, or
c. can be linked with other available information to identify an individual. When this notice further refers to personal information, it does so under the acronym PPI.

Ability Housing, Inc. adopted this policy to meet the standards for Homeless Management Information Systems issued by the Department of Housing and Urban Development. We intend for all policies and practices to be consistent with those standards. See 69 Federal Register 45888 (July 30, 2004). Also see 42 U.S.C. 1320d; 45 CFR Parts 160, 162, and 164.

This notice serves to inform tenants, staff, and others of how Ability Housing, Inc. processes personal information. We follow all policies and practices described in this notice.

We may amend this notice and change our policies or practices at any time. Amendments may affect personal information obtained before the effective date of the amendment.

a. A copy will specifically be made available to all Ability Housing, Inc. staff, volunteers, contractors, and associates who are required to comply with the privacy notice in addition a printed copy will be made available to all clients that are receiving supportive services from Ability Housing, Inc. or any subcontractor or associate of Ability Housing, Inc.

b. We will provide a hard copy of this privacy notice upon request.

B. How and Why We Collect Personal Information

We collect personal information in order to verify eligibility, to provide services, or when required by law. We may collect information for these purposes:
a. to provide or coordinate services to tenants;
b. to locate other programs that may be able to assist tenants;
c. for functions related to payment or reimbursement from others for services that we provide;
d. to operate our organization, including administrative functions such as legal, audits, personnel, oversight, and management functions;
e. to comply with government reporting obligations; and/or
f. when required by law.
We use lawful and fair means to collect personal information.

We collect personal information with the knowledge and consent of our tenants. 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

We may also obtain information about tenants from:
a. Accompanying parties or individuals (i.e. Case Managers, Employers, Family Members, etc.)
b. Other private organizations that provide services (i.e. Quest, Health Care Providers, Legal Authorities, etc.)
c. Government agencies (i.e. SSI, Medicare, etc.)
d. Telephone directories and other published sources

We post a sign at our intake desk or other locations explaining the reasons we ask for personal information. The sign states:
“We collect protected personal information (“PPI”) when necessary. We may use or disclose a tenant’s information in order to provide services. We may also use or disclose PPI to comply with legal entities and/or other obligators. We assume that you agree to allow us to collect information and use or disclose it as described in this notice. You may inspect the personal information that we maintain on file. You may also request for us to update or correct inaccurate or incomplete information. You may at any time inquire about our privacy policy or practices; we will respond to all questions or complaints. A copy of the full notice will be made available upon request.”

Participants may request copies of confidential communications of protected healthcare information and they may collect those documents in person from 76 S Laura St. Ste. 303 Jacksonville, FL 32202. We will provide the documents via mail if the participant provides Ability Housing, Inc. with a self-addressed postage paid envelope. You may also request an accounting of disclosures of protected health information.

C. How We Use and Disclose Personal Information

We use or disclose personal information only for activities described in this notice. We reserve the right to uses PPI as it pertains to the following. We assume that you consent to the use or disclosure of your personal information for the purposes described here and for other uses and disclosures that we determine to be compatible with these uses or disclosures:
a. to provide or coordinate services. We share tenant records with other organizations that may have separate privacy policies and that may allow different uses and disclosures of the information.
b. for functions related to payment or reimbursement for services
c. to carry out administrative functions such as legal, audits, personnel records, oversight, and management functions
d. to create de-identified (anonymous) information that can be used for research and statistical purposes without identifying tenants
e. when required by law to the extent that use or disclosure complies with and is limited to the requirements of the law
f. to avert a serious threat to health or safety if:(1) We believe that the use or disclosure is necessary to prevent or lessen a serious and imminent threat to the health or safety of an individual or the public, and

(1) We believe that the use or disclosure is necessary to prevent or lessen a serious and imminent threat to the health or safety of an individual or the public, and
(2) The use or disclosure is made to a person reasonably able to prevent or lessen the threat, including the target of the threat
g. to report an individual we reasonably believe to be a victim of abuse, neglect or domestic violence to a governmental authority (including a social service or protective services agency) authorized by law to receive reports of abuse, neglect or domestic violence
(1) Under any of these circumstances:
(a) where the disclosure is required by law and the disclosure complies with and is limited to the requirements of the law
(b) if the individual agrees to the disclosure, or
(c) to the extent that the disclosure is expressly authorized by statute or regulation, and
(I) we believe the disclosure is necessary to prevent serious harm to the individual or other potential victims, or
(II) if the individual is unable to agree because of incapacity, a law enforcement or other public official authorized to receive the report represents that the PPI for which disclosure is sought is not intended to be used against the individual and that an immediate enforcement activity that depends upon the disclosure would be materially and adversely affected by waiting until the individual is able to agree to the disclosure.
(2) when we make a permitted disclosure about a victim of abuse, neglect or domestic violence, we will promptly inform the individual who is the victim that a disclosure has been or will be made, except if:

(a) we, in the exercise of professional judgment, believe informing the individual would place the individual at risk of serious harm, or
(b) we would be informing a personal representative (such as a family member or friend), and we reasonably believe the personal representative is responsible for the abuse, neglect or other injury, and that informing the personal representative would not be in the best interests of the individual as we determine in the exercise of professional judgment.

h. for academic research purposes
(1) conducted by an individual or institution that has a formal relationship with the Changing Homelessness Organization if the research is conducted either:
(a) by an individual employed by or affiliated with the organization for use in a research project conducted under a written research agreement approved in writing by a designated Changing Homelessness Organization program administrator (other than the individual conducting the research), or
(b) By an institution for use in a research project conducted under a written research agreement approved in writing by a designated Changing Homelessness Organization program administrator.

