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<br />16-VI.C. RECORDS MANAGEMENT <br />The PHA will maintain applicant and participant files and information in accordance with the <br />regulatory requirements described below. <br />SAHA Policy <br /> <br />All applicant and participant information will be kept in a secure location and access will <br />be limited to authorized staff. <br />Staff will not discuss personal family information unless there is a business reason to do <br />so. Inappropriate discussion of family information or improper disclosure of family <br />information by staff will result in disciplinary action. <br />Privacy Act Requirements \[24 CFR 5.212 and Form-9886\] <br />The collection, maintenance, use, and dissemination of social security numbers (SSN), employer <br />identification numbers (EIN), any information derived from these numbers, and income <br />information of applicants and participants must be conducted, to the extent applicable, in <br />compliance with the Privacy Act of 1974, and all other provisions of Federal, State, and local <br />law. <br />Applicants and participants, including all adults in the household, are required to sign a consent <br />form, HUD-9886, Authorization for Release of Information. This form incorporates the Federal <br />Privacy Act Statement and describes how the information collected using the form may be used, <br />and under what conditions HUD or SAHA may release the information collected. <br />Upfront Income Verification (UIV) Records <br />PHAs Enterprise Income Verification (EIV) System are <br />required to adopt and follow specific security procedures to ensure that all EIV data is protected <br />in accordance with Federal laws, regardless of the media on which the data is recorded (e.g. <br />electronic, paper). These requirements are contained in the HUD issued document, Enterprise <br />Income Verification (EIV) System, Security Procedures for Upfront Income Verification data. <br />SAHA Policy <br /> <br />procedures required by HUD. <br />Criminal Records <br />The PHA may only disclose the criminal conviction records which the PHA receives from a law <br />enforcement agency to officers or employees of the PHA, or to authorized representatives of the <br />PHA who have a job-related need to have access to the information \[24 CFR 5.903(e)\]. <br />The PHA will establish and implement a system of records management that ensures that any <br />criminal record received by the PHA from a law enforcement agency is maintained <br />confidentially, not misused or improperly disseminated, and destroyed, once the purpose for <br />which the record was requested has been accomplished, including expiration of the period for <br />filing a challenge to the PHA action without institution of a challenge or final disposition of any <br />such litigation \[24 CFR 5.903(g)\]. <br />04/01/14 <br />Page 16-28 <br /> <br />