Privacy Policy for Gladden Community House

Updated November 12, 2021

What this Policy Covers.

1. This document describes the privacy policy and practices of Gladden Community
House. Our main office is at 183 Hawkes Avenue, Columbus, Ohio 43223.
2. This policy covers the collection, use, and maintenance of protected personal
information for clients of Gladden Community House, as an agency affiliated
with the Community Shelter Board (CSB).
3. Protected Personal Information (PPI) is any personal information we maintain
about a client that:
a. allows identification of an individual directly or indirectly;
b. can be manipulated by a reasonably foreseeable method to identify a
specific individual; or
c. can be linked with other available information to identify a specific client.
4. We adopted this policy because the Department of Housing and Urban
Development issued standards for Homeless Management Information Systems.
We intend our policy and practices to be consistent with those standards. See 69
Federal Register 45888 (July 30, 2004).
5. This policy informs our clients, our staff, and others how we process personal
information. We follow the policy and practices described in this privacy policy.
6. We may amend our policy or practices at any time. Amendments may affect PPI
that we obtained before the effective date of the amendment.
7. We give a written copy of this privacy policy to any individual who asks for it.
8. We maintain a copy of this policy on our website at www.gladdenhouse.org.

How and Why We Collect PPI.
1. We collect PPI only when appropriate to provide services or for another specific
purpose of our organization or when required by law. We may collect
information for these purposes:
a. to provide individual case management;
b. to produce aggregate-level reports regarding use of services;
c. to track individual program-level outcomes;
d. to identify unfilled service needs and plan for the provision
of new services;
e. to conduct research for consulting and/or educational purposes; and
f. to accomplish any and all other purposes deemed appropriate by CSB.
2. We only use lawful and fair means to collect PPI.
3. We normally collect with the knowledge or consent of our clients. If you seek our
assistance and provide us with PPI, we assume that you consent to the collection
of information described in this policy.
4. We may also receive PPI about you from other agencies who contract with the
Community Shelter Board. We do not share PPI with agencies outside of those in
that contract.
5. We post a sign at our intake desk or other location explaining the reasons we ask
for PPI. The sign says:
We collect information about homeless individuals from agencies for reasons that
are discussed in our privacy policy. We may be required to collect some personal
information by law or by organizations that give us money to operate this
program. Other personal information that we collect is important to run our
programs, to improve services for homeless individuals, and to better understand
the needs of homeless individuals. We only collect information that we consider
to be appropriate. If you would like to see our privacy policy, our staff will
provide you with a copy.

