This document describes the privacy policy and practices of Pratt Area Community Council, Inc. d/b/a Impacct Brooklyn (“Impacct Brooklyn”). Our main office is at 1000 Dean St, Brooklyn, NY 11238.
This policy covers the collection, use, and maintenance of protected personal information for clients of Impacct Brooklyn.
Personally Identifiable Information/Protected Identifying Information (“Private Information”) is any personal information we maintain about a client that allows identification of an individual directly or indirectly; can be manipulated by a reasonably foreseeable method to identify a specific individual; or can be linked with other available information to identify a specific client.
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).
This policy informs our clients, our staff, and others how we process personal information. We follow the policy and practices described in this privacy notice.
We may amend our policy or practices at any time. Amendments may affect Private Information that we obtained before the effective date of the amendment.
We give a written copy of this privacy notice to any individual who asks for it.
We maintain a copy of this notice on our website at https://impacctbrooklyn.org/privacy-policy.
We collect Private Information only when appropriate to provide services or for another specific purpose of our organization or when required by law. We may collect information to provide individual case management; produce aggregate-level reports regarding use of services; track individual project-level outcomes; identify unfilled service needs and plan for the provision of new services; conduct research for consulting and/or educational purposes; and accomplish any and all other purposes deemed appropriate by the New York City Continuum of Care (“CoC”).
We only use lawful and fair means to collect Private Information.
We normally collect Private Information with the knowledge or consent of our clients. If you seek our assistance and provide us with Private Information, we assume that you consent to the collection of information described in this policy.
We share this data with the NYC Department of Social Services (DSS), Federal Homeless Policy and Reporting unit (FHPR) a/k/a the “HUD CoC unit”, and any agency appointed by the CoC to manage all Private Information we record about our clients. This agency is required to maintain the confidentiality of the data.
We post a sign at our intake desk or other location explaining why we ask for Private Information that states:
We collect personal information about homeless individuals in a computer system called a Homeless Management Information System (HMIS) for reasons that are discussed in our privacy notice. 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 have any questions or would like to see our privacy notice, our staff will provide you with a copy.
We use or disclose Private Information for activities described in this notice. We assume that you consent to the use or disclosure of your Private Information to provide or coordinate services; for payment or reimbursement purposes; to carry out administrative functions such as legal, audits, personnel, oversight, and management; to create de-identified information; when required by law; or to avert a serious threat to health or safety when disclosure is necessary to prevent harm and is made to a person reasonably able to lessen that threat.
We may disclose Private Information to report abuse, neglect, or domestic violence to a governmental authority when required by law, when the individual agrees, or when disclosure is authorized by statute to prevent serious harm or when an individual is unable to consent.
When permitted disclosures are made regarding abuse, neglect, or domestic violence, we will promptly inform the individual unless doing so would place them at risk, compromise a law enforcement purpose, or is otherwise prohibited by law.
We may disclose Private Information to law enforcement pursuant to lawful court orders, subpoenas, or written requests meeting applicable legal standards; when the information constitutes evidence of criminal conduct on our premises; or to identify or locate a suspect, fugitive, material witness, or missing person under limited circumstances.
We may disclose information to comply with government reporting obligations for HMIS oversight.
We may disclose information to third parties to permit data matching across systems of care or to permit third-party research and evaluation, provided appropriate Data Use & Disclosure Agreements are executed and all applicable laws and HUD standards are followed.
Before making any use or disclosure of Private Information not described in this notice, we will seek your consent.
You may inspect and obtain a copy of your Private Information that we maintain, and we will explain any information you do not understand.
You may request correction of inaccurate or incomplete Private Information. If we agree, we may delete, correct, or supplement the information.
We may deny requests for access or correction if the information was compiled in anticipation of litigation, concerns another individual, was obtained under a promise of confidentiality, or if disclosure would endanger life or safety.
If we deny a request, we will explain the reason and document the request and denial.
We may reject repeated or harassing requests.
We collect only Private Information relevant to our purposes and seek to maintain information that is accurate, complete, and timely.
We dispose of Private Information not in current use seven years after creation or last modification, or we may remove identifying information instead.
We may retain information longer if required by law, regulation, contract, or other obligation.
We accept and consider questions or complaints regarding our privacy practices. You may request an appointment with your Program Director to discuss concerns.
All staff members are required to comply with this privacy policy and acknowledge receipt of this notice.
If concerns are not resolved internally, you may submit a written grievance to the CoC Grievance Committee. The committee will review and issue a determination. More information is available at www.nychomeless.com. You may also contact the NYC Commission on Human Rights.
