In case you were wondering what H.S.I.'s privacy policy regarding Protected Personal Information (that's YOUR information, stored in their case files!) is, read the following. You might also want to limit what you tell your case worker or any other staff member, unless you really don't care who knows your personal business.

Protected Personal Information (PPI) Privacy Policy Introduction The policy covers the collection, use, and maintenance of Protected Personal Information (PPI) for the tenants of HSI, as an organization affiliated with the NYC Coalition on Continuum of Care (CCoC). PPI is any personal information we maintain about a tenant that: a. allows identification of an individual directly or indirectly; b. can be manipulated by a reasonably foreseeable method to identify a specific individual; c. can be linked with other available information identifying a specific tenant. HSI adopted this policy because the Department of Housing and Urban Development issued standards for Homeless Management Information Systems. We intend our policy and practices to be consistent with those standards. (See 69 Federal Register 45888, (July 30, 2004)). This policy informs our tenants, our staff and others how we process personal information. We follow the policy and practices described in this privacy policy. The policy and practices may be amended at any time. Amendments may affect PPI that we obtained before the effective date of the amendment. HSI provides a written copy of this privacy policy to any individuals who ask for it. HSI maintains a copy of this policy on our website at www.hsi-ny.org Process HSI collect PPI only when appropriate to provide services or for another specific purpose of our organization or when required by law. We may collect information for these purposes: a. to provide individual case management; b. to produce aggregate-level reports regarding use of services; c. to track individual project-level outcomes; d. to identify unfilled service needs and plan for the provision of new services; e. to conduct research for consulting and/or educational purposes; and f. to accomplish any and all other purposes deemed appropriate by the CCoC. We only use lawful and fair means to collect PPI, normally collect with the knowledge or consent of tenants. If a tenant seeks our assistance and provide us with PPI, HSI assumes you consent to the collection of information described in this Policy has been granted. Data is shared with the NYC Department of Homeless Services (DHS), Planning, Development & Grant unit, the agency appointed by the CCoC to manage all PPI HSI records about our tenants. DHS is required to maintain the confidentiality of the data, and has a privacy policy that is available to the public. To inform tenants, HSI post signs at our intake at our intake desk explaining the reason we ask for PPI. The sign says: We collect personal information about homeless individuals in a computer system called a Homeless Management Information System (HMIS) for reasons that are discussed in our privacy policy. We may be required to collect some personal information by law or by organizations that give us money to operate this program. Other personal information that we collect is important to run our programs, to improve services for homeless individuals, and to better understand the needs of homeless individuals. We only collect information that we consider to be appropriate. If you have any questions or would like to see our privacy policy, our staff will provide you with a copy. Usage and Disclosure HSI discloses PPI for activities described in this part of the policy. HSI may or may not make any of these uses or disclosures of your PPI. HSI assumes that your consent to use or disclosure of your PPI for the purposes described below and for other uses and disclosures that we determine to be compatible with these uses or disclosures: i. to provide or coordinate services to individuals; ii. for functions related to payment or reimbursement for services; iii. to carry out administrative functions such a s legal, audits, personnel, oversight and management functions; iv. to create de-identified (anonymous) information; v. when required by law to the extent that use or disclosure complies with and is limited to the requirement by law; vi. to avert a serious threat to health an safety if: vii. appropriate HSI staff believe that the use of our disclosure is necessary to prevent or lessen a serious and imminent threat to the health or safety of an individual or the public; and viii. the use of disclosure is made to a person reasonably able to prevent or lessen the threat, including the target of a. the threat. ix. to report about an individual HSI reasonably believe to be a victim of abuse, neglect or domestic violence to a government authority (including a social service or protective service agency) authorized by law to receive reports of abuse, neglect