The HMIS Notice and the HMIS Privacy Statement, describes the HMIS privacy
practices of FSAD. FSAD collects personal information about the people and
customers it serves using the HMIS computer systems FSAD uses a single
information system as its official HMIS software called ServicePoint ("ServicePoint").
FSAD's records are subject to public disclosures under Florida Public Records
laws unless confidential or exempted by State of Florida's laws, federal laws,
federal regulations (including federal register) or other applicable regulations
protecting certain HMIS-related information. You might provide certain personal
information to FSAD that does not qualify as protected personal information
("Protected Personal Information" or "PPI") under such laws and regulations.
Protected Personal Information or PPI is any information maintained by a Covered
Homeless Organization ("CHO") about a living homeless client or homeless
individual that: (1) Identifies a specific individual directly or indirectly;
(2) can be manipulated by a reasonable foreseeable method to identify a specific
individual; or (3) can be linked with other available information to identify a
specific individual. A CHO is any organization that records, uses, or processes
PPI on homeless clients for an HMIS.
FSAD collects personal information directly from you for reasons that are
discussed in the HMIS Notice and the HMIS Privacy Statement. 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, legal, reporting obligations, and
When you request services from FSAD, information is entered into the HMIS about
you and members of your family. HMIS is used by FSAD and several social service
agencies in the State of Florida that provide housing and related services. 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 assistance, and to better understand the needs of
those individuals. FSAD only collects information that FSAD considers
appropriate for the provisions of services which are required by its funding
sources, legal, law, reporting obligations, other obligations or as otherwise
required. FSAD may use or disclose your information in order to provide you with
services. By providing your personal information to FSAD, you agree to allow
FSAD to collect it and to use or disclose it as described in the HMIS Notice
and the HMIS Privacy Statement.
You can inspect your personal information that FSAD maintains in its HMIS as
provided in the HMIS Notice and the HMIS Privacy Statement. 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 HMIS privacy practices. FSAD will respond to any
questions and complaints regarding its HMIS privacy \ practices. Please read the
HMIS Notice and the HMIS Privacy Statement for additional information. You will
be provided with a copy of the HMIS Notice and the HMIS Privacy Statement 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.
As a FSAD's customer, you may request to inspect the electronic or paper record
of the personal information that FSAD maintains in its HMIS. You may also ask
FSAD to correct inaccurate or incomplete information. You may ask FSAD about the
HMIS privacy practices. FSAD will respond to your questions or
complaints within a reasonable time after receipt of your request.
Please read the entire HMIS Notice and the HMIS Privacy Statement for more
detail. A copy of such document(s) can be provided to you upon request.
- What the HMIS Notice Covers:
- The HMIS Notice and the HMIS Privacy Statement, describe FSAD's HMIS
- The practices covers the processing of protected personal
information for customers of FSAD.
- Protected personal information and any information FSAD maintains
about a customer (who is a living homeless client or a homeless
- allows identification of a customer directly or indirectly;
- can be manipulated by a reasonably foreseeable method to
identify a specific customer; or
- can be linked with other information to identify a customer.
- Why Collect Personal Information?
- Personal information is collected by FSAD for a number of
purposes including, but not limited to, the following:
- To provide or coordinate services to customers;
- To locate other programs that may be able to assist customers;
- For functions related to payment or reimbursement from others
(such as third parties) for services that are provided;
- 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;
- To comply with government reporting obligations; or
- When required by law.
- FSAD will only use lawful and fair means to collect personal
information as described in the HMIS Notice and the HIMS Privacy
Statement. FSAD may also obtain information about you from other
sources, including the following:
- Individuals who are with you;
- Other private organizations that provide services;
- Government agencies; or
- Telephone directories and other published sources.
- FSAD will post notices (similar to that shown below) at each intake
(or comparable location) that explain generally the reason for
collecting this information:
FSAD NOTICE OF HMIS PRIVACY PRACTICE
Family Success Administration Division ("FSAD") collects personal
information directly from you for reasons that are discussed in FSAD's
Homeless Management Information System ("HMIS") Notice of Privacy
Practices (the "HMIS Notice") and FSAD's HMIS Privacy Statement. 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 FSAD collects is important to run its
programs, to improve services for homeless persons or other individuals,
and to better understand the needs of homeless persons or other
individuals being served. FSAD only collects information that it
considers to be appropriate for the provisions of services, required by
its funding sources or otherwise.
- Use and Disclosure of Personal Information
- FSAD will use or disclose personal information for activities
described in the HMIS Notice and the HMIS Privacy Statement.
Unless you provide immediate written notification to FSAD at the
applicable e-mail address or other physical address obtained from your
case manager, FSAD 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
or regulations) including, but not limited to, the following:
- To provide or coordinate services to individuals (shelter,
housing, case management, and other services).
- For functions related to payment or reimbursement for services.
- To carry out administrative functions, including, but not
limited to, personnel oversight, management functions, legal,
reporting obligations and auditing purposes.
- To create de-identified (anonymous) information that can be used
for research and statistical purposes.
- When required by law.
- 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.
- To report victims of abuse when authorized
- For research purposes unless restricted by
other federal or state of Florida's laws or regulations.
- To a law enforcement official for a
law enforcement purpose (if consistent with applicable laws and
- For judicial and administrative
proceedings in response to a court order, court-ordered warrant,
subpoena, summons issued by a judicial officer, a grand jury
subpoena or for Broward County (including FSAD) to properly
represent itself or defend itself in any pending or threatened
- To comply with government reporting obligations
for HMIS requirements.
Before FSAD makes any use or disclosure of your personal information
that is not described in the HMIS Notice and the HMIS Privacy
Statement, FSAD will first attempt to seek your written consent
unless the use or disclosure is allowed by federal or state of
Florida's laws or regulations.
- How to Inspect and Correct Personal Information
- 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
- 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 revise it, or FSAD may choose to
mark it as inaccurate, incomplete and may choose to supplement it
with additional information.
- To inspect, obtain a copy of, or ask for
correction of your information, you will need to submit your request
in writing to your case manager.
- FSAD may deny your request for inspection or
copying of personal information if allowed by applicable laws or
regulations under the following circumstances:
- The information was compiled by FSAD's
attorney(s) in reasonable anticipation of litigation or comparable
legal or administrative proceedings;
- The information is about another customer;
- 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;
- 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; or
- If otherwise allowed by other applicable laws,
rules, requirements, regulations or as FSAD determine appropriate
under Broward County's practices and procedures.
- 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
- FSAD may reject repeated or harassing requests
for access or correction of HMIS related information; however, if
FSAD denies an individual's request for access or correction to such
information, FSAD will explain the reason for the denial to the
individual and will include documentation of the request and the
reason for the denial as part of the personal information (or
protected personal information) about the individual. FSAD
will attempt to correct incorrect information as soon as practicable
after receipt of written notification, and FSAD intends to comply
with requests for records within a reasonable time after receipt of
- Data Quality
- 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.
- FSAD will maintain all personal information as
required by federal, state, or local laws.
- Complaints and Accountability
- FSAD accepts and considers questions or
complaints about its privacy 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.
[Dated: January 31, 2017]