Enclosure_9_-_2025_Clarity_Exhibit_for_Contracts.pdf

Enclosure 9 Revised April 2024

Clarity Human Services System Usage and Data Sharing Agreement for Core Service Agencies and

Homeless Service Providers

In 2014, Core Service Agencies and homeless service providers migrated to the secure, private and confidential Clarity Human Services system network by Bitfocus (“Clarity”). This migration to Clarity allows for data sharing across providers.

Commitment to Data Entry

The Core Service Agencies and homeless service providers (agency name, hereinafter “the Agency”) agrees to enter into Clarity’s secure system timely and accurate data about the clients to whom they provide safety net services and homeless services pursuant to their contracts with the County of San Mateo (“County”). Timely entry of this data is crucial to the community’s ability to match and refer clients to appropriate safety net and homeless services provided by other providers; to report accurate performance measures; and to capture data on community need.

If the Agency experiences difficulty with the timely entry of data into Clarity, they will notify HSA of the delay, seek technical assistance if necessary, and provide a plan within one week to bring the data entry current as soon as possible.

Confidentiality of Client Data

The Agency will establish appropriate administrative, technical, and physical safeguards to protect the confidentiality of client data and to prevent unauthorized use or access to it.

The data in Clarity shall not be disclosed to anyone or any entity except in connection with the administration of the Agency’s safety net and homeless service programs, as necessary to achieve the provision of homeless and safety net services, or for analysis of the data to show performance measurements, including that of contract compliance.

The data may be reviewed by San Mateo County personnel on a need-to-know basis to check performance measurements, community trends, client services, and for the purpose of monitoring contract compliance. Summary results (e.g., non-identifying information such as general statistical data, caseload, provider data, funding, and expenditure information) are non-confidential may be shared upon request. Data that contains identifying information will be accessible and shared on a need-to-know basis only, and only to the extent permitted by applicable law.

The Agency acknowledges that these confidential data are proprietary to the County and agrees to comply with all applicable State and Federal confidentiality laws and regulations.

The Agency may collect Personally Identifiable Information (“PII”, as defined in Federal information security and privacy laws as information that can be used on its own or in conjunction with other information to identify, contact, or locate a single person, or to identify an individual in context) only when appropriate for the purposes for which the information is obtained or when required by law. The Agency must collect PII by lawful and fair means and, where appropriate, with the knowledge of the individual. The Agency must post the San Mateo County Clarity HMIS Privacy Notice (“Notice”) at each building that provides direct services. If services are being provided by phone, the Agency will offer to read the Notice and also will make efforts to provide a written copy of the Notice via mail or other means. A copy of the Clarity HMIS Privacy Policy (“Policy”) must be made available to clients upon request. Consent of the individual for data collection may be assumed when the Notice is properly displayed according to the Policy. See the attachment or the following link for a copy of the current Policy: https://www.smcgov.org/hsa/san-mateo-county-clarity-hmis-privacy-policy.

Licensing

Only the Agency’s staff who provide safety net or homeless services shall be granted access to Clarity.

When the Agency requests a Clarity license for a new staff member, the Agency director or manager will review with the staff member the confidentiality and security rules regarding Clarity. The staff member will be asked to review and accept the Clarity oath of confidentiality upon their initial login into Clarity and annually thereafter while they retain access to the system.

ACCESS TO THE CLARITY SYSTEM AFTER EMPLOYMENT ENDS IS PROHIBITED. If an authorized user separates from employment with the Agency, notification must be made as soon as possible to the HSA Service Desk in advance of the employee leaving. The request will provide a license termination date.

If any license goes unused for more than 90 days, that license may be deactivated. The Agency holding the license will be notified prior to deactivation of the license and the Agency will have 5 business days to respond with a request if the license is to be continued.

System Configuration Change Requests

All Clarity user agencies’ requests to change Clarity system configuration will be evaluated by HSA. For the cost of all Change Requests unique to one or a group of agencies and for non-Core or non-HMIS standard programs, payment shall be made by the requesting agency(ies).

User Support

If the Agency experiences any technical difficulty with the system, the Agency’s staff will send a service request to the Human Services Agency Business Systems Group at hsa_servicedesk@smcgov.org or

(650) 802-7573.

https://www.smcgov.org/hsa/san-mateo-county-clarity-hmis-privacy-policy mailto:hsa_servicedesk@smcgov.org

Staff Responsibilities

The Agency agrees to train its staff and to establish internal processes and procedures to ensure all staff and volunteers safeguard clients’ confidentiality and privacy and enter accurate, complete data. It is understood that accessing Clarity’s secure, private, and confidential network is for the sole purpose of serving clients. All authorized individuals accessing the Clarity network of Core Service Agencies and homeless service providers must have a legitimate business reason when searching and accessing information. All activity is logged, and participating agencies understand and agree that this audit trail can be viewed at any time by authorized County personnel.

Contractor/Service Provider Agreement

BY ENTERING INTOTHIS AGREEMENT, THE AGENCY AGREES TO THE FOLLOWING:

The Agency agrees that all Agency staff provided with Clarity access will be trained to safeguard the information contained in the SMC secure and private network of Core Service Agencies and homeless services providers.

The Agency agrees to provide internal process and procedures to train the Agency’s staff on the security and confidentiality principles that guard this secure and private network.

The Agency understands and agrees that Agency and its representatives will share and protect information in the Clarity system as set forth herein and as required by law.

The Agency agrees to abide by the Clarity HMIS Privacy Policy and policy management document, available here: https://www.smcgov.org/hsa/san-mateo-county-clarity-hmis-privacy-policy (current version attached). The Agency agrees to further abide by any updates to these documents.

https://www.smcgov.org/hsa/san-mateo-county-clarity-hmis-privacy-policy