What are the minimum and maximum data retention requirements for HMIS data?

Date Published: October 2017

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For records stored within HMIS, HUD requires that data be retained for seven years after the data was created or last changed, as indicated in the 2004 HMIS Data & Technical Standards:

"A covered homeless organization (CHO) must develop and implement a plan to dispose of or, in the alternative, to remove identifiers from, protected personal information (PPI) that is not in current use seven years after the PPI was created or last changed (unless a statutory, regulatory, contractual, or other requirement mandates longer retention)."

When an HMIS record has met the threshold of having no changes in the 7 years since it was first created or last updated, CoCs may either completely delete the entire record, or remove identifiers from the record. Note that the 7-year threshold is HUD’s standard for HMIS. Other obligations (federal, state, local, other contractual requirements) may necessitate retention past the 7-year threshold.

Tags: Data - Data Retention and Disposal

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