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Limitations on Collection of ORR Client Information for Refugee Programs

Policy Letter 20-02

Published: December 2, 2019

November 26, 2019

This Policy Letter announces limitations on access to personally identifiable information (PII) gathered pursuant to refugee programs funded directly by ORR (such as the Match Grant Program).

All ORR grantees have an obligation to protect PII and must adhere to limitations on sharing PII.1 Grantees cannot share PII outside of the direct funding relationship with ORR; nor can one grantee compel another grantee to share PII.

ORR grantees and their sub recipients may request information from another grantee or agency about a specific person only to confirm enrollment in the program and in order to prevent duplication of services. Grantees must limit the amount of PII shared to only that which is necessary to confirm enrollment and must ensure PII is protected when sharing and receiving the confirmation of enrollment. Aggregate information that is de-personalized can also be shared as long as the grantee who collected the data is willing to do so.

Grantees may however collect data directly and ask individuals about their participation in other ORR programs as relevant per their contractual agreements and specific provision of services. For example, as part of the Refugee Support Services, Family Self Sufficiency Plan, states and Replacement Designees may directly collect information from individuals related to their Match Grant program or other program enrollment.

If you have questions about this Policy Letter, please contact Britanny Vanderhoof at Britanny.Vanderhoof@acf.hhs.gov.

Sincerely,

Jonathan H. Hayes, Director Office of Refugee Resettlement
Administration for Children and Families
U.S. Department of Health and Human Services


Footnotes:

1 See Policy Letter 17-02: Data Sharing.

Last Reviewed: December 3, 2019