How We Use and Disclose PPI.
1. We use or disclose PPI for activities described in this part of the policy. We may
or may not make any of these uses or disclosures of your PPI. We assume that
you consent to the use or disclosure of your PPI for the purposes described below
and for other uses and disclosures that we determine to be compatible with these
uses or disclosures:
a. to provide or coordinate services to individuals;
b. for functions related to payment or reimbursement for services;
c. to carry out administrative functions such as legal, audits,
personnel, oversight and management functions;
d. to create de-identified (anonymous) information;
e. when required by law to the extent that use or disclosure complies with
and is limited to the requirements of the law;
f. to avert a serious threat to health or safety if:
i. we 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
ii. the use or disclosure is made to a person reasonably able to prevent
or lessen the threat, including the target of the threat.
g. to report about an individual we reasonably believe to be a victim of
abuse, neglect or domestic violence to a governmental authority (including
a social service or protective services agency) authorized by law to receive
reports of abuse, neglect or domestic violence in any of the following
three circumstances:
i. where the disclosure is required by law and the disclosure complies
with and is limited to the requirements of the law;
ii. if the individual agrees to the disclosure; or
iii. to the extent that the disclosure is expressly authorized by statute
or regulation and either of the following are applicable:
A. we believe the disclosure is necessary to prevent serious
harm to the individual or other potential victims; or
B. if the individual is unable to agree because of incapacity, a
law enforcement or other public official authorized to
receive the report represents that the PPI for which
disclosure is sought is not intended to be used against the
individual and that an immediate enforcement activity that
depends upon the disclosure would be materially and
adversely affected by waiting until the individual is able to
agree to the disclosure;
when we make a permitted disclosure about a victim of abuse
neglect or domestic violence, we will promptly inform the
individual who is the victim that a disclosure has been or will be
made, except if:
(i) we, in the exercise of professional judgment, believe informing the
individual would place the individual at risk of serious harm; or
(ii) we would be informing a personal representative (such as a family
member or friend), and we reasonably believe the personal
representative is responsible for the abuse, neglect or other injury,
and that informing the personal representative would not be in the
best interests of the individual as we determine in the exercise of
our professional judgment.
h. to a law enforcement official for a law enforcement purpose (if consistent
with applicable law and standards of ethical conduct) under any of these
circumstances:
i. in response to a lawful court order, court-ordered warrant,
subpoena or summons issued by a judicial officer, or a grand jury
subpoena;
ii. if the law enforcement official makes a written request for PPI
that:
A. is signed by a supervisory official of the law enforcement
agency seeking the PPI;
B. states that the information is relevant and material to a
legitimate law enforcement investigation;
C. identifies the PPI sought;
D. is specific and limited in scope to the extent reasonably
practicable in light of the purpose for which the
information is sought; and
E. states that de-identified information could not be used to
accomplish the purpose of the disclosure.
iii. if we believe in good faith that the PPI constitutes evidence of
criminal conduct that occurred on our premises;
iv. in response to an oral request for the purpose of identifying or
locating a suspect, fugitive, material witness or missing person and
the PPI disclosed consists only of name, address, date of birth,
place of birth, social security number and distinguishing physical
characteristics; or
v. if:
A. the official is an authorized federal official seeking PPI for
the provision of protective services to the President or other
persons authorized by 18 U.S.C. 3056, or to foreign heads
of state or other persons authorized by 22 U.S.C.
2709(a)(3), or for the conduct of investigations authorized
by 18 U.S.C. 871 and 879 (threats against the President and
others); and
B. the information requested is specific and limited in scope to
the extent reasonably practicable in light of the purpose for
which the information is sought.
i. to comply with government reporting obligations for HMIS and for
oversight of compliance with HMIS requirements.
j. to third parties for the following purposes:
i. to permit other systems of care to conduct data matches (i.e., to
determine if you are also utilizing services from such other systems
of care); and
ii. to permit third party research firms and/or evaluators to perform
research and evaluation services in connection with the programs
administered by CSB and the other agencies;
provided that before PPI is disclosed under this subsection, the third party
that will receive such PPI and use it as permitted above must first execute
a Data Use & Disclosure Agreement requiring such third party to comply
with all applicable laws and regulations, including the privacy standards
and disclosure provisions contained in the Department of Housing and
Urban Development Homeless Management Information Systems; Data
and Technical Standards Final Notice (see 69 Federal Register 45888 (July
30, 2004)), which such standards and provisions are reflected herein.
2. Before we make any use or disclosure of your PPI that is not described here, we seek
your consent first.

How to Inspect and Correct PPI.
1. You may inspect and have a copy of your PPI that we maintain. We will offer to
explain any information that you may not understand.
2. We will consider a request from you for correction of inaccurate or incomplete
PPI that we maintain about you. If we agree that the information is inaccurate or
incomplete, we may delete it or we may choose to mark it as inaccurate or
incomplete and to supplement it with additional information.
3. We may deny your request for inspection or copying of PPI if:
a. the information was compiled in reasonable anticipation of litigation or
comparable proceedings;
b. the information is about another individual (other than a health care
provider or homeless provider);
c. the information was obtained under a promise of confidentiality (other
than a promise from a health care provider or homeless provider) and if
the disclosure would reveal the source of the information; or
d. disclosure of the information would be reasonably likely to endanger the
life or physical safety of any individual.
4. If we deny a request for access or correction, we will explain the reason for the
denial. We will also include, as part of the PPI that we maintain, documentation
of the request and the reason for the denial.
5. We may reject repeated or harassing requests for access to or correction of PPI.

Data Quality.
1. We collect only PPI that is relevant to the purposes for which we plan to use it. To
the extent necessary for those purposes, we seek to maintain only PPI that is
accurate, complete and timely.
2. We are developing and implementing a plan to dispose of PPI not in current use
seven years after the information was created or last changed. As an alternative to
disposal, we may choose to remove identifiers from the PPI.
3. We may keep information for a longer period if required to do so by an applicable
statute, regulation, contract or other requirement.

Complaints and Accountability.
1. We accept and consider questions or complaints about our privacy and security
policies and practices.
2. All members of our staff (including employees, volunteers, affiliates, contractors
and associates) are required to comply with this privacy policy. Each staff
member must receive and acknowledge receipt of a copy of this privacy policy.

History of Changes to this Notice
1. Version 1.0 October 1, 2007. First Draft
2. Version 2.0 August 16, 2010 Second Draft
3. Version 3.0 January 3, 2014 Third Draft
4. Version 4.0 July 1, 2015 Fourth Draft
5. Version 5.0 November 3, 2015 Fifth Draft (amended staff signed notice)
6. Version 6.0 September 1, 2018
7. Version 7.0 April 26, 2021
8. Version 8.0 October 16, 2021
9. Version 9.0 November 12, 2021