Privacy Policy

Email

1. When you send us email we won’t keep or share your email address with anyone outside of Community Housing Network, Inc. (CHN) staff and our contractors. We’ll only use your email address to respond to your requests for information.
2. If you sign up for one of our e-newsletter lists, we’ll only send you the kinds of information you’ve requested. We won’t maintain your name on the list and won’t share your email address with anyone outside of CHN.
3. If you use the “email a friend,” feature in one of our e-Newsletters, we will use your email address only to let your friend know who sent the web address, so he or she can reply to you.

Information collection

When you visit our website, we collect certain information about your visit that does not identify you personally. We can tell the type of computer, browser, and web service you are using. We also know the date and time you visit and the pages you visit. Collecting this information helps us design the site according to your needs.

There are several pages on our website that provide an opportunity for people to engage with us by completing and submitting an inquiry form. We have systems in place that ensure people outside of CHN cannot access any of the information you submit. This information is never shared with any individual or organization outside of CHN, unless required by a law enforcement investigation. Any information we collect for those investigations is destroyed according to federal guidelines.

Site security

1. We monitor visits to the website to identify any attempt to tamper with it.
2. When you submit personal information (including credit card, address, email address, and phone number data) using our website – for example, if you register for a Homebuyer  Education workshop, make an online donation, or submit an inquiry to our Housing Resource Center – we have systems in place that ensure people outside of CHN cannot access your personal information.
3. We would only try to identify you personally when required to do so by a law enforcement investigation. Any information we collect for those investigations is destroyed according to federal guidelines.
4. Tampering with CHN’s website is against the law. If anyone tries to tamper with it, they may be punished under the Computer Fraud and Abuse Act of 1986 and the National Information Infrastructure Protection Act.

Links to other sites

1. Our website has links to many other websites. When you go to another site, you are subject to the privacy and security policies of that site. CHN cannot attest to the accuracy of information provided there.
2. Linking to a website does not constitute an endorsement by CHN, Inc., or any of its employees, of the sponsors of the site or the products presented on the site.

Michigan State Homeless Management Information System (MSHMIS) recommended privacy notice

The MSHMIS was developed to meet a data collection requirement made by the United States Congress to the U.S. 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. Some, only with your permission, share information you provide to us with other MSHMIS participating agencies. The information that you may agree to allow us to collect and share includes: basic identifying demographic data (e.g., name address, birth date, phone number), the nature of your situation, and 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. We collect information only when appropriate to provide services, manage our organization, or as required by law. 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. The Michigan Coalition Against Homelessness administers the MSHMIS database.

Confidentiality rights

This agency has a confidentiality policy that has been approved by its Board of Directors.

This policy follows all HUD and HIPAA confidentiality regulations that are applicable to this agency, including those covering programs that receive HUD funding for homeless services (Federal Register/Vol. 69, No. 146), and those covered under the HIPAA privacy and security rules which govern confidential health information such as the diagnosis, treatment, of a mental health disorder, a drug or alcohol disorder, an AIDS/HIV condition or a domestic violence situation.

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.

This agency is restricted to using or disclosing personal information from the MSHMIS to the following circumstances:

• To provide or coordinate services to an individual with proper client consent;
• For functions related to payment or reimbursement for services.
• To carry out administrative functions including but not limited to legal, audit, personnel, planning, oversight and management functions;
• Databases used for research, where all identifying information has been removed.
• Contractual research where privacy conditions are met.
• Where a disclosure is required by law and disclosure complies with and is limited to the requirements of the law. Instances where this might occur are during a medical emergency, to report a crime against staff of the agency, or to avert a serious threat to health or safety.

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:

1. Allow only your name, year of birth, and partial 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.
2. 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.
3. Close all information including identifying information from all sharing. Only this agency may see the information.
4. Use an anonymous client ID so that no identifying information exists on the record, even within this agency.

PRIVACY NOTICE AMENDMENTS: The policies covered under this Privacy Notice may be amended over time and those amendments may affect information obtained by the agency before the date of the change. All amendments to the Privacy Notice must be consistent with the requirements of the Federal Standards that protect the privacy of consumers and guide HMIS implementation and operation.