Loading...
HomeMy WebLinkAbout03 - HA ANNLPLANREQUEST FOR HOUSING AUTHORITY ACTON MEETING DATE: RECORDING SECRETARY USE ONLY: APRIL 4, 20'f'I TITLE HOUSING AUTHORITY ANNUAL PLAN APPROVED ^ As Recommended ^ As Amended CONTINUED TO IN E IM ECUTIVE ©IRECTOR RECOMMENDED ACTION Adopt a resolution to approve and submit the Annual Plan to the U. S. Department of Housing and Urban Development. COMMUNITY REDEVELOPMENT AND HOUSING COMMISSION RECOMMENDATION At its Regular Meeting of March 15, 2011, by a vote of 6:0, the Community Redevelopment and Housing Commission recommended that-the Housing Authority adopt a resolution to approve and submi# the Annual Plan to the U. S. Department of Housing and Urban Development. DISCUSSION The U. S. Departmen# of Housing and Urban Development. (HUD) requires housing authorities that administer a Housing Choice Voucher (HCV) Rental Assistance program to have an Annual Plan. The purpose of the Housing Authority's Annual Plan is to advise HUD, program participants and members of the public of its mission and strategy to serve the needs of very low-income families. The Annual Plan (Exhibit 1) provides detailed information about the current operations of the Housing Authority, including programs, participants, services far the upcoming year, and any operational or tenant concerns. The Authority is required to review its existing operations and needs an a yearly basis with input from a Tenant Advisory Committee comprised of HCV participants. The Annual Plan includes the Authority's new Enterprise Income Verification {EIV) Security Policies and Procedure document which is required by HUD (Exhibit 2). The Tenant Advisory Committee met on February 1, 2011, #o review the Plan for fiscal year 2011 2012. There were 31 committee members in attendance. As required, aEl comments from the February 1 committee meeting are incorporated into the Annual Plan. 3 Housing Authority Annual Plan April 4, 2011 Page 2 HUD regulations require a 45-day comment period. 4n January 28, 2011, notifcation was published that the draft plan was available for review. The public comment period ended March 15, 2011. All comments received wilt be included in the final documents submitted to HUD. FISCAL IMPACT There is no fiscal impact associated with this action. l~ r ,~ ;, Shelly La ry-Bayle Housing anager Community Development Agency NTE/SLB/LFlsr Exhibits: 1. Annual Plan 2. EIV Security Policies and Procedures 3. Resolution oKF .~ ~T~ BHA SWYear and IT,~, Department aiIF7[nusing and Urban fl1Vi'B No. 2577-o22G Development Expires 4I3i1/24I1 .A.DDIl.a~ ~~an t3flFce nfPublit and Indian .Housin 1,0 PISA Information PHA Name; -Housing Authoriky of the City of Santa Ana PHA Code: _CA013 PHA ~: ^ Small X High Performing (~ Standard 7{ IICV (Section &) PHA Fiscal Year Beginning: (MM/YYYY): _07101/2011 2.E1 Inventory (based an ACC units at Time o€FY beginning in 1.0 above) Number of PH units: biumber of HCV units: 2658 3.It SuI)mtssion'I'ype 5-Year and Annua[ Pfan K>] Annual Flan Onty ^ 5-Year Plan only `I'© PISA Consortia ^ PHA Consortia: (Check box ifsubmitting a joint Plan and complete table below.) Participating PHAs PHA Program{s) Included in the Programs Nat in the No. of Units in Eaclt Pro am Code Consortia Consortia PH HCV PHA 1: PHA 2: PHA 3: 5.t3 5-Year Plan, Comptete items 5.1 and S.2 nnly at 5-Year Plan update. S.I Mission. State the PIIA's Mission for serving the needs oflow-income, very law-income, and extremely taw income families in the PHA's jurisdiction for the next five years: To promote adequate and aflFordable housing, economic opportunity, and a suitable living environment free from discrimination. 5.2 Goals and Objectives. Identify the PHA's quantifiable goals and objectives that will enable the PHA to serve the needs of ]ow-income and very low-income, and extremely low-income (amities for the nexk five years. Include a report on the progress the PISA has made in meeting the goals and objectives described in the previous 5-~5'ear Pfan. Goal {E1: Expand the supply of affordatale hnusing by applying for additional rental vouchers when avaitabte. Craal #2: Improve the quality ofassisted housing by improving voucher management, increasing cuskomer sattsfhction, and improving speciftc managemenk function. • 2005-2009 Progress: SAHA maintained high-performer status for four of the rive years, Customer service ratings continue to be high, rating "good" or "excellent" in 86% of responses in November 2009 survey. The automated rent reasonahteness program was implemented as scheduled. Csnal # 3: Increase assisted housing choices by providing portability counseling to ]00°10 