Privacy Policy
(As relates to website information)

The Homeless Coalition of Hillsborough County is committed to protecting each visitor’s privacy. The purpose of this statement is to detail all issues concerning privacy on our site.

What information do we collect and how do we use it?
While visiting our site we may ask you to give us various pieces of personal information in regard to donations, donations pickup, feedback, volunteering, or others aspects of the Coalition’s efforts to end homelessness. The information gathered may include: name, local address, telephone number, fax number, and e-mail address. Information about the type of group donating (business, independent, faith organization, etc.), the number of beneficiaries of the donation, the type of donation (monetary or other), and condition of the donation may also be asked. In addition, other non-identifying information such as web site hits, types of web browser use, and types of operating system use will be recorded.

Use of all information acquired by the Homeless Coalition is restricted to internal use only. This includes any non-identifying information. It is our policy not to sell, trade, or rent your personal information to anyone. Personal information will be used in an internal database for recording donations, and follow up to inquiries.  In addition, e-mail addresses will be saved and entered into a database for use in the sending of our periodic newsletters and information about events, activities and needs at the Homeless Coalition. Non-identifying information will be used exclusively for research and/or in optimizing the web site in general.

How do you contact us regarding your information?
If you wish to stop receiving our newsletters, update your information, or wish for your personal information to be removed from our databases, contact Lesa Weikel at (813) 223-6115 or Lesa@homelessofhc.org.

For any other questions or concerns, contact the Homeless Coalition via phone at (813) 223-6115 or email at info@homelessofhc.org or via mail to:

Homeless Coalition of Hillsborough County

PO Box 360181

Tampa, FL 33673-0181

 

Privacy Notice
Homeless Coalition of Hillsborough County
(As related to UNITY Information Network)

 A. What This Notice Covers

 1.  This notice describes the privacy policy and practices of the
      Homeless Coalition of Hillsborough County (Homeless Coalition).  
      Our main office is at 2105 N. Nebraska Ave., 2nd floor, Tampa, FL 
      33602.  Our main phone number is (813) 223-6115.

2.   The policy and practices in this notice cover the processing of protected personal information for clients of the Homeless Coalition.

 3.  Protected Personal information (PPI) is any information we maintain
     about a client 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 a specific client.  When this notice refers to personal information, it means PPI.

4.   We adopted this policy because of standards for Homeless Management Information Systems issued by the 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).

5.   This notice tells our clients, our staff, and others how we process personal information.  We follow the policy and practices described in this notice.

6.   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. 

7.   We give a written copy of this privacy notice to any individual who asks.

 B. How and Why We Collect Personal Information

 1.   We collect personal information only when appropriate to provide
       services or for another specific purpose of our organization or when
       required by law.  We may collect information for these purposes:  

a.  to provide or coordinate services to clients

b.  to locate other programs that may be able to assist clients

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

f.   when required by law

 2.  We only use lawful and fair means to collect personal information.

 3.  We normally collect personal information with the knowledge or
      consent of our clients.  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

 4.  We may also get information about you from: 

a. Individuals who are with you

b. Other private organizations that provide services (identify)

c. Government agencies (identify)

d. Telephone directories and other published sources 

 5.  We post a sign at our intake desk (if applicable) or other location
      explaining the reasons we ask for personal information.  The sign
      says:

 “We collect personal information directly from you for reasons that are discussed in our privacy statement.  We may be required to collect some personal information by law or by organizations that give us money to operate this program.  Other personal information that we collect is important to run our programs, to improve services for homeless individuals, and to better understand the need of homeless individuals.  We only collect information that we consider to be appropriate.”

 C. How We Use and Disclose Personal Information

 1.  We use or disclose personal information for activities described in this
      part of the notice.  We may or may not make any of these uses or
      disclosures with your information.  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 to individuals  We share client 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, oversight, and management functions

d.  to create de-identified (anonymous) information that can be used for research and statistical purposes without identifying clients

        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 preventor 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 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

(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. 

and        

           (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 r
                elationship with the CHO 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 CHO 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 CHO program administrator. 

and

            (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)if

(a) 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), and

(b) the information requested is specific and limited in scope to the extent reasonably practicable in light of the purpose for which the information is sought.

and

         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 seek your consent first.

D. How to Inspect and Correct Personal Information

 1.  You may inspect and have a copy of your personal information that we
      maintain.  We will offer to explain any information that you may not
      understand.

2.   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.

3.   To inspect, get a copy of, or ask for correction of your information, ask any staff member for access.

4.   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.

5.   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

6.   We may reject repeated or harassing requests for access or correction.

E. Data Quality

1.  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.

2.  We are developing and implementing a plan 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 may
choose to remove identifiers from the information. 

3.   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 this Agency and to:

     UNITY Grievance Committee
     Homeless Coalition of Hillsborough County
     P.O. Box 360181
     Tampa, FL 33673-0181

The UNITY Grievance Committee will attempt to resolve your complaint.  Should further review be required your complaint will be escalated to the UNITY 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 the UNITY Information Network are prohibited from retaliating against you for filing a complaint.

1. All members of our staff (including employees, volunteers, affiliates,
   contractors and associates) are required to comply with this privacy
   notice.  Each staff member must receive and acknowledge receipt of a
   copy of this privacy notice.

G. Privacy Notice Change History

1.   Version 1.0.  June 1, 2005.  Initial Policy