HMIS & CSMS Privacy Practices

The purpose of this notice is to explain to you why FSAD collects personal information from you and to refer you to FSAD's HMIS and CSMS Statement for Notice of Privacy Practices for additional information regarding how this information may be used or disclosed.
 
This notice describes the privacy practices of FSAD as it relates to the Client Services Management System. FSAD collects personal information about the people and customers FSAD serves in computer systems called Client Services Management System ("CSMS").  Broward County uses a single information system as the official Client Services software and has selected a system called Client Services Management System (CSMS).
 
FSAD collects personal information directly from you for reasons that are discussed in more detail in FSAD's CSMS Statement for Notice of Privacy Practice. FSAD may be required to collect some personal information by law or by organizations that provide funds to operate some of its programs. Other personal information that is collected is important to run FSAD's programs, to improve services, and to better understand the needs of individuals being served. FSAD only collects information that is considered to be appropriate for the provisions of services which are required by its funding sources or otherwise required. 
 
When you request services from FSAD, information is entered into a computer system about you and members of your family called CSMS. CSMS is used by several social service agencies in Broward County that provide housing and related services. FSAD collects personal information directly from you for reasons that are discussed in more detail in FSAD's CSMS Statement for Notice of Privacy Practices. FSAD may be required to collect some personal information by law or by organizations that give FSAD funds to operate its programs. Other personal information that FSAD collects is important to run its programs, to improve services for individuals who need housing and/or case management assistance, and to better understand the needs of those individuals. FSAD only collects information that FSAD considers to be appropriate for the provisions of services which are required by its funding sources or otherwise required. FSAD may use or disclose your information to provide you with services. FSAD may also use or disclose it to comply with legal and other obligations. FSAD assumes that you agree to allow FSAD to collect information and to use or disclose it as described in more detail in FSAD's CSMS Statement for Notice of Privacy Practices.
 
You can inspect personal information about you that FSAD maintains, as provided in FSAD's CSMS Statement for Notice of Privacy Practices. You can also ask FSAD to correct inaccurate or incomplete information. Please contact your Case Manager to make this request.
 
Feel free to ask FSAD about its privacy and security policies and practices. FSAD will respond to any questions and complaints regarding its privacy and security policies and practices. Please read FSAD's CSMS Statement for Notice of Privacy Practices for additional information. You will be provided with a copy of FSAD's CSMS Statement for Notice of Privacy Practices upon request by contacting Broward County's Family Success Administration Division at 954-357-6367 during normal business hours which are usually Monday to Friday between 8:30AM to 5PM excluding County holidays and other times when County offices are closed. You may also access FSAD's CSMS Statement for Notice of Privacy Practices by clicking on the following link: FSAD's CSMS Statement for Notice of Privacy Practices.
 
[January 31, 2017]
 
 
BROWARD COUNTY FAMILY SUCCESS ADMINISTRATION DIVISION ("FSAD") CSMS STATEMENT FOR NOTICE OF PRIVACY PRACTICES
       
As stated in FSAD's Notice of Privacy Practice ("Notice"), FSAD's CSMS Statement for Notice of Privacy Practices ("Statement") describes in more detail the privacy practices of FSAD as it relates to the Client Services Management System. FSAD collects personal information about the people and customers that FSAD serves in computer systems called Client Services Management System ("CSMS").  Broward County uses a single information system as the official case management software and has selected a system called Client Services Management System ("CSMS").
 
FSAD has included a brief description of what CSMS is, how it works, and what it does. CSMS is a web-based software application used to collect demographic information and service outcome information on people and customers served by FSAD. The purpose of CSMS is to record and store customer-level information about the numbers, characteristics, and needs of persons who use FSAD's supportive services and about people and customers who receive assistance from FSAD. CSMS also helps FSAD to understand patterns of service use and measures the effectiveness of programs.
 
The creation and maintenance of centralized customer records also allows for the development of long-term goals and case plans. The ultimate goal is to provide you access to services for which you may qualify. To reach this goal, manageable strategies must be developed, implemented, and tracked. CSMS allows FSAD and its service providers to identify and establish phased goals-over-time and the action steps necessary to achieve those goals. The software gives FSAD the power to drive an outcome rather than simply hoping for the best.
 