of participants, conducting outreach to potential participating property owners, and implementing voucher homeownership program. • 2t}05-2009 Progress: l00%of participants received portability counseling. SAHA maintained epmmunications with Grange County Apartment (3wners Association to recruit new participating owners. Voucher homeownership program has been developed, however funding gaps still exist between voucher funding and local for-sale housing market. Goal #4: Provide an improved living environment through efforts w link participants with local neighborhood associations. • 2005-2009 Progress: Information on total associations provided via tenant newsletters and during voucher issuance briefmgs_ Goal #5: Promote self sufficiency by increasing employment among participants, linking to supportive services to increase independence for the elderly andlor disab[ed, and increase participation in ttre Pamily Self Sufficiency (FSS) program. • 2005-2001 Progress: SAI-IA continued providing referrals to the Sartta Ana V~1l0/1t/K Center for jab training and placement services, provided information and linkages to the County's Council on Aging (elderly services) and the l7ayte Melntash Center (disabled services), and conducted recruitment for the TSS program at initial voucher issuance, at annual reexaminations, and through tenant newsletters. Goal #6: Ensure equal opportrrnrty and affirmaiivcly further fair housing through caardinatian with the Orange County Fair Housing Council, the prepararion of the Analysis of Impediments to fair housing choice, and continued training on fair housing practices for staff, owners, and participants. • 2005-2009 Progress: Fair Housing programs and resources era included in ail issuance briefings. Reasonable Accommodation tracking logs were implemented. Communication was maintained with the County's Fair Housing Council, ensuring proper referrals for anyone alleging discrimination, whether an HCV participant or member of the public. Page 1 of 3 form RI3#7-50t)75 (412008) Exhibit 1 PHA Plan Update {a) Identify all PISA Plan elements that have heart t~vised by the PHA since i€s last Annual Plan submission: Eligibility and Selection from Wait List- na changes. Financial Resources-Received funding for additional ] OQ vouchers (NED) Rent Determination - no changes. Operations and Management-Approved EiV Security Policy and Procedures G.0 Grievance Procedures -no changes. Designated Elderly and Disabled Housing -- NJA Community Service -NIA Safety and Crime Prevention -NIA Pets -NIA Civil Rights Certiftcation- No change -full compliance. Fiscal'YearAudit-Noehange,nofindings. Asset Management-NIA Violence Against Women Aet- no changes. (b) Identify the specilic loco#ion(s) where the public may obtain copies of the 5-Year and Annual PISA P€an. For a complete list o€PHA Plan elements, see Section 6.0 ofthe instructions. Main PHA Busi:rase Office: Santa Ana City Hall, 20 Civic Center Plaza, 2nB Ploor, Santa Ana, CA 92702 fTope @I, iYlixed Tinance Modernization or Development, Ilemeiition and/or Dlsposifion, Conversion ofPublle Housing, Homeownership Programs, and Project-based Vouchers. Include stat¢menis related to these programs as appircabla. ,10 Housing Choice Voucher (I-TCV) homeownership (applying HAP and TTP to mortgage instead of rant) is passible, but funding gag exists between available resoueces and local far-sale housing market, SAHA will evaluate annually the number of HCV that can he made oval€abie for project-based assistance within its jurisdiction ofthe City ofSanta Ana. This will assist with the jurisdiction's affordable housing needs supported by the SAHA Adminisirativc Pian and the Consolidated Plan for the City of Santa Ana. 8.0 Capital Impresvements. Please complete Parts S.l through 8.3, as applicable. N ! A 8 i Capital fund Program Annual StatementlPerformanceond Evaluation itepvrt. As part ofthe PI-IA 5-Year and Annual Plan, annually ° tmd Program Annual Statement/Petfarntunce arrd Evaluation Report, farm MUD-50075,1, for each current and complete and submit the Capital ! open CFI' grant and CFFP financing. $ 2 Capital Fund Program ]live-Year Action Plan. As part of the submission of the Annual Plan, PHAs must complete and submit the Capital Fund Program Five-fear Action Plan, form HUD-50075.2, and subsequent atrnual updates (on a roiling basis, e.g., drop current year, and add latest year fior a five year period), large capital items must be included in the Five-Year Action Plan. 8~ Capital Fvnd k'~nancing Program {CFFP). © Check if the PHA proposes to use any portion of its Capital Fund Program (CFP}IReplacement Flousing