HMIS Privacy Notice and Client Consent Form 

This article includes the following 
  • What is the HMIS Privacy Notice and Client Consent Form? 
  • When is it used? 
  • How is the data collected used in the Cincinnati/Hamilton County 
  • Who has access to basic client data in the HMIS? 
  • What is required of Agencies regarding this notice? 
  • What are clients' rights?
  • Additional Agency/Program Specific ROIs
What is the HMIS Privacy Notice and Client Consent Form? 

The HMIS Privacy Notice and Client Consent Form (also known as the Clarity HMIS Release of Information or ROI in Clarity) includes several important elements: a description of what an HMIS is, benefits for clients who participate, reasons why data is collected, how the information may be used, and a description of clients’ rights. Clients review this document to consent to share their information with other Cincinnati/Hamilton County CoC participating providers who may also work with that specific client. 


Clients have the option to refuse to share their data in the HMIS.  In this case, data is still entered within the HMIS system; the Clarity “Release of Information” should be set to “no,” and the client privacy setting should be set to “private.” Clients may agree to share information in Clarity and also request specific information be set to Private. See "Setting Clients to Private in Clarity" for instructions on how to set a client record or specific data elements to private. article about setting specific data to private in Clarity. Note: mentions of Caracole or YWCA should always be set to private.


The HMIS Privacy Notice and Client Consent Form is valid for seven years from the time of signing; however, a client can revoke it at any time by completing the HMIS Revocation of Consent Form.  This form can either be completed within Clarity or uploaded to a client’s files in Clarity. If a client revokes their consent to share basic information in HMIS,  notify HMISsupport@end-homelessness.org immediately with the client(s) Clarity Unique Identifier so the HMIS Support team can change a client’s privacy setting from public to private. Note: any information already shared between projects cannot be un-shared.  


When is it used? 
When initially engaged with an agency, clients must sign the HMIS Privacy Notice and Client Consent Form (also known as the Release of Information/ROI in Clarity).  Clients must have an active ROI for each agency they are actively receiving services from, or their Clarity record or specific enrollments must be set to private.  Signature on the HMIS Privacy Notice and Client Consent Form can be documented in Clarity by:

  • Electronic Signature: clients can sign the HMIS Privacy Notice and Client Consent Form in Clarity using a mouse or touchscreen.
  • Verbal Consent: can be used when obtaining a signed consent form is not possible.
  • Attached PDF: allows users to upload a scanned PDF version of a signed paper document.
  • Signed Paper Document: users can documentation of the location of a paper document kept by the agency. 
  • Household: this option should be used for household members who are not able to document their own sharing choice (e.g. children, other dependants, or other adult household members who are not present to determine their own sharing settings).
  • Outside Agency Verified: this option is available in the STEH Coordinated Access and KEYS agencies and can be used for clients who have an active signed HMIS Privacy Notice and Client Consent form at the user's primary agency.

An unexpired HMIS Privacy Notice and Consent Form can be used for multiple program enrollments within an agency.


How is the data collected used in the Cincinnati/Hamilton County CoC? 

Sharing information within the HMIS can help our CoC: 

  • Develop and improve quality and increased access of programs, services, and housing that meet our specific community needs 
  • Comply with state, federal, local, and funder requirements 
  • Decrease the need for clients to repeat basic information for multiple programs 
  • Contribute to aggregate data used to better understand and improve the homeless service system in our community 


Who has access to client data in the HMIS? 

  • Only trained and approved staff with a reason to use HMIS have access.
  • All staff must commit in writing to keep information private and only access information for a specific business reason (like working with a specific person/family or supervising a specific program).
  • The HMIS is hosted on a secure server and data is unable to be read when not being used.


What is required of Agencies regarding this notice?  

A client’s privacy is very important, and participating agencies and HMIS users are responsible to make sure the client’s personal information is secure. HMIS users and agencies need to: 

  • Post the HMIS Privacy Notice and Client Consent Form where it is easily viewed by clients who are homeless. 
  • Understand and be able to explain the HMIS Privacy Notice and Client Consent Form to clients. 
  • Present and ask the client to sign (or refuse) the HMIS Privacy Notice and Client Consent Form prior to collecting HMIS data. 
  • Enter each Client's consent or refusal of consent into Clarity.  
  • Make sure all Client data is entered into the HMIS. 
  • Know where to refer the client if they have questions or concerns.
  • Uphold the client's privacy in HMIS, as described in the HMIS Privacy Notice and Client Consent Form, HMIS User Agreement and Code of Ethics, and the HMIS Policies and Procedures.

What are Clients’ rights? 

All Cincinnati/Hamilton County CoC clients have the right to (1) refuse to disclose Personal Identifiable Information (PII), (2) use the agency’s services even if s/he refuses to sign the consent form, and (3) revoke consent at any time by submitting a request in writing. 

Clients also have the right to request in writing: 

  • A copy of all PII collected 
  • An amendment to any PII used to make decisions about their care and services (this request -may be denied at the discretion of the agency, but the client’s request should be noted in the project records) 
  • An account of all disclosures of client PII 
  • Restrictions on the type of information disclosed to outside partners 
  • A current copy of the Partner Agency’s privacy statement 


Additional Agency/Program Specific ROIs:

Coordinated Exit

  • Clients enrolled in the EHV Referral or HCV Referral programs must agree that the data collected in these programs can be used to submit applications to CMHA for Emergency Housing Vouchers or Housing Choice Vouchers.
  • The Coordinated Exit specific data sharing language has been combined with the HMIS Privacy Notice and Client Consent language. This updated language is available from the Client Privacy screen in Clarity. 
    • Must be completed for heads of households enrolled in the EHV Referral or HCV Referral program (a single person is the head of their household).
    • Make sure you are logged into the STEH Coordinated Exit agency in Clarity (note: this consent form is only available in Clarity).
    • Click on the shield icon from the client's Profile screen.
    • Click on 'Add Release of Information,' this step must be completed even if the client has an active signed release of information recorded.
    • Ask the client to sign an electronic version of the HMIS/C-Exit release form, upload a scanned document, or note where a paper version of the release can be signed.

Other Agency-Specific ROIs

  • Some Agencies and other specific programs share information with other resources in order to provide the most effective services to support individual clients/households based on their specific needs. Clients must agree to share this information. 
    • Some agencies develop these forms in-house and track their completion in Clarity in different ways:
      • Agency Specific ROIs made available in the program level "Forms" tab in Clarity
      • Agency Specific ROIs as a service in the program level "Provide Services" in Clarity
    • Contact your supervisor to learn if and how your agency tracks your agency-specific ROI in Clarity.

 

For more information and detailed steps on how to enter, update, or revoke the HMIS Policy and Privacy Notice/Release of Information, please see these articles or email HMISsupport@end-homelessness.org : 


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 to 3:00pm Monday through Friday excluding holidays. 


Note: When contacting HMIS Support about a particular client, please do not send personally identifiable information such as full name, social security number, medical records, or any other information used to determine a person's identity. Instead, send the client's Clarity Unique Identifier found on the client's Clarity profile.