CSMS also comes with an array of reporting tools capable of collating both aggregate and local data. Among other things, customized reports give FSAD the ability to spot trends in service demand and gaps in service delivery. The Reporting Module assists FSAD in the collection of meaningful data. The software is fully-encrypted and password protected.
 
CSMS is used to collect and share customer data; manage community resources; organize shelter information in real time; and get accurate outcome results. CSMS can also track outcomes and movements of services consumers across programs sharing CSMS which are also using the same software as Broward County.
 
In addition CSMS can benefit the community by providing electronic storage of customer records, facilitating enhancement of programs and services, simplifying funder reporting, enhancing access to needed resources and services, and providing accurate data to assess service gaps across the support management and policy making.
 
FSAD protects "personal information" contained in electronic data format. Such "personal information" means either of the following:

  1. An individual's first name or first initial and last name in combination with any one or more of the following data elements for that individual:
    1. A social security number;
    2. A driver license or identification card number, passport number, military identification number, or other similar number issued on a government document used to verify identity;
    3. A financial account number or credit or debit card number, in combination with any required security code, access code, or password that is necessary to permit access to an individual's financial account;
    4. Any information regarding an individual's medical history, mental or physical condition, or medical treatment or diagnosis by a health care professional; or
    5. An individual's health insurance policy number or subscriber identification number and any unique identifier used by a health insurer to identify the individual.
  2. A user name or e-mail address, in combination with a password or security question and answer that would permit access to an online account.

Additionally, personal identifying information of a temporary cash assistance program participant (except for information identifying a parent who does not live in the same home as the child) are confidential and exempt information but may be released for purposes directly connected with certain programs and for specific purposes.
 
FSAD uses the personal information that it collects to run its programs and to help FSAD improve its services. Also, FSAD is required to collect information for the individuals and agencies that fund its programs. Your information will help FSAD to obtain the appropriate services for you in the programs offered by FSAD and other agencies. FSAD may also use or disclose personal information to comply with legal, funding, and other reporting obligations.
 
As a customer, you may request to inspect the electronic or paper record of the personal information that FSAD maintains in CSMS. You may also ask FSAD to correct inaccurate or incomplete information. You may ask FSAD about the privacy practices of CSMS. FSAD will respond to your questions or complaints within a reasonable time after receipt of your request.
 
Please read this entire Statement for more details. A copy of the entire Statement can be provided to you upon request.

  1. What This Statement for the Notice Covers:
    1. This Statement for the Notice describes the privacy practices of FSAD.
    2. The practices in the Statement for the Notice covers the processing of protected personal information for customers of FSAD.
    3. Protected personal information and any information FSAD maintains about a customer that:
      1. allows identification of a customer directly or indirectly;
      2. can be manipulated by a reasonably foreseeable method to identify a specific customer; or
      3. can be linked with other information to identify a customer.
  2. Why Collect Personal Information?
    1. Personal information is collected by FSAD for a number of purposes including, but not limited to, the following:
      1. To provide or coordinate services to customers;
      2. To locate other programs that may be able to assist customers;
      3. For functions related to payment or reimbursement from others (such as third parties) for services that are provided;
      4. To operate Broward County's overall  organization of which FSAD is a part, including administrative functions such as legal, audits, personnel, oversight, and management functions;
      5. To comply with government reporting obligations; or
      6. When required by law.
    2. FSAD will only use lawful and fair means to collect personal information as described in this Statement for the Notice. FSAD may also get information about you from other sources, including the following:
      1. Individuals who are with you;
      2. Other private organizations that provide services;
      3. Government agencies; or
      4. Telephone directories and other published sources.
    3. FSAD will post notices (as stated below) at various intake and service locations:
       