Factor (RHF) to repay debt incurred to finance capital itnprovements_ Housing Needs. Based on information provided by the applicable Consolidated Plan, information provided by HUD, and other generally available data, make a reasonable efFart to identify the housing needs of the low-income, very low-income, and extremely low-income families who reside in the jurisdiction served by the PFIA, including elderly families, families with disabilities, and households of various races and ethnic groups, and other families who are on the public housing and Section $ tenant-based assistance waiting lists. The identifcation of housing needs must address p,8 issues of affordability, supply, quality, accessibility, size of units, and location. The recently-completed Housing Element ofthe General Plan has identified a shortfall between supply and demand of 12,000 large rontai units (3+ bedrooms. Whereas the majority of HCV participants {54%) and applicants {Sl °1°) only require i-bedroom units, 45% of the overall renting population in Santa Ana have honseholds of 5 or more persons. The mast recent data on housing burden {Census 2000 data} show moderate (30~°f° of income to housing casts) and severe overpayment {50~-% of income to housing casts) levels at; Moderate Cncome 3% moderate Q% severe, I.ow Income 23%ond 2°10, Very Low Income bl% and I2%, and Extremely Low Income 82% and 60°!°. 50% of elderly renters are estimated to overpay for housing. Of the 4204 on the HCV waiting list, 35% are disabled, 2l °/a are elderly, 51°fa of households have only i or 2 members, and 59% are headed by a female head of household. Strategy far Addressing Housing Needs. Provide a brief descrip#ion of the PHA's strategy far addressing the housing needs of families in the jurisdiction and on the waiting list in the upcoming year. Note: Small, Seetian 8 only, and High Performing PHAs complete only for Annual 9.1. Plan submission with tl-e 5-Year Pian. SAHA will continue to maximize voucher utilization (average lease rate for CY 2010 was 106°1°), apply for now vouchers when they are made available, and continue to investigate fraudulent activity to maintain the program's integrity. Given the stow nataral turnover of vouchers, fire focus wiEl be on issuing a voucher within 30 days of it becoming available to the next applicant on the waiting list. Additional Information. Describe the following, as well as any additional information HUD has requested. 10.8 {a} Progress in Meeting Mission and Goals. Provide a brief statement of the PHA's progress in meeting the mission and goals described in the 5- YearPlan. See Section 5.2 above. {b) Significant Amendment and Substantial Deviation/Modiftcatien. Provide the PHA's defin'stian of "significant amendment" and `"substantial deviatiou/modifieation" Any change via regulation, interpretation, or other guidance that rneasurably changes the administration ofthe i-1GV Program. Also, any proposed change in the scope of the HCV program {e.g. project-based, homeownership). Page 2 of 3 forth HiJD-50D75 (4/20t)8) 1i.0 Required Submission for HTJ!? Field (3fiiee Review, In addition to the PHA Plan template {HI.JI~-50075), PHRs must submit the following dveuments. I#ems (a) through {g) may 6e submitted wish signature by mail or alectronicatly with scanned signatures, but e[ectconic submission is encouraged. Items (lr) through (i) must 6e attached electronieally with the PICA Plen. Dote: Faxed copies ofthese dacnments witl not be accepted by the Field Offie~ (a) Form FIUI?-SOD77, PFIA Cert~cafions of Compliance with the PHA Plans and Related Regulafians {which irteludes aI€ certificat€ons relating t4 Civil Rights) (b) Form FillD-50670, Ceriifrcatianfor a Drug-Free Worl~7ace (PHAs receiving CFP grants only} {c) Form I-IUD-SOD7I, Certification of Paymenis fa Injluance Federal Trarrsactians (PI-fAs recaivi€~g CFP grants only) (dj Farm SF-LLL, Dlsclasurs of Lobbying Activities (PHAs receiving CFP grants an€y) (e) Form 5F-LLL-A, Disclosure of Lobbying Activities Coniitruatiorr Sheet (PHAs receiving CFP grants on€y) {f) Resident Advisory Board (RA$) comments. Comments received from the RAI3 mnst be submitted by the PHA as an attachment to the PI-iA Plan. PHAs must also include a narrative describing their analysis of the recamntendativns and the decisions made on these recommendations. (g) Challenged Elements {h} Form IiLID-5Qp75, I, Capital Fund Program Annual StafemanllPerformance and Evaluation Report (PHAs receiving CFP grants only) {i) Form HL1I?