9-17 Disclosure of EIV Data

• A. Disclosure of an Individual’s EIV Information to Another Person or Entity

The Federal Privacy Act (5 USC 552a, as amended) prohibits the disclosure of an individual’s information to another person without the written consent of such individual. As such, the EIV data of an adult household member may not be shared (or a copy provided or displayed) with another adult household member or to a person assisting the tenant with the recertification process, unless the individual has provided written consent to disclose such information. The owner, however, is not prohibited from discussing with the head of household and showing the head of household how the household’s income and rent were determined based on the total income reported and verified. See Exhibit 9-4, for a Sample Tenant Consent to Disclose EIV Income Information for use by the owner in obtaining the tenant’s consent to disclose information to another adult household member.

• B. Disclosure to Persons Assisting Tenants with the Recertification Process

With the written consent of the tenant, EIV data may be shared with persons assisting the tenant with the recertification process. Tenants who require assistance during the recertification process may have a representative present to assist them in their ability to participate in the recertification process; this includes review and explanation of the written third party income verifications. Disclosure of EIV information to these parties must be employment or income information pertaining only to the tenant who has provided his/her consent. These parties must not have access to EIV information for any other household members.

Parties to whom the tenant can provide written consent include:

• Service coordinators (only if they are present at and assisting the tenant with the recertification process)

• Translators/Interpreters

• Individuals assisting an elderly individual or a person with a disability

• Guardians

• Powers of Attorney

• Other Family Members

See Exhibit 9-4, for a Sample Tenant Consent to Disclose EIV Income Information for use by the owner in obtaining the tenant’s consent to disclose information to persons assisting the tenant with the recertification process.