(2) Any written research agreement:
(a) Must establish rules and limitations for the processing and security of PPI in the course of the research
(b) Must provide for the return or proper disposal of all PPI at the conclusion of the research
(c) Must restrict additional use or disclosure of PPI, except where required by law
(d) Must require that the recipient of data formally agree to comply with all terms and conditions of the agreement, and
(e) Is not a substitute for approval (if appropriate) of a research project by an Institutional Review Board, Privacy Board or other applicable human subjects protection institution.
i. to a law enforcement official for a law enforcement purpose (if consistent with applicable law and standards of ethical conduct) under any of these circumstances:
(1) in response to a lawful court order, court-ordered warrant, subpoena or summons issued by a judicial officer, or a grand jury subpoena
(2) if the law enforcement official makes a written request for PPI that:
(a) is signed by a supervisory official of the law enforcement agency seeking the PPI
(b) states that the information is relevant and material to a legitimate law enforcement investigation
(c) identifies the PPI sought
(d) is specific and limited in scope to the extent reasonably practicable in light of the purpose for which the information is sought, and
(e) States that de-identified information could not be used to accomplish the purpose of the disclosure.
(3) if we believe in good faith that the PPI constitutes evidence of criminal conduct that occurred on our premises
(4) in response to an oral request for the purpose of identifying or locating a suspect, fugitive, material witness or missing person and the PPI disclosed consists only of name, address, date of birth, place of birth, Social Security Number, and distinguishing physical characteristics, or
(5) the official is an authorized federal official seeking PPI for the provision of protective services to the President or other persons authorized by 18 U.S.C. 3056, or to foreign heads of state or other persons authorized by 22 U.S.C. 2709(a)(3), or for the conduct of investigations authorized by 18 U.S.C. 871 and 879 (threats against the President and others).
j. To comply with government reporting obligations for homeless management information systems and for oversight of compliance with homeless management information system requirements.
2. Before we make any use or disclosure of your personal information that is not described here, we will first seek consent.
3. All other disclosures require written consent. Consent may be revoked but it may result in ineligibility to receive services or participate in programs provided by Ability Housing, Inc.

D. How to Inspect and Correct Personal Information

You may inspect and have a copy of the personal information that we maintain. We will offer an explanation of any information that you may not understand.
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.
Participants may request restrictions on certain uses of protected healthcare information in writing to Staff at Ability Housing, Inc., 76 South Laura Street, Suite 303, Jacksonville, FL. 32202. Not all requests will be honored. In the event that your request is not honored, we will offer an explanation as to why we cannot accommodate the request.
To inspect, get a copy of, or ask for correction of your information, ask any staff member for access.
We may deny your request for inspection or copying of personal information if:
a. the information was compiled in reasonable anticipation of litigation or comparable proceedings
b. the information is about another individual (other than a health care provider or homeless provider)
c. the information was obtained under a promise or confidentiality (other than a promise from a health care provider or homeless provider) and if the disclosure would reveal the source of the information, or
d. Disclosure of the information would be reasonably likely to endanger the life or physical safety of any individual.
If we deny a request for access or correction, we will explain the reason for the denial. We will also include, as part of the personal information that we maintain, documentation of the request and the reason for the denial
We may reject repeated or harassing requests for access or correction.
E. Data Quality

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.
We agree to dispose of personal information not in current use seven years after the information was created or last changed. As an alternative to disposal, we reserve the right to remove identifiers from the information.
We may keep information for a longer period if required to do so by statute, regulation, contract, or other requirement.
F. Complaints and Accountability

We accept and consider questions or complaints about our privacy and security policies and practices. Complaints must be submitted in writing to Ability Housing, Inc. 76 South Laura Street Suite 303 Jacksonville, FL. 32202. Individuals may additionally complain to their health care provider or to the Secretary of the US Department of Health and Human Services if they believe their privacy rights have been violated.
The Administrator will attempt to resolve your complaint. Should further review be required your complaint will be escalated to the Changing Homelessness Incorporated Homelessness Management Information System Steering Committee to determine a voluntary resolution of the complaint. Resolution of the complaint will be provided in writing to the agency and the individual filing the complaint. This Agency and Changing Homelessness, Inc. as the Homeless Management Information System administrator are prohibited from retaliating against you for filing a complaint.
1. All members of Ability Housing, Inc. staff (including employees, volunteers, affiliates, contractors and associates) are required to comply with the privacy notice. Each staff member must receive and acknowledge receipt of a copy of this and any subsequent revised privacy notices.

G. Privacy Notice Change History

Version 1.0. June 1, 2012. Initial Policy
Version 2.0 February 22, 2016 Revised
Version 3.0 June 14, 2016 Revised