-50075.2, Capital Fuxd Program Five-Year Aclian Plan (PHAs receiving CFI' grants on€y} Znfonmation regarding SAHA's efforts for victims of domestic violence to obtain and maintain housing, and prevent domestic violence in assisted families, in accordance with the Violence Against IVomen Act (VA~iVA} of 2005; Applicants v~tho are victims of domestic violence are given a priority on SAHA°s wait list, • SARA coordinates closely with the County of Orange's Domestic Violence Office for referrals and to ensur$ applicants ~vho are victims of domestic violence obtain housing assistance as quickly as possible. • lnfarmation on details of VAWA as pertaining to owner/tenant relations an:d evictions is given to all applicants and program participants and mailed to all participating owners. • SAHA's administrative plan details restrictions an terminating assistance for victims of domestic violence, as well as guidelines on terminating assistance far perpetrators of domestic violence. "l'he Housing Authority developed an EIV Sec~#rity Policy and Procedures Document to be approved by resolution in Apri1201 1. Page 3 of3 form HUT?-5Q©'~5 (R12t)b8} Housing Authority of the City of Santa Ana HOUSING CHOICE VOUCHER PROGRAM Enter rise Income Verification EIV Security Policy and Procedures The Enterprise Income Verification System (EIV} The ETV system is intended to provide a single source ofincome-related data to PHAs for use in verifying the income reported by tenants in the various assisted housing programs. The office of Public and Indian Housing (PIH} is responsible for administering and maintaining the EIV system. Types of Upfront Verification of Income Provided by EIV The EIV system compares the tenant income data obtained from various sources including: • Tenant-supplied income data captured on Form HUD-50058 and maintained in the PIC databases; • U.S. Department of Health and Human Services, National Directory of New Hires (NDNH) data. NDNH becomes the single source for wage, unemployment insurance benefit information, and the new hire (employment) information; • Social Security and Supplemental Security income froxn the Social Security Administration (informarion formerly accessed through TASS}; and • User profile information from the PIC database. What EIV Tenant Data Is Used For EIV data is the first level in the hierarchy of upfront income verification. The EIV data maybe used in the following way: • To verify an applicantJparticipant's eligibility for participation in a HUD rental assistance program and to determine the level of assistance the applicant/participant is entitled to receive. • No adverse action can be taken against an applicant/participant until the PHA has independently verified the EIV (according to the PHA's income verification policy (see note below) and the applicant/participant has been granted an opportunity to contest any adverse findings through the established grievance, hearing, or other legal procedures. Applicability The procedures in this document apply to all Housing Authority of the City of Santa Ana (SARA} staff that access EIV data. Exhibit 2 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, S U.S.C. SS2 (a) is one such regulation. The fill text of the Privacy Act can be accessed at http_//www.usdoj.~ov/fois/privstat.l~.tm. 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 maybe 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 ~ 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 E1V Security Officer(s), appointed by the Housing & Neighborhood Development Manager is responsible for ensuring that proper technical, physical, and adaininistrative safeguards are in place and enforced. The duties of the security officer are as follows: • Conducts quarterly reviews of all User IDs issued to detem~ine if the users still have a valid need to access the EN data and modif es 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 a~znually, to assure that a copy of Foam HUD- 9886has been signed by each member of the household age l8 years or older and is in the household file 2 Exhibit 2 • Ensures compliance with SARA security policies and procedures outlined in this document • Communicates security information and requirements to appropriate personnel, including coordinating and conducting annual security awareness training sessions Ensures that any infractions of security procedures are promptly reported to the Housing & Neighborhood Development Manager or her designee for investigation and enforcement • Ensures that all EIV retards and forms (i.e., signed user agreements} are kept and updated as needed. Other Quality Cantr©1 Reviews Lead Staff Persons routinely conduct audits on completed transactions. As part of any file audit, they will check for a current HUD-9886 The