Client Privacy Basics

Clarity provides several alternatives to ensure that client data that should not be shared can be set to private. Data that is set to private will not be shared outside of the agency that entered it (and with system administrators and monitors). Data that is shared can be viewed by any HMIS user but can only be edited by a user at the agency that entered the data.


Sharing data within HMIS has several advantages outlined in the HMIS Privacy Notice and Client Consent Form, including reducing trauma for clients when they do not need to repeat their stories with every provider who works with them. With that said, the Cincinnati/Hamilton County CoC takes client privacy very seriously, so it is vital to understand your role as an HMIS user in maintaining client privacy:

  1. Never share your HMIS username or password.
  2. Only access client records for clients you are working with or have a specific business purpose to do so.
  3. Make sure you understand the HMIS Privacy Notice and Client Consent Form, and the HMIS User Agreement and Code of Ethics.  
  4. Take care not to share client data by mistake; log out of Clarity when not in use, lock your screen if it is visible to others, and never discuss clients using personally identifiable information (PII) if you can be overheard by others not authorized to have the information.
  5. Understand why, when, and how to set client data to private in Clarity.

Why Set Client Data to Private

Clarity data must be set to private under these circumstances:

  • The client does not agree to share information and an HMIS Privacy Notice and Client Consent Form is not signed.
  • The client requests that a specific data point (note, service, referral, event, assessment, etc.) be set to private and not shared with other agencies.
  • Any note, assessment, service, referral, etc., mentioning or referring to Caracole or the YWCA, or including sensitive details about legal issues, substance use, domestic violence, or health (physical or mental).

When to Set Client Data to Private

Clarity has three privacy settings levels. Understanding these privacy levels is important when determining when or how to keep client data private.


Level 1: This method requires setting the entire client record to private in Clarity. 

  • It is used when a new client chooses not to sign the HMIS Privacy Notice and Client Consent Form. 
  • This method cannot be used for client records that have been shared previously. In these cases, the level 2 method of making the program enrollment(s) private is recommended. 
  • In some cases, such as with Caracole's clients, a second client record can be created and set to private.

Level 2: Level 2 methods include setting client-level data to private but allowing basic client information (available from the Clarity Profile screen) to be shared. Use these methods when:

  • Clients whose information has already been shared refuse to sign the HMIS Privacy Notice and Client Consent Form. Setting program enrollment screens to private ensures all program-related data are kept private. 
  • Clients whose data is imported from Vesta: Setting the program enrollment record to private is the only method for making Vesta imported records private.
  • Enrollments should also be set to private at the client's request.
  • Client-level referral information should be set to private when:
    1. A client requests the data to not be shared or set to private.
    2. The referral or the referral note contains sensitive details related to legal issues, substance use, domestic violence, or health (physical or mental). 
    3. The referral or the referral note references Caracole of the YWCA.
  • Some agencies collect additional information through client-level services, notes, assessments, and public alerts. Individual client-level services, notes, assessments, and public alerts should be set to private when: 
    1. A client requests the data to not be shared or set to private.
    2. The service, note, assessment, or public alert contains sensitive details related to legal issues, substance use, domestic violence, or health (physical or mental).
    3. The service, note, assessment, or public alert contains references or mentions of Caracole or the YWCA.

Level 3: Methods provided in level 3 privacy settings allow specific data elements entered within a program enrollment to be set to private. For example, individual services, notes, assessments, events, and files entered at the program level can be set to private. Set individual program-level data elements to private when:

  • The client record is shared. And.
  • The program enrollment is shared. And
  • The client requests information not be shared. Or
  • The data element includes sensitive legal, substance use, domestic violence, or health (physical or mental) details. Or,
  • The data element includes any reference to Caracole or the YWCA.


How to Set Client Data to Private

Level 1 - Set the Entire Client Record to Private


1. Create a new client record


If the client agrees to share information, search for an existing client record and follow the process for enrolling the client into your program (see our article on Program Enrollments for more information). 


2. Set ROI permission to "No"

After creating the new client record, be sure to set the HMIS Release of Information (RoI) permission to "No."



3. Set the client record to private

After adding the client record, you'll see the yellow warning banner alerting you the HMIS Release of Information is missing or permission is not provided. This warning is alerting you the client's data has not been set to private.  



Click the Privacy Icon (shield) on the right sidebar under the yellow banner.




Click on 'Private' then 'Save Changes.'




 

You may find you cannot set an existing client record to Private. This is because the client's record has previously been shared, and multiple providers have contributed to the record. 




If your client requests their data to not be shared but you are not able to set the record to private,  you can either:

  1. Set the program enrollment(s) to private in the shared record. Use this approach if the client has a currently active HMIS ROI documented by another agency/program.
  2. Create a new client record and set it to private. 


Level 2 - Set Client-Level Data to Private

How to Set a Program Enrollment to Private

  1. Select the edit icon next to the assigned staff name after enrolling a client in a program or from the client's enrollment screen.
  2. Toggle on "Make Program Private" and click "Save Changes."

How to Set Client-Level Notes, Files, Assessments, and Referrals to Private

  1. From the client-level navigation, click on the tab of the item you want to set to private.
  2. Click on the edit button next to the time you want to set to private and click the private toggle, or click on the private toggle before saving the item.
  3. Make sure to save the item after toggling private on.

How to Set Client-Level Service Items to Private

  1. A service item must be saved before it can be set to private. 
  2. From the client-level History tab, click on the edit icon next to the service to be set to private.
  3. Toggle on "Private" and click "Save Changes."


Level 3 - Set Program-Level Data to Private

How to Set Program-Level Notes, Files, Assessments, and Referrals to Private

  1. From the program-level navigation, click on the tab of the item you want to set to private.
  2. Click on the edit button next to the time you want to set to private and click the private toggle, or click on the private toggle before saving the item.
  3. Make sure to save the item after toggling private on.

How to Set Service Items to Private

  1. A service item must be saved before it can be set to private. 
  2. from the program- or client-level "History" tab, click on the edit icon next to the service to be set to private.
  3. Toggle on "Private" and click "Save Changes."


Contact Us

If you need help, or wish to offer suggestions or feedback, please contact the Cincinnati/Hamilton County HMIS support team at HMISsupport@end-homelessness.org or by calling 513-263-2790 9:00am - 3:00pm Monday-Friday (excluding holidays).


When contacting HMIS Support, please do not include any Personal Identifiable Information (PII) such as names, social security numbers, birth dates, etc. Please use the Clarity Unique Identifier found on the Clarity client profile page.