- 4. EPIC Releases Fact Sheet on Homeless Tracking Systems
(First posted August 21, 2003)
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- EPIC has published a fact sheet on Homeless Management
Information Systems (HMIS) (see EPIC Alert 10.16). HMIS are database systems
that the Department of Housing and Urban Development (HUD) is requiring
shelters to maintain. Under the proposed guidelines, federally funded
shelters and other care organizations will be required to collect unique
identifiers, as well as physical and mental health information on each
benefits recipient. There are specific provisions that require the collection
of HIV and pregnancy status.
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- Homeless tracking presents a number of privacy and civil
liberties concerns. First, HMIS lays the infrastructure for a nationwide
system of homeless tracking. The proposed guidelines mandate consistency
in data collection, and the ability to export all data in the system to
a common format. This raises substantial risks for those living with HIV,
physical or mental health disabilities, or others who have conditions that
potentially subject them to stigma or discrimination.
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- Second, government access to the database is nearly unlimited.
Under the proposed guidelines, system users can disclose information from
the database to Secret Service or agents of a national security agency
without any showing of an emergency, a court order, or even a risk of attack.
Law enforcement access is more limited, but nevertheless, HUD is not requiring
police to obtain warrants or court orders before releasing HMIS data.
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- Third, HMIS places victims of domestic violence at heightened
risk of harm. Many victims flee violent partners by staying in shelters,
and HMIS may provide opportunities for malicious actors to locate their
victims.
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- The EPIC fact sheet argues that HUD should seek less
invasive alternatives to evaluate the effectiveness of benefits and support
for the poor. For instance, HUD could perform a census on a specific day
to obtain an unduplicated count of the homeless staying in particular shelters.
Such a census would not require the collection of personal identifiers
or tracking over time, and would be less expensive.
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- The public can comment on HMIS until September 22, 2003
by mail to HUD. No provision for electronic or fax submissions has been
arranged. Comments should be addressed to:
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- Michael Roanhouse Re: Doc. No. FR 4848-N-01 / HMIS Data
Office of Special Needs Assistance Programs Office of the Assistant Secretary
for Community Planning and Development Room 7262 HUD 451 7th St. SW Washington,
DC 20410
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- EPIC's Homeless Tracking Fact Sheet is available at:
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- http://www.epic.org/privacy/poverty/hmisfactsheet.pdf
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- HUD's proposed HMIS Guidelines are available at:
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- http://www.epic.org/privacy/poverty/hmis.pdf
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- More information about privacy and the homeless is available
at:
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- http://www.epic.org/privacy/poverty/
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- http://www.epic.org/alert/EPIC_Alert_10.17.html
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