Supervisors} will conduct an annual review of tenant files to ensure that HUD-9886 forms are in tenant files. Files will be randomly selected. Sample size will be the same as sample size outlined in SEMAP regulations for indicator #3 --Adjusted Income. Security Awareness Training Security Awareness Training is a crucial aspect of ensuring the security of the EIV system and data. EIV users and potential users will be made aware of the importance of respecting the privacy of data, following established procedures to maintain privacy and security, and notifying management in the event of a security of privacy violation. In addition to annual Security Awareness Training, the Security Officer{s) will communicate security information and requirements to appropriate personnel using various methods such as: • E-mail reminders • Discussions at group and managerial meetings • Security bulletins posted throughout the work areas Security Awareness Training will be provided to each employee upon granting access to the EIV system. Thereafter, annual security awareness refresher training will be provided to each employee with EIV access. Annual Security Awareness Training will be conducted through HUD Webcasts ar by the Security Officer. • The trainer and the employee will both sign a certif cation that EIV security training has been provided. The training certif cation and a record of the training material provided at the awareness training will be kept in the Security Awareness Training section of the EIV fle. • A# the end of the training, each employee will also sign the EIV Rules of Behavior and User Agreement form. One copy will be given to the employee to be placed in their desk 3 Exhibit 2 manual and one copy will be retained in the User Agreement section of the EIV file. The farms will be updated once a year at the refresher training. • Examples of potential Privacy Act and security violations will be provided during the training. Technical Safeguards The purpose of these technical safeguards is as follows: • To reduce the risk of a security violation related to the EIV system's software, network or applications • To identify and authenticate all users seeking access to the EIV system • To deter and detect attempts to access the system without authorization • To monitor the user activity of the ETV system. Various technical safeguards have been built into the EN system to mitigate the risk of security violations. However, SAHA will ensure that the physical and administrative safeguards are also in place to complement these technical safeguards in order to meet HUD's standard for the protection of private data. description of Built In Technical Safeguards The following describes the technical controls built into the EIV system: • Each user is required to have their own User ID and Password • The User ID identifies the PHA and tenant information that the user is authorized to access • User IDs are confidential and maintained by the Security Officer • The system forces all users to change their password periodically and limit the reuse of previous passwords • After three unsuccessful attempts to login, the User ID is locked and the user must contact the HUD System Administrator to have the password reset • Online warning messages that inform the user of the civil and criminal penalties associated with unauthorized use of the EIV system will be displayed. The following describes additional SAHA Technical Safeguards: • Each user is requited to have their own User ID and Password • The individual User ID is attached to specific access rights • System {network} users are granted limited access rights and given a password to access the Network system • Warning messages when users log in inform the user of City of Santa Ana policy governing the use of City systems. 4 Exhibit 2 In addition to the built-in technical safeguards, SARA will follow the following technical security requirement: • SAHA staff will not save EN data to a computer hard drive or any ather automated information system {i.e., network drive, disk or CD} • SAHA staff will not leave their computer unattended with EIV data displayed on the screen • SAHA staff will not log in on another user's ID. Administrative Safeguards The SAHA EN Security Officer{s} will maintain security-related records and monitor programmatic security issues. The EN Security Officers} will adhere to the following administrative safeguards: Ensure that aIl users who have access to EIV data have an Access Authorization/Rules of Behaviar/LTser Agreement foam on f le signed by the user and the Security Officer on her designee on file; Conduct quarterly