The following information about clients’ right to privacy must be posted in every clinical staff member’s office and given to each client when they are admitted to an ABRI program:
ABRI collects personal information from clients, including but not limited to: name, social security number, date of birth, demographic information, employment status, income information, diagnoses, and medical history.
This information is referred to as “Protected Personal Information (PPI).”* This information is stored in clients’ charts, electronically in internal databases, and is reported to funding agencies and through Connecticut’s Homeless Management Information System (HMIS). ABRI may be required to collect some personal information by law or by organizations that give us money to operate this program. The purpose of collecting this information is to assist ABRI staff in providing services to clients and referring them to appropriate community resources. We also use this information to improve services for homeless persons and to better understand the needs of the populations we serve.
Clients will be required to sign a Release of Information (ROI) with a primary treatment provider prior to admission to any ABRI residential transitional housing program (Homes for the Brave, Female Soldiers: Forgotten Heroes, and HFTB West Haven). Residents are free to choose not to sign the release of information to allow ABRI staff to communicate with their primary treatment provider, but if they do so, ABRI staff may work to place them in another program.
ABRI shall not permit the disclosure of the identity, diagnosis, prognosis, or treatment of any such client that would constitute a violation of Federal or State Statutes concerning confidentiality of alcohol or substance use treatment participants’ records or mental health treatment participants’ records and any regulations pursuant thereto, or as they may be amended from time to time. ABRI shall adopt regulations to protect the confidentiality of information in accordance with Federal and State law.
ABRI may make available to authorized persons information from clients’ records for the purpose of conducting scientific research, arrangement audits, financial audits, and program evaluations, provided such information shall not be utilized in a manner that discloses clients’ names or other identifying information.
ABRI may also disclose PPI in response to a lawful court order, court‐ordered warrant, subpoena or summons issued by a judicial officer, or a grand jury subpoena.
ABRI will not disclose any information over the telephone to any agency or person, private or public without written authorization from a client.
ABRI will disclose PPI to a continuing treatment facility, service agency and law enforcement agencies, provided the client has signed a release of information specific to these agencies.
ABRI may disclose PPI if ABRI staff believes the disclosure is necessary to prevent or lessen a serious and imminent threat to the health of safety of an individual or of the public. In this case, disclosure can be made to a person reasonably able to prevent or lessen the threat.
Clients have a right to refuse signing a Release of Information or to revoke an ROI. However, refusal that prevents sharing of information critical to clients’ participation in a program may result in discharge from that program and a referral to another provider.
Clients have a right to view the information stored in their chart with the assistance of ABRI staff. To request access to this information, clients must file a request with the program’s CEO, CCO, or COO.
ABRI also shares PPI externally through the Homeless Management Information System (HMIS). Clients’ participation in this program is voluntary. Choosing not to participate will in no way affect the services offered. Clients can choose to have any information previously shared deleted from the system at any time. Clients can revoke any written consent at any time. For the purpose of reporting requirements and advocacy, information will be used without revealing names or other PPI.
If a client needs assistance reading and understanding his/her privacy rights, ABRI will provide reasonable accommodation to assist him/her.
If a client feels his privacy rights, as outlined above, have been violated, he has a right to file a complaint with the CEO of ABRI, who will then investigate the client’s allegations and provide the client with a the results of any inquiry.
*Protected Personal Information (PPI) is defined as any information maintained by or for ABRI about a living resident or individual that (1) identifies, either directly or indirectly, a specific individual; (2) can be manipulated by a reasonably foreseeable method to identify a specific individual; or (3) can be linked with other available information to identify a specific individual. (“Homeless Management Information Systems (HMIS); Data and Technical Standards Final Notice.” Federal Register 69: 146 (July 30, 2004) p. 45928.)