Ex. 2 HA ANNLPLAN, EIV - Laserfiche WebLink

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Purpose The purpose of this document is to set forth SAHA policies and procedures governing the use of the EIV system and associated documents. The practices, controls and safeguards described in this document have been established to ensure compliance with the Federal laws regarding the protection of this information. Privacy Act The data provided via the EIV system will be protected to ensure that it is only used for official purposes and not disclosed in any way that would violate the privacy of the individuals represented in the system data. Privacy of data and data security for computer systems are covered by a variety of Federal laws and regulations. The Privacy Act of 1974 as amended, 5 U.S.C. 552 (a) is one such regulation. The full text of the Privacy Act can be accessed at http://www.usdoj.gov/fois/privstat.htm. Examples of Privacy Act Violations SAHA will not rely entirely upon staff to read and understand the Privacy Act. To ensure that staff has a complete understanding of the Privacy Act and how seemly harmless actions may be violations, examples of a Privacy Act violations will be provided annually during security awareness training. The following example of a security violation was explained during the HUD Satellite Broadcast introducing the EIV system: EIV data can only be viewed by authorized PHA staff and the individual adult who the information pertains to. This means that EIV data for an adult household member in a resident family cannot be shared with another adult household member of the resident family (even the head of household) unless that family member is present or signs a waiver authorizing the other family member to view their EIV information. The Privacy Act protects the privacy of each adult family member from any unauthorized person viewing their EIV data, even another family member. However, EIV data for minor children may be viewed by the Head of Household. Security Officer(s) An EIV Security Officer(s), appointed by the Housing & Neighborhood Development Manager technical, physical, administrative is responsible for ensuring that proper and safeguards are in place and enforced. The duties of the security officer are as follows: Conducts quarterly reviews of all User IDs issued to determine if the users still have a valid need to access the EIV data and modifies or revokes access rights as appropriate At the request of the Housing & Neighborhood Development Manager or her designee, updates the EIV Security Policy and Procedures Coordinates or conducts file audits, at least annually, to assure that a copy of Form HUD- 9886 has been signed by each member of the household age 18 years or older and is in the household file 2 Exhibit 2