or domestic violence in any of the following three circumstances: x. where the disclosure is required by law and the disclosure complies with and is limited to the requirements of the law; xi. if the individual agrees to the disclosure; or xii. to the extent that the disclosure is expressly authorized by statute or regulation and either of the following are applicable: a. HSI staff believes the disclosure is necessary to prevent serious harm to the individual or other potential victims; or b. if the individual is unable to agree because of incapacity, law enforcement or other public official authorized to receive the report represents that the PPI for which disclosure is sought is not intended to be used against the individual and that an immediate enforcement activity that depends upon the disclosure would be materially and adversely affected by waiting until the individual is able to agree to the disclosure; c. When making a permitted disclosure about a victim of abuse , neglect or domestic violence HSI will promptly inform the individual who is the victim that the disclosure that a disclosure has been or will be made, except if: xiii. in the exercise of professional judgment, HIS staff believe informing the individual would place the individual at risk of serious harm; or xiv. ii. HSI staff would be informing a personal representative (such as a family member or friend) and staff reasonably believe the personal representative is responsible for the abuse, neglect or other injury and that informing the personal representative would not be in the best interests of the individual as we determine in the exercise of our professional judgment. xv. h. to a law enforcement official for a law enforcement purpose consistent with summons issued by a judicial officer, or a grand jury subpoena; i. is signed by a supervisory official of the law enforcement agency seeking the PPI; ii. states that the information is relevant and material to a legitimate law enforcement investigation; iii. identifies the PPI sought; iv. is specific and limited in scope to the extent reasonably practicable in light of the purpose for which the information is sought; and v. states that de-identified information could not be used to accomplish the purpose of disclosure; xvi. iii. if HSI staff believe in good faith that the PPI constitutes evidence of criminal conduct that occurred on our premises; xvii. in response to an oral request for the purpose of identifying or locating a suspect, fugitive, material witness or missing person and the PPI disclosed consists only of name, address, date of birth, place of birth, social security number and distinguishing physical characteristics; or xviii. if: a. the official is authorized is an authorized federal official seeking PPI for the provision of protective services to the President or other persons authorized by 18 U.S.C. 3056, or to foreign heads of state or other persons authorized by 22 U.S.C. 2709 (a) (3), or for the conduct of investigations authorized by 18 U.S.C. 871 and 879 (threats against the President and others); and b. the information requests is specified and limited in scope to the extent reasonably practicable in light of the purpose for which the information is sought. xix. to comply with government reporting obligations for HMIS and for the oversight of compliance with HMIS requirements. xx. to third parties for the following purposes: xxi. to permit other systems of care to conduct data matches (ie. to determine if you are also utilizing services from such other systems of care);and xxii. to permit third party research firms and/or evaluations to perform research and evaluation services in a. connection with the programs administered by the CCoC and the other agencies; provided that before PPI is disclosed under the subsection, the third party that will receive such PPI and use it as permitted above must first execute a Data Use & Disclosure Agreement requiring such third party to comply with all applicable laws and regulations, including the privacy standards and disclosure provisions contained in the Department of Housing and Urban Development Homeless Management Information Systems; Data and Technical Standards Final Notice (see 69 Federal Register 45888 (July 30, 2004)), which such standards and provisions are reflected herein. Before HSI makes any use of disclosure of your PPI that is not described herein, we will seek tenants consent first. Inspect and Correct PPI Tenants may inspect and have a copy of your PPI that HSI maintains. Requests for inspection of PPI must be documented in a progress note. HSI staff will offer to explain any information that you may not understand. HSI will consider requests from tenants for correction of inaccurate or incomplete PPI that is maintained. If HSI agrees that the information is inaccurate or incomplete, it may be deleted or we may choose to mark it as inaccurate or incomplete and