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 (NEW SECTION!)

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 basic information (the information found on the Client Profile page) with other Cincinnati/Hamilton County CoC participating providers who may also work with that specific client. 


Clients have the option to refuse sharing their basic 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 set to “private.” Please see this article for instructions on setting a client profile to private. Clients cannot be refused services if they do not consent to share information. 


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 the client's record must be set to private.  Signature on the HMIS Privacy Notice and Client Consent Form can be documented in Clarity with an electronic signature, verbal consent, an attached PDF, or documentation of the location of a paper document kept by the agency (please note: do not use your agency name, project name, or address when documenting a location, rather, indicate the general location such as 'client file' or 'case manager's desk'). 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 basic client data in the HMIS? 

Only the enrolling agency staff members, database administrators, or auditors who have signed a confidentiality agreement will be allowed to see, enter, or use client-specific information entered into the HMIS. All information entered into the HMIS is protected and secured to protect the client's privacy. 


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: 

  • Know where to refer the client if they cannot answer the client’s questions. 
  • Uphold the client’s privacy in the HMIS.     


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 Access - CoC VI-SPDAT

  • Clients enrolled in the CoC VI-SPDAT program must agree that the data collected in this program (basic personal information) and assessment answers can be viewed by STEH Coordinated Access, Strategies to End Homelessness, and participating agencies to obtain housing.
  • CoC VI-SPDAT program data is accessible to all HMIS users who have access to STEH - Coordinated Access agency in Clarity.  This includes users from a cross selection of agencies. Users must complete additional training and obtain approval from the STEH Coordinated Access team before being granted access to this agency and program. Even though users only interact with their specific clients, because of the more sensitive enrollment and assessment data, an additional ROI is required.
  • The CoC VI-SPDAT ROI is located in the program level enrollment in the "Forms" tab
    • Must be completed for heads of households enrolled in the CoC-VI-SPDAT program (a single person is the head of their household).
    • Either upload a scanned copy or ask the client to sign the VI-SPDAT ROI electronically.
    • For more information on this process and a step-by-step guide, please see this article: How CE VI-SPDAT Works in Clarity : (freshdesk.com)

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.

KEYS 

  • Clients enrolled in KEYS must agree to their basic information being shared for the purpose of KEY participating agencies to provide services, review assessments, and develop  case plans. As KEYS is a collaborative project across multiple agencies, data entered into the KEYS programs are more broadly shared than standard HMIS data. Clients must agree that more sensitive enrollment and assessment data can be accessed by KEYS users from other KEYS partner agencies.
  • The KEYS ROI is located in the program level enrollment in the "Forms" tab 
    • Must be completed for heads of households enrolled in a KEYS program (a single person is the head of their household).
    • Click on the program level "Forms" tab in the client's KEYS enrollment (you must be logged into the appropriate KEYS to a Future without Youth Homelessness program).
    • Either upload a scanned copy or ask the client to sign the KEYS to a Future without Youth Homelessness - Release of Information form electronically.
    • Please review the KEYS manual for step-by-step instructions.

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.