reviews of all User IDs to determine if the user still has a valid need to access the EIV data; and Ensure the access rights are modified or revoked as appropriate. The EN Security Officers} will maintain the following EIV security records and forms: • EIV Rules of Behavior and User Agreement forms • EIV Access Authorizatian Forms • EN Security violation information * EIV Security Awareness Training Records • Records of internal audits to ensure that the Form HUD-9855 has been signed by each adult member of the household and is kept in the Confidential Resident File • A record of all users who have approved access to EN data including the date the access was granted and the date access was terminated. Physical Safeguards The purpose of physical safeguards is to provide barriers between unauthorized persons and documents containing private data. Access to Work Space The doors to the SAHA work area are locked at all times. To enter into the workspace, you must access a coded door lock. Employees are only granted access to a workspace that is appropriate based on their employment assignment. Hours of access to the workspace are also controlled. In general, staff is alIawed access to the workspace Monday-Friday, from 7:00 a.m. to 6:00 p.m. Management approval is required far weekend or after hours work. S Exhibit 2 Confidenfial Resident Files/Central Filing Room All EN data will be viewed for each adult- If printed to assist with a fraud investigation it will be destroyed after use by shredding to a size where strips are unreadable (Section 2.2 of HUD's. EIV Security Procedures Manual}. Policy prior to April 2008 allowed for EN to be printed and imaged. The main door to the imaging area will remain lacked and files not already imaged will be released only when the file clerk who oversees the area is present. Same files are not yet imaged. As necessary, staff may maintain a file at their workstation. However, tenant files containing EN may not be left unattended or open on the desktop when staff is away from their desk. Any tenant files containing EIV held at workstations must be properly stored in locked overhead bins or locked desk drawers when not in use. Once a transaction is completed, and if the EIV documents were printed to investigate fraud, they will be destroyed by shredding to a size where strips are unreadable {Section 2.2 of HUD's EIV Security Procedures Mahual}. Hard Copy Security Requirement When EIV is printed, staff will retrieve computer printouts as soon as they are generated so that EIV data is not left Lying unattended in printers where unauthorized users may access them. Hard Copy Security Violations SARA will handle EN data in such a manner that it does not become misplaced ar available to unauthorized personnel Any eonf dential resident file should he assumed to contain EN data. Therefore, the participant file cannot be viewed by any personnel that are not expressly authorized {examples of authorized staff: staff in charge of that file, the supervisor of the staff in charge of the file, or approved/authorized auditors} and who do not have both an Access Authorization Form/Rules of Behavior/User Agreement on file with the EIV Security Qfficer. Viewing the EIV information of a participant outside of a staffs caseload assignment is considered a security violation for both the staff viewing the EIV information and for the staff that left the infomaation unattended. Unless a supervisor has specifically authorized staff to view another staff s EN data, this is expressly prohibited. Disposal of EIV Information EIV Reports must be disposed of under the following circumstances: • EN report was incorrectly requested. Repurtin~ Improper Disclosures Recognition, reporting and disciplinary action in response to security violations are crucial to successfully maintaining the security and privacy of the EN system. 6 Exhibit 2 Security Violations may include the following: • Disclosure of private data • Attempts to access unauthorized data ~ Sharing of User IDs and passwords Upon discovery of a possible improper disclosure of EIV information or another security violation by a SARA Employee or any other person, the individual making the observation or receiving the information should contact their immediate supervisor or the EIV Security Officers}. If the incident is reported to a supervisor, the supervisor must immediately inform the EIV Security Officer. The EN Security Officers} will document all improper disclosures in writing an a security disclosure form providing details including who was involved what was disclosed, how the disclosure occurred, and where