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New Endeavors
by Women
Privacy Notice SummaryEffective October 2006 Version 1.0 This notice describes the privacy policy of New Endeavors by Women (NEW). NEW may amend this policy at any time, and will maintain a record of the changes made as well as post new versions on the NEW web site located at www.newendeavorsbywomen.org. This notice applies to the personal information of persons served through our programs that is collected or maintained by NEW in hard copy or electronic formats or through the DC Homeless Management Information System (HMIS). In relation to this information, NEW:
Each person providing personal information can:
A. What This Notice Covers: This notice describes the privacy policy and practices of NEW. Our main office is at 611 N Street NW Washington, District of Columbia 20001. Our phone number is 202-682-5825 and our web site is located at www.newendeavorsbywomen.org. The policy and practices in this notice cover the processing of protected personal information for clients of NEW and its programs. This notice covers all personal information that is maintained by NEW in its role as administrator for DC Continuum of Care programs. Protected Personal Information (PPI) is any information NEW maintains about a client that :
OR
NEW adopted this policy in accordance with the Homeless Management Information Systems Data and Technical Standards issued by the US Department of Housing and Urban Development. We intend our policy and practices to be consistent with those standards. {See 69 Federal Register 45888 (July 30, 2004)}. We also intend for our policies to be consistent with requirements outlined in the DC Homeless Services Reform Act and other applicable local laws. This notice tells NEW clients, staff contractors, HMIS users and how personal information is processed at NEW. We may amend this notice and change our policy or practices at any time. Amendments may affect personal information that we obtained before the effective date of the amendment. The new notice will be posted in the intake/case managers office as well as on our web site at www.newendeavorsbywomen.org at least 30-days prior to taking effect. NEW will provide a written copy of this privacy notice to any individual or organization that requests one. NEW also maintains a copy of this notice on its web site at www.newendeavorsbywomen.org. B. How and Why We Collect Personal Information NEW collects and maintains personal information only when appropriate to provide services, or for another specific purpose of our organization, or when required by law. Information may be collected for the following purposes:
NEW uses only lawful and fair means to collect personal information. If you seek NEW’s assistance and provide personal information, NEW assumes that you can consent to the collection of information as described in this notice. NEW may also obtain information about those seeking services from: Other individual who are accompanying the person seeking services , such as a guardian, caretaker or advocate; or Referring organizations and/or service providers (with proper consent). NEW posts a sign at our offices explaining the reasons we ask for personal information. The sign says: DC Continuum of Care Privacy Posting The U.S. Department of Housing and Urban Development (HUD) requires that each jurisdiction that receives funding from HUD must have a Homeless Management Information System (HMIS) in place. Therefore, this Agency is required to participate in the DC Homeless Management Information System (HMIS), a computerized system that collects and stores basic information about the persons who receive services from this Agency. The goal of the DC HMIS is to assist us in determining your needs and to provide a record for evaluating the services we are providing to you. We only collected information that is needed to provide you services, and we do not share your information without written consent, except when required by our funders or by law, or for specific administrative or research purposes outlined in our privacy policy. By requesting and accepting services from this program, you are giving consent for us to enter your personal information into the HMIS. The collection and use of all personal information is guided by strict standards of confidentiality as outlined in our privacy policy. A copy of our agency’s Privacy Policy is available upon requests for your review. C. How NEW Uses and Discloses Personal Information NEW uses or discloses personal information for activities described in this part of the notice. As necessary to help you, we may or make any of these uses or disclosures. We assume that you consent to the use or disclosure of your personal information for the purposes described below and for other uses and disclosures that we determine to be compatible with these uses or disclosures: To provide or coordinator services for individuals to help the exit homelessness. We share client records (with consent) with other organizations that may have separate privacy policies and that may allow different uses and disclosures of the information; For functions related to payment or reimbursement for services; To carry out administrative functions such as audits, personnel, oversight, reporting, analysis and management functions, including the maintenance and operation of the HMIS; To create de-identified (anonymous) information that can be used for research and statically purposes without identifying clients; When required by law to the extent that use or disclose complies with and is limited to the requirements of the law; To avert a serious threat to health or safety if: 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 The use or disclosure is made to a person reasonably able to prevent or lessen the threat, including the target of the threat. To report about 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 under any of the following circumstances: Where the disclosures is required by law and the disclosure complies with and is limited to the requirements of the law; If the individual agrees to the disclosure; or To the extent that the disclosure is expressly authorized by statue or regulation and We believe the disclosure is necessary to prevent serious harm to the individual or other potential victims; or If individual is unable to agree because of incapacity, then a law enforcement or other public official authorized to receive the report must represent that the PPI for which disclosure is ought is not intended to be used against the individual, and must represent that an immediate enforcement activity that depends upon the disclosure would be materially and adversely affected by waiting until the individual the is unable to agree to the disclosure; and 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; In the exercise of professional judgment we believe informing the individual would place the individual at risk of serious harm, or We would be informing a personal representative (such as a family member or friend) and reasonably believe the personal representative is responsible for the abuse, neglect or their injury; such that informing the personal representative would not be in the best interests of the individual as we determine in the exercise of professional judgment.
An institution for use in a research agreement approved in writing by a designated CHO program administrator; and The formal relationship is contained in a written research agreement that must:
Provide for the return or proper disposal of all PPI at the conclusion of the research; Restrict additional use or disclosure of PPI, except where required by law; Require that he recipient of data formally agree to comply with all terms and conditions of the agreement; 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. NEW may also seek approval, as appropriate, by the public entity that has rights to the data (in part or in full) because the data has been generated and collected under a contract or subcontract with the public entity.
If the law enforcement official makes a written request for PPI that; Is signed by a supervisory official of the law enforcement agency seeking the PPI; States that the information is relevant and material to a legitimate law enforcement investigation; Identifies the PPI sought; Is specific and limited in scope to the extent reasonably practicable in light of the purpose for which the information is sought; and States that de-identified information could not be used to accomplish the purpose of the disclosure.
In response to a written request, as described above, for the purpose of identifying or locating a suspect, fugitive, material witness or missing person and the PPI disclosed consists only not name, address, date of birth, place of birth, Social Security Number , and distinguishing physical characteristics; If 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 the 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 (and threats against the President and others); and if the information requested is in writing and is specific and limited in scope to the extent reasonably practicable in light of the purpose for which it is sought. To comply with government funding reporting obligations.
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