According to the HUD 2004 Data and Technical Standards, “A covered homeless organization (CHO) must develop and implement a plan to dispose of or, in the alternative, to remove identifiers from, protected personal information (PPI) that is not in current use seven years after the PPI was created or last changed (unless a statutory, regulatory, contractual, or other requirement mandates longer retention).”
Following this, when a record in Show The Way has met the threshold of having no changes in the 7 years since it was first created or last updated, the Client shall be able to delete the entire client’s information or remove personally identifiable information from the record.
As the 7-year threshold is HUD’s standard for HMIS, the client must monitor Federal, state, local, and other contractual requirements to determine if other data retention periods must be adhered to.