it occurred. The following contacts will 6e made: • The EIV Security Officers} will contact and provide the written documentation of the security violation. The Security Officers} is responsible for informing the Housing & Neighborhood Development Manager of any security breaches. • The Housing & Neighborhood Development Manager or her designee will provide the HUD Field Office Public Housing Director with the written documentation; and, • The HUD Field Office Public Housing Director, upon receipt of the documentation, will make a determination regarding the referral and provision of the written documentation to the Headquarters EN Coordinator and/or EN Security Officers} for further review and follow-up action. Appendix 1. Safeguards Provided by the Privacy Act The Privacy Aet provides safeguards for individuals against invasion of privacy by requiring Federal agencies, except as otherwise provided by law or regulation to: 1. Permit individuals to know what records pertaining to them are collected, maintained, used or disseminated; 2. Allow individuals to prevent records pertaining to them, obtained for a particular purpose from being used or made available for another purpose without their consent; 3. Permit individuals to gain access to information pertaining to them, obtain a copy of all or any portions thereof, and correct or amend such records; ~. Collect, maintain, use or disseminate personally identifiable information in a manner that ensure the information is current and accurate, and that adequate safeguards are provided to prevent misuses of such information; 5. Permit exemption-from the requirements of the Act only where an important public policy need exists as determined by specific statutory authority; and 6. Be subject to a civil suit for any damages that occur as a result of action that violates any individual's rights under this Act. 7 Exhibit 2 RESOLUTION NO. 2011- A RESOLUTION OF THE HOUSING AUTHORITY OF THE CITY OF SANTA ANA APPROVING THE ANNUAL PLAN FOR FISCAL YEAR 20'1'1 20'!2 BE IT RESOLVED BY THE MEMBERS OF THE HOUSING AUTHORITY OF THE CITY OF SANTA ANA, AS FOLLOWS: Section 1. The Housing Authority of the City of Santa Ana conclusively finds, determines and declares as follows: A. The Housing Authority of the City of Santa Ana (the "Authority") is required by the U.S. Department of Housing and Urban Development ("HUD"} to have an Annual Plan due to the fact that the Authority administers a Section 8 Rental Assistance Program. B. The purpose of the Authority's Annual Plan is to advise HUD, program participants and members of the public of its mission and strategy to serve the needs of very low-income families. It provides information about the current operations of the Authority including programs, participants, services for the upcoming year, and any operational or tenant concerns. C. The Authority is required to review its operations and needs on an annual basis with input from a Tenant Advisory Committee comprised of Section 8 participants. The Tenant Advisory Committee met on February 1, 2011, to review the Annual Plan for fiscal year 2011-2012, and all comments from said meeting are incorporated into the Annual Plan, as required by HUD regulations. D. HUD regulations require aforty-five {45} day comment period. On January 28, 2011, notifcation was published in the Orange County Register that the draft plan was available for public review. The public comment period ended on March 15, 2011. Further, a public hearing was held by the Community Redevelopment and Housing Commission on March 15, 2011, and all comments received at the hearing are included in the final documents to be submitted to HUD. Section 2. The fiscal year 2011-2012 Annual Plan of the Housing Authority of the City of Santa Ana is hereby approved and adopted. Said Annual Plan shall be submitted by the Authority to HUD. Section 3. This Resolution shall ta[ce effect immediately upon its adoption by the Authority Board, and the Recording Secretary for the Authority shall attest to and certify the vote adopting this Resolution. ADOPTED this day of , 2011. Miguel A. Pulido Chair APPROVED AS TO FORM: Authority General Counsel By: Lisa E. Storck Assistant Counsel AYES: Boardmembers: NOES: Boardmembers: ABSTAIN: Boardmembers: NOT PRESENT: Boardmembers: CERTIFICATION OF ATTESTATION AND ORIGINALITY 1, MARIA D. HUIZAR, Secretary to the Housing Authority, da hereby aftest to and cer#ify the attached Resolution No. 2D11 ~. to be the original resolution adopted by the Housing Authority of the City of Santa Ana on , 2011. Date: Maria D. Huizar, Recording Secretary Santa Ana Housing Authority 2