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Michigan State Homeless
Management Information System (MSHMIS)
Privacy Notice
The MSHMIS was developed to meet a data collection
requirement made by the United States Congress to the Department of
Housing and Urban Development (HUD). Congress passed this requirement in order to
get a more accurate count of individuals who are homeless and to identify
the need for and use of different services by those individuals and families. We
are working to assist the State of Michigan in meeting the goal set by
Congress by collecting statistical information on those who use our services
and report that information to a central data collection system.
Many agencies in this area also use the MSHMIS to: keep computerized
case records, and with your permission, share information you
provide to us with other MSHMIS participating agencies. The range of
information that you may agree to allow us to share includes: basic identifying
demographic data (e.g., name address, birth date, phone number), the
nature of your situation, the services and referrals you receive from
our agency.
Sharing information with MSHMIS and other agencies
helps us to better understand the number of individuals who need services
from more than one agency. This may help us to meet your needs and the needs of
others in our community by allowing us to develop new and/or more efficient
programs. Sharing information through MSHMIS can also help us
make referrals more easily, often with less paperwork for us and for
you.
Maintaining the privacy and safety of those using
our services is very important to us. Information gathered about you is personal and
private. Your record will only be shared if you give your permission
to do so. Depending on your individual situation, there may be benefits
and/or risks for you to carefully consider before you decide whether
or not to consent to the release of any identifying information to another
agency. You also have the right to request that your name be entered
in the system as “anonymous”. You cannot and will not
be denied services that you would otherwise qualify for if you choose
not to share information.
Please note that even if you do not want your information
shared with other agencies or your actual name entered into the system,
we must still report some information to the central data collection
system, which contains provisions to protect your name and privacy,
because of our federal and state requirements.
CONFIDENTIALITY RIGHTS
This agency follows all confidentiality regulations. In addition
to this privacy notice, our agency has its own confidentiality policy.
This specifically includes the confidentiality regulations regarding
the disclosure of alcohol and/or drug abuse records (as contained in
the Code of Federal Regulations, 42 CFR Part 2,) and medical information
and records (as contained in the Protected Individually Identifiable
Health Information, under HIPPA.
Even if you choose to allow us to share information with other agencies,
records about substance abuse, physical and mental health, HIV, and domestic
violence will not be shared without your specific, additional release
of information.
GRIEVANCE PROCEDURE
If you believe that your confidentiality was not protected, you may file
a complaint or grievance as outlined in the agency grievance policy.
YOUR INFORMATION RIGHTS
As a client receiving services at this agency, you have the following
rights:
- Access to your record. You have the
right to review your MSHMIS record. At your request, we will
assist you in viewing the record within 5 working days.
- Correction of your record. You
have the right to request to have your record corrected so that information
is up-to-date and accurate to ensure fairness in its use.
- Refusal. You have the right to refuse
consent to share your information with other agencies. You cannot
be denied services that you would otherwise qualify for if you refuse
to sign the MSHMIS client Information Release Authorization form. Please
note that if you refuse, information will still be entered into the
system for statistical purposes, but your information will be closed
so that no other agency will have access to it.
- Anonymous Entry. You have a right
to have your name entered as “Anonymous” if for some reason
your name presents a risk even if not shared with other agencies.
- End Date of Consent and Withdrawal of the Release of
Information Form. If you choose to allow information
to be shared with other agencies, your release will be in effect
for the specific time frame you have designated. After that
information will no longer be shared unless you sign another release. The
release of information agreement can be withdrawn at any time by
making a written request at this agency.
- Grievance. You have the right to
be heard if you feel that you have been unjustly served, put at personal
risk, or harmed. Our agency has established a formal grievance
process for you to use in such a circumstance.
HOW YOUR INFORMATION WILL BE KEPT SECURE
Protecting the safety and privacy of individuals receiving services and
the confidentiality of their records is of paramount importance to
us. We have done several things to make sure your information
is kept safe and secure:
Through training, policies and procedures, and software:
- The computer program we use has the highest degree of security protection
available.
- Only trained and authorized individuals will enter or view your personal
information.
- Your name and other identifying information will not be contained
in MSHMIS reports that are issued to local, state, or national agencies.
- Employees receive training in privacy protection and agree to follow
strict confidentiality standards before using the system.
- The server/database/software only allows authorized
individuals access to the information. Only those who should
see certain information will be allowed to see that information.
- The server/database will communicate using 128-bit
encryption – an
Internet technology intended to keep information private while it is
transported back and forth across the Internet. Furthermore,
identifying data stored on the server is also encrypted or coded so
that it cannot be recognized.
- The server/database exists behind a firewall – a
device meant to keep hackers/crackers/viruses/etc. away from the
server.
- The main database will be kept physically secure, meaning only authorized
personnel will have access to the server / database.
WHAT IS INFORMED CONSENT?
Information about you and the services provided to you cannot be given
to anyone without your giving informed consent. In order to be
able to give informed consent:
- You should be told about the benefits, risks, and available alternatives
to sharing your information (KNOWLEDGE).
- You should be able to reasonably understand the information including
the risks, benefits, other options, and other consequences (UNDERSTANDING).
- You should not be forced or pressured into a decision. The
choice you make should be your decision (VOLUNTARY). ¨
BENEFITS OF MSHMIS AND AGENCY INFORMATION SHARING
Information you provide us can play an important role in our ability
and the ability of other agencies to continue to provide the services
that you and others in our community are requesting.
Allowing us to share your real name, even in the absence of other information,
results in a more accurate count of individuals and services used. The
security system is designed to create a code that will protect your identity
on the system. A more accurate count is important because it can help
us and other agencies:
- Better demonstrate the need for services and the specific types of
assistance needed in our area.
- Obtain more money and other resources to provide services.
- Plan and deliver quality services to you and your family.
- Assist the agency to improve its work with families and individuals
who are homeless.
- Keep required statistics for state and federal funders (such as HUD).
You may choose to agree to share additional information with one or
more MSHMIS participating agency in order to:
- Promote coordination of services so your needs are better met
- Make referrals easier by reducing paperwork
- Avoid having to repeat as much information to get assistance from
other agencies
RISKS IN SHARING INFORMATION
While the MSHMIS system was designed to promote better services for those
who are homeless, there are risks that may lead some individuals to choose
to do one or more of the following:
- Allow only your name, age, and social security
number (optional) to be shared with all participating agencies. All
other information including where you are being served and your particular
situation are kept confidential or shared with only select agencies.
- Allow some statistical or demographic information to be shared with
select other agencies, but do not allow other more personal data such
as health, mental health, drug/alcohol use history or domestic violence
information to be shared.
- Close all information including identifying information
from all sharing. Only this agency may see the information.
- Use an anonymous client ID so that no identifying information exists
on the record even within this agency.
- Risks you should consider before deciding whether and what type of
information to share include:
- Physical harm or other negative consequences to you or members of
your family if someone knew that they could find you from the information
shared with other participating MSHMIS agencies.
- Physical harm or other negative consequences to you or members of
your family if someone found out you sought help, particularly if you
or your children have experienced domestic violence, sexual assault,
stalking, or child abuse.
- There are others who may work or volunteer at other MSHMIS participating
agencies who you may not want to have access to your information or
to know you are seeking services.
- The degree to which you are satisfied by the confidentiality provisions
explained about the MSHMIS system.
¨ Michigan
Department of Community Health, “Know Your Rights” brochure.
For information about joining
in Macomb County's HMIS program please contact:
Heather Uhley
HMIS System Administrator I
75 North River Road
Mt. Clemens, MI 48043
(586) 469-7702
huhley@macomb-stclairworks.org
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