to supplement it with additional information. The correction will be documented in a progress note. HSI may deny your request for inspection or copying PPI if: i. the information was compiled in reasonable anticipation of litigation or comparable proceeding; ii. the information is about another individual (other than a health care provider or homeless iii. provider); iv. the information was obtained under a promise of confidentiality (other than a promise from a health care provider or v. homeless provider) and if the disclosure would reveal the source of the information; or vi. disclosure of the information would be reasonably likely to endanger the life or the physical safety of any individual. If HSI denies a request for access or correction, we will explain the reason for denial and document the same in a detailed progress note. HSI will also include, as part of the PPI that we maintain, documentation of the request and the reason for the denial. HSI may reject repeated or harassing requests for access to or correction of PI. Data Retention HSI collect only PPI that is relevant to the purposes for which we plan to use it. To the extent necessary for those purposes, HSI seeks to maintain only PPI that is accurate, complete and timely. HSI will dispose of PPI not in current use seven years after the information was created or last changed. As an alternative to disposal, HSI may choose to remove identifiers from the PPI. HSI may keep information for a longer period if required to do so by applicable statute, regulations, contract or other requirement. Complaints and Accountability All HSI staff (including employees, volunteers, affiliates, contractors and associates) are required to comply with this privacy policy. Each staff member must receive and acknowledge receipt of a copy of the privacy policy. HSI accepts and considers questions or complaints about HSI’s privacy and security policies and practices. Tenants may make an appointment with the Program Manager to discuss any questions or concerns they have about this policy. In the event that tenants’ question or complaint is not sufficiently addressed through this organization, you may take your concerns to the Grievance Committee at the CCoC. Individuals will submit grievances in writing to the co-chairs. The co-chairs will pass the grievance to the Grievance Committee of the CCoC. Individuals will submit grievances in writing to the co-chairs. The co-chairs will pass the grievances to the Grievance Committee, which will review it and make a recommendation back to the co-chairs. The co-chairs will make the final decision about the outcome and notify you. More information about this Committee can be found at www.NYC.Homeless.com.

A number of Kenmore Hall tenants have been having problems with the H.S.I. social service staff since roughly May 2013. The issues include: · the closing of the community room at midnight and the lobby at 1:00, prohibiting tenants from having the 24 hour access they’d all been accustomed to for many years (this is allegedly because a number of fights between tenants had broken out, and rather than ban the fighting tenants, all tenants are deprived of the use of common areas that would be a relief from the close quarters in the tiny “studio” apartments) · commencing monthly “home visits” by social workers; social workers haven’t communicated clearly why these home visits are at all necessary, but the widespread lie the social workers tell tenants is that they signed a consent form as part of their original packet of material when they moved in. Nobody recalls signing a consent form like that, and nobody who’s asked to see the form has been allowed to see it. · Some tenants have been given peculiar health forms to sign, including one tenant who was given an HIV consent form to sign. Most people are refusing to sign them. · Tenants seeking relief from problems in their units like severe infestation by mold or roaches are told that they themselves are the cause of the problem, even if they don’t have food lying around in the open and have been filling out work orders requesting help getting rid of the problem · Tenants who call 311 about heat/hot water and other issues are told that H.S.I. can’t afford one more violation, that the tenants must not call 311 again or there will be a legal retaliation, and then tenants are banned from going on movie trips with the social director. Tenants who resist submitting to the new rules are told that they are: · Mentally ill · Hoarders · Nuisances, and subject to legal action, including possible eviction · Having a nasty attitude toward case workers · In need of help from Adult Protective Services (APS) Please keep in mind that the commentary about the tenants’ frame of mind comes from case workers who are usually at least 20 years younger than most tenants, and who don’t display their academic affiliation and which degrees they’ve earned.

