On July 30, 2004, the US Department of Housing and Urban Development (HUD) released the standards for Homeless Management Information Systems (69 Federal Register 45888). This standard outlined the responsibilities of the HMIS and for the agencies which participate in an HMIS. This section of our Standard Operating Procedure describes the Privacy Plan of the DuPage County HMIS System. We intend our policy and plan to be consistent with the HUD standards. All users, agencies and system administrators must adhere to this Privacy Plan.
We intend our Privacy Plan to support our mission of providing an effective and usable case management tool. We recognize that clients served by individual agencies are not exclusively that "agency's client" but instead are truly a client of the DuPage County Continuum of Care. Thus, we have adopted a Privacy Plan which supports an open system of client-level data sharing amongst agencies.
The core tenant of our Privacy Plan is the Baseline Privacy Notice. The Baseline Privacy Notice describes how client information may be used and disclosed and how clients can get access to their information. Each agency must either adopt the Baseline Privacy Notice or develop a Privacy Notice which meets and exceeds all minimum requirements set forth in the Baseline Privacy Notice (this is described in the Agency Responsibilities section of this Privacy Plan). This ensures that all agencies who participate in the HMIS are governed by the same minimum standards of client privacy protection.