California Department of Social Services Privacy Policy – IHSS EVV Mobile App

Effective:

This Privacy Policy sets forth the California Department of Social Services (CDSS) Privacy Policy applicable to the In-Home Supportive Services (IHSS) Electronic Visit Verification (EVV) mobile application (IHSS EVV Mobile App).

From time to time, this Privacy Policy may change. For example, as CDSS updates and improves the IHSS EVV Mobile App, new features may require modifications to the Privacy Policy.

CDSS is committed to promoting and protecting the privacy rights of individuals as enumerated in Article 1 of the California Constitution and other state and federal laws including:

• Government Code section 11015.5
• Health and Safety Code section 1500 et seq.
• Information Practices Act - Civil Code section 1798 et seq.
• Public Records Act - Government Code section 6250 et seq.
• Safeguarding Information for the Financial Assistance Programs - 45 CFR section 205.50
• Statewide Administrative Manual (SAM) section Privacy 5310 et seq.
• Statewide Information Management Manual (SIMM) 5310 - A & B.
• Welfare and Institutions Code section 10850

In accordance with state and federal law, it is the policy of CDSS to safeguard the privacy of personal information collected or maintained by the CDSS. However, information on the IHSS EVV Mobile App may be subject to public inspection and copying under the California Public Records Act (PRA), which ensures public access to government records and information unless an exception applies to protect the information. The exceptions serve various needs, including maintaining the privacy of individuals. In the event of a conflict between this Policy and any law governing the disclosure of records, the applicable law will control.

CDSS follows these principles in collecting and managing personal information:

(1) CDSS collects personal information on individuals only as allowed by law and uses personal information only as specified and consistent with those purposes; unless CDSS obtains the consent of the subject of the information, or as required or allowed by law. Any subsequent use of the information shall be limited to and consistent with the fulfillment of those purposes; and/or to make disclosures as required or authorized by law.

IHSS EVV Mobile App To comply with Federal and State Laws, CDSS may collect the following information as well as additional information as necessary:

• Location information including GPS latitude and longitude at the start and end of a visit. Location is ONLY collected at these two points in time. CDSS does not track the movement of the users at any time.
• Start and end date and time of the visit
• Hours worked
• Provider identification
• Recipient identification
• Language preference
• Device model/version

Provided there is no cellular or Wi-Fi signal, the IHSS EVV Mobile App may store the above referenced information on a mobile device temporarily (in an encrypted form). Once a signal is established, such data is transferred to CDSS system and then deleted from the device.

(2) CDSS does not disclose personal information. Personal information may not be disclosed, made available, or otherwise used for a purpose other than those specified, except with the consent of the subject of the personal information, or as prescribed by law or regulation.

(3) CDSS tells people who provide personal information about their right to review that information. Individuals who provide personal information to CDSS have the right to review the information for accuracy and completeness and to request corrections or deletions. For personal information access requests send an email to CDSS’ Public Inquiry and Response Unit piar@dss.ca.gov and/or call (916) 651-8848 who will then direct you to your program representative.

(4) CDSS protects personal information. The Department takes precautions and security measures to protect the personal information collected or maintained by CDSS against loss, unauthorized access, use, modification or disclosure.

CDSS will provide additional information on our privacy policy if requested. If you have further questions, comments, or complaints about our privacy policy or policy compliance you may contact:

CDSS Information Security & Privacy Officer
744 P Street
MS 9-9-61
Sacramento, CA 95814
E-mail: iso@dss.ca.gov

For more general information about online privacy and security, please see the California Department of Justice’s Online Privacy page.

Other Information Security and Privacy Websites

The California Department of Social Services (CDSS) works with its partners in Local, State, and Federal government to protect the confidentiality of information it receives. Additional information on the state and federal policies and principles of information security and privacy protection may be found on the following hyperlinked websites.

State of California:

1. State of California Information Security & Privacy Policies – provides information on the security and privacy policies published by the State Information Security Office.
2. Office of the Attorney General Privacy Portal – provides information on privacy protection for citizens.
3. California Office of HIPAA Implementation – provides guidance to state departments on protecting health information as set forth in the Health Insurance Portability and Accountability Act (HIPAA).
4. Committee for the Protection of Human Subjects (CPHS) – is the review board that assures research involving human subjects is conducted ethically and with a minimum risk to participants.
5. Security Awareness – contains consumer information on general security awareness provided by the Office of the Attorney General.

Federal Information:

1. Rules and Policies – Protecting Personal Identifiable Information (PII) – Privacy Act – The webpage is intended to inform the public of GSA's privacy policies and practices.
2. Computer Crime and Intellectual Property - The Computer Crime and Intellectual Property Section (CCIPS) is responsible for implementing national strategies in combating computer and intellectual property crimes worldwide.

*CDSS is presenting these references without necessarily endorsing their content. The State of California cannot guarantee the accuracy of any information presented in the references. The information in a cited reference may not represent the policy of the State of California on the subject matter of the reference.