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Next time your case manager tries to bluff you into thinking you signed a consent to have them do a monthly home visit, ask to see that consent form. Then ask them if they're familiar with the old house rules form, which is the only other form most of use signed aside from our leases. Go read your lease CAREFULLY, by the way - it's a standard rent stabilized lease and says absolutely NOTHING about home visits or any other social services they're trying to coerce tenants into agreeing to. This is a verbatim transcript of the text of the house rules as of April, 2008. The formatting is slightly different. Kenmore Hall House Rules and Regulations Revised 8/26/02 VISITORS 1. Visitors will be allowed to enter the building before 11:00 p.m. and after 8:00 a.m. 2. Management reserves the right to deny access to any visitor at any time and to photograph any visitor at the time of sign-in. 3. Failure to comply with the following rules may lead to visitors being escorted from and/or barred from the building at the discretion of management. 4. All visitors are required: a. To leave a valid picture identification at the front desk prior to entering Kenmore Hall b. To sign in and out of the guest logbook located at the front desk. c. To carry a guest pass for the designated floor on which their host lives. d. To remain with their host tenant at all times. e. To adhere to the rules and regulations of Kenmore Hall. 5. Acceptable photo IDs include valid driver’s license, NYS non-driver’s ID, employment ID, passport, current welfare card, and/or any other valid photo ID issued by a government agency. 6. Children under the age of 18 years must be accompanied by an adult at all times, and must leave the building by 11 p.m. FACILITY REGULATIONS 7. Consumption of alcohol or illegal substances, and smoking are prohibited in common areas. 8. No pets are allowed. 9. Loud noise between the hours of 11 p.m. and 8 a.m. will be investigated and may be grounds for termination of the lease. Excessive noise, which disturbs others, will not be tolerated at any time. 10. No soliciting, congregating, or trespassing is allowed in or around the building perimeter. 11. Foul language, fighting, or other disruptive behavior will result in a security intervention. 12. Keys are the sole responsibility of the tenant. The fee to replace the key is ten dollars. Management reserves the right to retain a copy of the key to your apartment for emergencies, inspections, exterminating and room repairs. 13. Tenants must cooperate with building personnel who conduct regular apartment inspections and smoke alarm tests to ensure compliance with federal quality housing standards. 14. All trash must be placed in plastic bags. Only household trash may be thrown down the chute located near the elevator on each floor. Rinsed recyclable items must be placed in the blue bins next to the chute. 15. Portions of the building are permanently off limits to tenants. They are clearly indicated by posted signs and include the roof, basement, fire tower stairs, or emergency exits located at the end of each stairwell. Management may temporarily restrict other areas. 16. Stairs, which are marked as Stairwell A and Stairwell B are not to be used to enter or leave the building except in the event of an emergency. 17. Tenants planning to move must notify the management in writing a minimum of thirty days in advance. 18. Rent payments are due the first of the month. INFORMATION: 19. The Community Lounge, Library and Exercise Room, located on the second floor, are open daily from 9 a.m. to 11 p.m. unless otherwise noted. Please help keep them clean. 20. Designated hours for moving large objects in or out of the building are 10 a.m. to 4 p.m. Please notify management two days in advance of the move. 21. When repairs are needed in your apartment, please fill out a Work Order Form at the Front Desk. Indicate on the form a time during normal business hours when you will be available to grant access or leave a Room Access Form. Normal maintenance requests will be handled on a priority basis. Emergency repairs will be handled immediately. 22. Laundry facilities are located on every other floor. They are open daily between 6 a.m. and 11 p.m. Their usage is for tenants only. Tenants must provide their own laundry detergent. Kenmore Associates are not responsible for the operation or maintenance of laundry machines or for change lost in the machines. If machines malfunction, report the problem immediately to the Front Desk staff. They will contact the vendor and schedule service. 23. Kenmore Associates is not liable for tenant’s personal property. Tenants are encouraged to purchase renter’s insurance to protect their belongings. 24. The Rent Payment Office on the second floor accepts rent from 9 a.m.-2 p.m. Mon-Fri. No cash is accepted. Checks or money orders should be made payable to Kenmore Assoc., L.P. 25. In case of fire, call 911 immediately, then notify management. Do not use the elevators. Please take the time to review the evacuation plan attached to your lease packet, and familiarize yourself with the locations of the emergency exits nearest your apartment. 26. Each floor is supplied with fire extinguishers for emergency use only. Signature: __________________________________________________________________Date: _________