      NOTICE OF PRIVACY PRACTICE

      FSAD collects personal information directly from you for reasons that are discussed in FSAD's CSMS Notice of Privacy Practice and FSAD's CSMS Statement for Notice of Privacy Practice. FSAD may be required to collect some personal information by law or by organizations that provide funds to operate some of its programs. Other personal information that is collected is important to run FSAD's programs, to improve services, and to better understand the needs of individuals being served. FSAD only collects information that is considered to be appropriate for the provisions of services, required by its funding sources or otherwise required.  
  3. Use and Disclosure of Personal Information
    1. FSAD will use or disclose personal information for activities described in this part of the Statement for Notice.  Unless you provide immediate written notification to FSAD, it assumes that you consent to the use or disclosure of your personal information for the purposes described and for other uses and disclosures (unless restricted by federal or state of Florida's laws) including, but not limited to, the following:
      1. To provide or coordinate services to individuals (shelter, housing, case management, and other services).
      2. For functions related to payment or reimbursement for services.
      3. To carry out administrative functions, including, but not limited to,  personnel oversight, management functions, legal, and auditing purposes.
      4. To create de-identified (anonymous) information that can be used for research and statistical purposes.
      5. When required by law.
      6. To avert a serious threat to health or safety if:
        (1)  FSAD believe that the use or disclosure is necessary to prevent or lessen a serious and imminent threat to the health or safety of an individual or the public, and
        (2)  The use or disclosure is made to a person reasonably able to prevent or lessen the threat, including the target of the threat.
      7. To report victims of abuse when authorized by law.
      8. For research purposes unless restricted by other federal or state of Florida's laws.
      9. To a law enforcement official for a law enforcement purpose (if consistent with applicable law).
      10. For judicial and administrative proceedings in response to a lawful court order, court-ordered warrant, subpoena, or summons issued by a judicial officer, or a grand jury subpoena.
      11. To comply with government reporting obligations for HMIS and CSMS requirements.

Before FSAD makes any use or disclosure of your personal information that is not described here, FSAD will first seek your written consent unless the use or disclosure is allowed by federal or state of Florida's laws.

  1. How to Inspect and Correct Personal Information
    1. You may inspect and have a copy of your personal information that FSAD maintains by providing FSAD a reasonable time to provide this information to you. FSAD's staff will offer to explain any information that you do not understand. FSAD will not be able to provide legal advice to you.
    2. FSAD will consider a request from you for correction of inaccurate or incomplete personal information that FSAD maintain about you. If FSAD agree that the information is inaccurate or incomplete, FSAD may delete it, or FSAD may choose to mark it as inaccurate, incomplete and may choose to supplement it with additional information.
    3. To inspect, obtain a copy of, or ask for correction of your information, by submitting your request in writing to your case manager.
    4. FSAD may deny your request for inspection or copying of personal information if allowed by applicable laws under the following circumstances:
      1. The information was compiled by FSAD's attorney(s) in reasonable anticipation of litigation or comparable legal or administrative proceedings;
      2. The information is about another customer;
      3. The information was obtained under a promise of confidentiality and the disclosure would reveal the source of the information as long as there is applicable law protecting the confidentiality of the source; or
      4. Disclosure of the information would be reasonably likely to endanger the life or physical safety of any individual as long as there is applicable law protecting the confidentiality of the source.
    5. If FSAD denies a request for access or correction, FSAD will explain the reason for the denial. FSAD will also include, as part of the personal information that it maintains, documentation of the request and the reason for the denial.
    6. FSAD may reject repeated or harassing requests for access or correction of information; however, FSAD intends to correct incorrect information as soon as practicable after receipt of notification, and FSAD intends to comply with requests for records within a reasonable time after receipt of such requests.
  2. Data Quality
    1. FSAD collects only personal information that is relevant to the purposes for which FSAD plans to use it. To the extent necessary for those purposes, FSAD seeks to maintain only personal information that is accurate, complete, and timely.
    2. FSAD will maintain all personal information as required by federal, state, or local laws.
  3. Complaints and Accountability
    1. FSAD accepts and considers questions or complaints about its privacy and security practices.
       
      Any questions or complaints can be brought to your Case Manager.
       
      If you feel your question or complaint is not fully addressed within a reasonable timeframe, you may register a complaint with Broward County's Family Success Administration Division by calling 954-357-6367 during normal business hours which is usually Monday to Friday between 8:30AM to 5PM excluding County holidays and other times when County offices are closed.

[Statement for Notice Revised January 31, 2017]