We recognize that you may be concerned about our use and disclosure of your personal information. Your privacy is very important to us, and the following will inform you of the information that we, National Veterans Homeless Support (NVHS), may collect from you, and how it is used. By using our website, www.nvhs.org, conducting business either as a donor or vendor, or by contacting or requesting services with us as a client in any other manner, you are accepting the practices described in this policy.
You may request a written version of this policy at any time by mail at:
Attn: Privacy Notice
1436 King Street
Cocoa, Florida 32922.
Information Collection and Methods
First, information is collected through normal accounting transactions with donors (people and businesses that contribute to us) and vendors (people and businesses we pay). That information comes from checks we receive, written approval to process a credit card or ACH payment, online donations made to us through PayPal, and invoices we have to pay. This includes, but is not limited to:
- Phone Number
- Credit/Debit Card/Bank Account Numbers
Second, information is collected from visitors to our website, www.nvhs.org, in the following manors:
- Google Analytics
- We have embedded Google Analytics into our website’s programing. Google Analytics is a website traffic analysis application that provides real-time statistics and analysis of user interaction with the website. Google analytics enables us to analyze our site visitors, with the objective of interpreting and optimizing our website’s performance. Google analytics can track all forms of digital media and referring upstream web destinations, banner and contextual advertisements, e-mail and integrates with other Google products.
- Constant Contact
- Constant contact is an online email marketing service that we subscribe to. When you input an email address on our contact us page, your email goes directly to us, and also is recorded on constant contact.
- PayPal is an industry leading secure online payment processing software. On our donation page there is an option to donate online, and that option takes you to PayPal to complete the transaction. When the transaction is complete, your name, email, and address could be sent to us if you choose to allow that. We do not get information related to your payment method or account numbers.
Third, we collect sensitive information from clients requesting or receiving services. This information comes from intake forms, both paper and online, that clients complete when receiving or requesting services from us. Information collected may include:
- Demographic Information (i.e. Race, Gender, Marital Status, Veteran Status)
- Social Security Number
- Numbers from government identification cards (i.e. Drivers License)
- Income Sources
- Email address
- Phone Numbers
- Sources of Income
- Limited Medical Information (i.e. are you disabled?, do you have a substance abuse issue?)
- Bank Account/Mortgage/Rent/Utility Account Numbers
Collected Information Use
Information collected from donors and vendors are used to:
- Receive payments
- Issue payments
- Issue receipts
- Understand donor trends to improve marketing efforts
- Communicate during marketing or informational efforts with donors and vendors via mail and digital means
Information collected during website visits are used to:
- Understand site visitor habits when they are on the site to improve the visitors experience
- Understand what brought a visitor to the site for marketing analysis
- Build contact lists for email marketing efforts (i.e. Constant Contact and PayPal)
Information collected from clients requesting services are strictly used to:
- Build individual case management plans to address the client’s individual needs
- Perform background checks using open source methods (i.e. clerk of courts records)
- Communicate with Department of Veteran Affairs (VA) to verify veteran status and assist with obtaining VA benefits
- Program tracking and effectiveness measurements using aggregate data for reporting to funders and internal personnel
Information Storage and Protection
Information collected from donors and vendors are stored:
- In our accounting system QuickBooks, with the company file being stored on an Intuit approved encrypted and secure cloud server hosted by SageNext. Access to the company file is a two step authentication process:
- First, accounting personnel access the SageNext Server with a username and password
- Second, they access the company file with a separate username and password.
- Additional information can be found about this service at the following link. https://www.thesagenext.com/quickbooks-hosting
- Additionally, paper records are maintained per IRS regulations in a locked accounting office inside locked filing cabinets, with access limited only to personnel that have a role in the actual bookkeeping function of our accounting.
Information collected from website visitors is limited to donation processing through PayPal as described earlier or requests to be added to our email marketing lists through Constant Contact as described earlier. Google Analytics only provides aggregate information, and nothing that we are able to physically use to identify a particular person or business.
Information collected from clients are stored:
- Paper records are stored in locked filing cabinets in case management offices, with access restricted to only personnel that have been trained on data protection protocols AND that have an active role in the case management process.
- All client information is recorded in a Department of Housing and Urban Development information system called the Homeless Management Information System (HMIS).
- We are a member of the Brevard Housing Coalition/Housing Management Information System (BHC/HMIS). A HMIS is a local information technology system used to collect client-level data and data on the provision of housing and services to homeless individuals and families and persons at risk of homelessness. Each Continuum of Care (CoC) is responsible for selecting an HMIS software solution that complies with The U.S. Department of Housing and Urban Development’s (HUD) data collection, management, and reporting standards. BHC is the CoC of Brevard County, Florida.
