Violence Against Women Act

VAWA Confidentiality Notice

Protecting Survivor Safety, Confidentiality, and Privacy

Effective Date: March 1, 2019 In Time of Need Incorporated

In Time of Need Incorporated is committed to protecting the safety, confidentiality, and privacy of survivors of domestic violence, dating violence, sexual assault, and stalking. This notice explains the confidentiality protections that apply to individuals seeking or receiving services in connection with any HUD-funded program we operate or administer.

Our Confidentiality Commitment

Consistent with the Violence Against Women Act (VAWA) and applicable HUD program requirements, we will not enter or disclose any personally identifying information (PII) about any client into, or through, a shared database (such as a Homeless Management Information System, or HMIS) if the organization is a victim service provider, or otherwise where prohibited by law.

Personally identifying information includes, but is not limited to:

Name, address, or other identifying information about a client of domestic violence, dating violence, sexual assault, or stalking services
Address or location of any domestic violence, dating violence, sexual assault, or stalking shelter or program
Information about a client's status as a survivor, or the services a client is receiving, that could be used to identify the client

When Information May Be Shared

We will not disclose confidential information except:

With the client's informed, written, reasonably time-limited consent
When required by statute, court mandate, or other applicable law
In non-identifying, aggregate statistical form to comply with reporting requirements to HUD or other funders, with no PII included

Consent to release information can be revoked by the client at any time, in writing.

If our organization operates or refers to a confidential shelter or safe location, the address and contact information for that location will not be made public, and will not be entered into any shared data system, consistent with survivor safety requirements.

Right to Non-Discrimination

No individual will be denied services or assistance based on their refusal to consent to disclosure of their personally identifying information, except where such consent is a required condition of a specific, legally permissible program requirement that has been clearly explained to the client in advance.

Data Security

Any confidential information collected will be stored securely, with access limited to staff with a legitimate need to know, consistent with our internal HIPAA Policies and Procedures and applicable HUD data security standards.

Questions or Concerns

Dorian Williams, Privacy Officer

In Time of Need Incorporated

Address: PO Box 724494, Atlanta, GA 31139

Phone: 678-439-6005

Email: info@intimeofneed.org

This notice reflects the general VAWA confidentiality framework applicable to HUD-funded homeless assistance and victim service programs. Exact obligations vary depending on your specific HUD funding source and whether your organization is classified as a "victim service provider" under HUD's definitions. This notice should be finalized in coordination with your HUD grant agreement terms and reviewed by counsel, particularly once specific HUD funding is awarded.