The lobby and community room should not be closed to all tenants at night because a few tenants have created problems. Ban the problem tenants, and restore full access to everyone else. Access to common areas of the building is a (legal) right, not a privilege, but tenants are also entitled to peaceful and quiet enjoyment of the premises. Problem tenants should have their public behavior restricted – rather than restricting non-offending tenants. Certain problem tenants drink publicly in the lobby and community room on a regular basis, and then become loud and belligerent toward other tenants who are minding their own business.  This behavior is tolerated by management and staff, despite the fact that they make other tenants extremely uncomfortable. They “perform” on camera for hours on end, and the lobby staff has to be aware of it because the activity is so loud. Why is this tolerated? It wouldn’t be in any other building. Management seems to favor tenants with severe drug and alcohol problems, or at least turn a blind eye toward negative public behavior. The alleged “mandatory,” building-wide room inspections on a monthly basis are illegal and invasive. Kenmore Hall is NOT a shelter or assisted-living institution; it’s an S.R.O. Tenants here are protected by rent stabilization laws. Our leases are legal contracts that provide us with rights and protections according to federal, state and city real estate laws. H.S.I. can put anything they want to in writing, or agree to make an appointment, but that doesn’t take priority over law, and tenants have the right to question and contest arbitrary regulations. Why does the Clinical Director seem to think that it’s acceptable to assume that all tenants in the building are in “programs”? That’s a form of profiling, and it’s extremely offensive. Some tenants are here because they have larger issues (alcoholism, drug addiction, mental illness, incarceration) that aggravate poverty. Some other tenants actually have jobs, though, and others are merely poor and trying to put their lives back together. Not all of us have the kind of problems/issues that require participation in a “program.” HOWEVER, some of the more problematic tenants, who disrupt life on a regular basis for everyone else, aren’t in programs of any sort and appear to need them – if not to actually help them overcome their problems/issues, then to at least help them learn to respond appropriately to the kind of social cues that would make life easier for the rest of us (for instance, leaving a common area when everyone else there is telling them that nobody wants to listen to their drunken rants or be harassed). Even if it’s not possible to compel someone to participate in a program if they have substance abuse problems, can’t legal measures be taken if they persistently abuse drugs or alcohol in public and disturb other tenants’ right to peaceful use of common areas?

GUESTS

You have the right to have guests and a roommate! Your landlord does not have the legal right to forbid you from having guests. You cannot be prevented from having guests by a lease, or by house rules, or by printed notices in the lobby. For example, in the case of McKenna v. Peekskill Housing Authority, the New York State Court of Appeals said that tenants had a basic right to invite whomever they wished to their homes. Landlords may be able to keep people out only if they have previously conducted themselves improperly or unlawfully. You can also have a long-term guest & a roommate. Section 235-f of New York Real Property Law gives tenants -- including SRO tenants -- the right to have a roommate. Restrictions on roommates can be based only on the size of the room or apartment. In general, an SRO room that is at least 130 square feet (for example, 10' by 13') can have up to two people. A smaller room can have only one person. ____________________________________________ For more information contact: Goddard Riverside Community Center The West Side SRO Law Project 51 West 109 Street New York, NY 10025 212-799-9638 Drop-in Intake: Thursdays, 4p.m. to 6p.m. ¡Usted tiene el derecho de tener huéspedes y un compañero de cuarto! Su casero no tiene el derecho legal de prohibir sus invitados. Reglas de la casa, ni un arriendo, ni una noticia en el vestíbulo puede prohibir invitados. Bajo el caso McKenna v. Peekskill Housing Authority, la corte de apelación de Nueva York dijo que inquilinos tienen el derecho básico de invitar a cualquier persona que desea a sus hogar. El casero si puede prohibir visitas, si la visita se comporta de una manera ilegal o impropia. También se puede tener un compañero de cuarto. La Sección 235-f del Real Property Law de Nueva York le da inquilinos incluyendo inquilinos de cuartos individuales B el derecho de tener compañeros del cuarto. Restricciones solo existen en el caso que el cuarto sea demasiado pequeño. Generalmente, un cuarto tiene que ser más de 130 pies cuadrado (por ejemplo 10’ por 13’) para tener dos personas. Un cuarto más pequeño solo puede tener una persona. Para obtener más información: Goddard Riverside Community Center Proyecto Legal de Cuarto Individuales (West Side SRO Law Project) 51 West 109 Street 212-799-9638 Citas: jueves, de 4p.m. a 6p.m.