- HUD and the federal partners, along with other planners and policymakers use aggregate HMIS data to better inform homeless policy and decision making at the federal, state, and local levels.
- The HEARTH Act, enacted into law on May 20, 2009, requires that all communities have an HMIS with the capacity to collect unduplicated counts of individuals and families experiencing homelessness. Through their HMIS, a community should be able to collect information from projects serving homeless families and individuals to use as part of their needs analyses and to establish funding priorities. The Act also codifies into law certain data collection requirements integral to HMIS. With enactment of the HEARTH Act, HMIS participation became a statutory requirement for recipients and sub recipients of the CoC Program and Emergency Solutions Grant (ESG) funds.
- Only personnel that have been trained by the Database Lead Agency (211Brevard) on how to use the software, requirements needed to legally log information into the software, and data/client protection protocols are given usernames and passwords to the system. Only case management and program management personnel are submitted for training to 211Brevard.
- Information and contact with 211Brevard with respect to HMIS can be found at http://www.211brevard.org/hmis/homeless-management-information-system-hmis/
Sharing of Information:
Except as required by law, in particular under rules and regulations imposed by us through the IRS, we do not share any collected donor, vendor, or website visitor information with any 3rd party agencies. If this information is requested (i.e. by funders), only after the explicit written consent of the individual or business who the information belongs will that information be shared.
For clients requesting and receiving services, when an intake is recorded on you during an encounter, regardless if paper or digital, there are two forms with release of information approval that will likely be asked of you:
- First is the BHC/HMIS Release of Information
- The second, if you’re a veteran, is a VA Release of Information
Your approval is given when you sign these individual forms, either digitally or physically. The BHC/HMIS Release of Information allows us to enter you into the HMIS. Without this, we are prohibited by our user agreement with the lead agency to enter your information into the HMIS system. The VA Release of Information allows the VA to talk with us about your veteran record; without this they will not release any information about your service. The VA release is straightforward, the BHC/HMIS release is comprehensive and is defined below:
BHC/HMIS Release of Information:
As stated earlier, when you receive or request program services from this organization, information about your household is collected and entered into the BHC/HMIS. By requesting or receiving services from this organization, you understand and acknowledge that:
- NVHS is a member of the HUD/HMIS
- You consent to and authorize the collection of data and information maintained by NVHS to HUD/HMIS and affiliated agencies, provided such organizations are a party to the HUD/HMIS organization agreement under which the organization has specifically agreed to share information.
- The data, information and records gathered and prepared by NVHS and HUD/HMIS will be included in the database and may be utilized by HUD/HMIS and affiliated agencies to
- Provide individual case management
- Produce reports regarding utilization of services
- Track individuals program outcomes
- Provide accountability for individuals and entities that provide funds for use in providing services in Brevard County
- Identify unfilled service needs and plan for the provision of new services
- Allocate resources among agencies engaged in the provision of services in Brevard County
- Be used for all other uses to be deemed appropriate by HUD/HMIS
- Your data and information may be used in aggregate data along with information of other individuals served by NVHS for the purposes described above.
- Data, information, and records pertaining to the services provided to you by NVHS will only be disclosed to organizations, individuals, and entities other than HUD/HMIS only with your written authorization
- That the data pertaining to the services provided to you may include medical and health information and other information the privacy of which may be protected by federal or Florida State laws and expressly consent to the release of such information in accordance with these protections.
By signing the consent for release of information, you are consenting to the information above.
How You Can Review and Update Records and/or Opt Out
All individuals that have information collected and stored by us have the following rights
- Inspect, copy, and request amendment of all records maintained by us and to receive a paper copy of this policy
- File a grievance if you believe your privacy rights have been violated to the organization’s privacy complaints manager, Jennifer Taylor, Programs Director of NVHS, by mail at the address listed earlier “Attn: Jennifer Taylor”.
- Unsubscribe to email marketing by clicking unsubscribe at the bottom of the email which removes you permanently from Constant Contact’s database
- If you are a client who has been input into HMIS, you have a right to opt out of having your data, information and records disclosed to HUD/HMIS and affiliated agencies by providing notice to us, and that you are entitled to services regardless of your decision. Additionally, you may revoke this consent at any time by providing written notice to NVHS at the address listed earlier “Attn: Jennifer Taylor”.