3 - PUBLIC HEARING ANNUAL ACTION PLAN

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Administrative Plan 4/1/2016 Page 16-29 If an informal hearing to establish a family’s citizenship status is held, longer retention requirements apply for some types of documents. For specific requirements, see Section 16- III.D., Retention of Documents. 16-VI.C. RECORDS MANAGEMENT PHAs must maintain applicant and participant files and information in accordance with the regulatory requirements described below. SAHA Policy All applicant and participant information will be kept in a secure location and access will be limited to authorized staff. Staff will not discuss personal family information unless there is a business reason to do so. Inappropriate discussion of family information or improper disclosure of family information by staff will result in disciplinary action. Privacy Act Requirements [24 CFR 5.212 and Form-9886] The collection, maintenance, use, and dissemination of social security numbers (SSN), employer identification numbers (EIN), any information derived from these numbers, and income information of applicants and participants must be conducted, to the extent applicable, in compliance with the Privacy Act of 1974, and all other provisions of Federal, State, and local law. Applicants and participants, including all adults in the household, are required to sign a consent form, HUD-9886, Authorization for Release of Information. This form incorporates the Federal Privacy Act Statement and describes how the information collected using the form may be used, and under what conditions HUD or SAHA may release the information collected. Upfront Income Verification (UIV) Records PHAs that access UIV data through HUD’s Enterprise Income Verification (EIV) system are required to adopt and follow specific security procedures to ensure that all EIV data is protected in accordance with federal laws, regardless of the media on which the data is recorded (e.g. electronic, paper). These requirements are contained in the HUD-issued document, Enterprise Income Verification (EIV) System, Security Procedures for Upfront Income Verification data. SAHA Policy Prior to utilizing HUD’s EIV system, SAHA has adopted and implemented EIV security procedures required by HUD. Criminal Records SAHA may only disclose the criminal conviction records which SAHA receives from a law enforcement agency to officers or employees of SAHA, or to authorized representatives of SAHA who have a job-related need to have access to the information [24 CFR 5.903(e)]. 3-373