Date Published: October 2017
There should be a legal review of state, local, and other federal privacy laws to determine if there are more restrictive or limiting requirements for entering data into HMIS. If so, these laws will need to be considered when developing your local HMIS data collection and sharing policies. In general, HUD does not require client consent to simply enter a client's information into HMIS.
If a client's information is to be shared from one participating service provider to another participating service provider via HMIS, then consent to share which data, and with whom, should be obtained from the client. Therefore, if an HMIS is configured in such a manner that information entered into HMIS is automatically shared among participating service providers, then client consent should be obtained prior to entering the information into HMIS.
If a client declines to provide consent for sharing information, the information may still be entered into HMIS, however, administrative steps should be taken to prevent the information from being automatically shared among participating service providers upon entry.