Default image

Privacy Policy

Adoption and Revision History

Initial Adoption: Resolution No. 5460 on May 18, 2026

HOUSING AUTHORITY OF THE CITY OF OAKLAND

A. PURPOSE


The purpose of this Policy is to safeguard the trust of Oakland Housing Authority (Authority) resident, staff, and the community at large in the Authority’s use of new and emerging technologies and to protect their digital privacy rights. It sets forth the framework for Authority departments to observe when information systems or other
applications and forms collect the public’s Personally Identifiable Information (PII). This Policy strives, to the extent practicable, to assist others in determining when, how, and to what extent information about them is communicated to others. As new and emerging technologies have a greater capacity for collecting information
and drawing insights about people and communities, this Privacy Policy will enable the Authority to harness the power of those insights to provide better services to the community while ensuring that personal and sensitive information is properly protected.


B. DEFINITIONS


Personally Identifiable Information (PII): Information collected by the Authority that can directly or indirectly identify individuals can be classified into five primary categories of data:

  1. Personal data: information relating to an individual, such as full name, street address, email address, and personal computer or mobile device IP address.
  2. Sensitive or demographic data: subsets of personal data that require extra security and care, such as biometric or genetic data, racial or ethnic origin, and religious or political affiliations.
  3. Image data: digital pictures or photographs that can identify an individual by their face or other contextual information.
  4. Recording data: audio or video information that can identify an individual by their face, voice, or other contextual information.
  5. Geolocation data: information affiliated with a computer, device, or vehicle that can be used to identify an individual based on physical location or on aggregate location patterns.



Pseudonymize: a data management practice where personally identifiable information is replaced with artificial identifiers to prevent direct recognition withoutadditional, separately stored data


Tracking Technology: Any technology that collects, stores, or transmits personally identifiable information, location or spatial data, images, or recordings that can be used to identify, monitor, surveil, make inferences about, or predict the behavior of individuals.


C. POLICY

It is the Policy of the Oakland Housing Authority to protect the privacy of individuals and the digital form of any Personally Identifiable Information that is collected, used, shared, or stored by the Authority. In addition to this Policy, the Authority is also subject to laws and regulations that govern the collection, storage, and retention of
information.

To the extent permissible by law, Authority departments will adhere to this Policy, as well as the following elements to protect individual privacy:

  • Notice: Providing notice about the collection, use, and sharing of personal information at the time such information is collected. The Authority will make every reasonable effort to provide a privacy notice when basic services are requested or delivered.
  • Retention: Developing, maintaining, and following the Authority’s Records Retention and Disposition Policy 1 data retention schedule. Departments must ensure that identifying information is deleted or deidentified after the retention period expires. In the event of a conflict between this Policy and the Public Records Act, Sunshine Act, or other law governing the disclosure of records, the applicable law will determine our obligation in support of open and transparent government.
  • Minimization: Minimizing the collection and processing of identifying information and limiting collection to only what is necessary to provide services and to conduct business. When personally identifiable data is required to deliver or improve a service, departments must anonymize, de-identify, pseudonymize, or otherwise mask this information.
  • Accountability: Maintaining documentation, available for public review and third-party monitoring, to demonstrate compliance with our privacy principles and Policy. If any information under our control is compromised or if residents are impacted due to a breach of security or negligent maintenance of information systems, the Authority will take reasonable steps to investigate the situation and notify those individuals whose information may have been impacted.
  • Accuracy: Making every reasonable effort to provide the public with information on how predictive or automated systems are used and will institute processes to correct inaccurate information or methodologies in those systems. The Authority may use predictive or automated systems and technologies to support decision-making, but some degree of human input and oversight into decision making is also required.
  • Sharing: Following clear data governance procedures and instituting information sharing agreements when sharing information with outside entities, which shall strive to enable effective information sharing while following this Policy. Nothing in this policy shall preclude data sharing with research or other institutions as long as clear data sharing agreements are in place that govern the use of data pursuant to the standards of this Policy.
  • Equity: The Authority is mindful of the populations it serves and how data about residents and other members of the public can and should be used. The Authority will strive to advance equity in a data-driven way while ensuring that PII is used only in accordance with this policy.


D. APPLICATION AND USE OF PRIVACY DATA

The Authority’s Executive Director, or designee, will lead the agency’s implementation, maintenance, and adherence to this Privacy Policy in coordination with the Director of Information Technology.

Projects, specifically technology related projects, shall be adjudicated according to this Policy.

Implementation of this Policy shall include at least the following:

  • Development of procedures for prioritizing and executing the evaluation of privacy risks for new projects and vendor contracts according to this Policy, and the interests expressed by the Board of Commissioners, residents, and the community at large; and
  • Privacy review and assessment processes to aid departments and information system owners in ensuring that digital privacy standards in this Policy are integrated into technologies, projects, processes, and vendor contracts.


At the recommendation of the Director of Technology, and/or other department heads, and in accordance with the standards in this Policy, the Executive Director may require departments to effect modifications to technologies or projects to comply with this Policy.

Exceptions

Due to the critical and time-sensitive nature of emergency responses and investigative efforts, personally identifiable information may be collected by the OHA Police Department (OHAPD) and other authorized personnel, as needed, and such data collection, use, and disclosure practices may fall outside the scope of this
Privacy Policy as necessary to carry out public safety and law enforcement functions.

The OHAPD may also follow specialized protocols and procedures when responding to emergency calls, conducting ongoing investigations, and engaging in other law enforcement activities. The OHAPD will strive to honor the principles outlined in this policy and will conduct its activities in accordance with the applicable provisions of relevant federal, state, and local laws, including the Fourth, Fifth, Sixth, and
Fourteenth Amendments to the United States Constitution.

In addition, this Policy does not apply to personal/personnel information obtained in the Authority’s capacity as an employer. Employment information is covered under separate Human Resources policies.

Confidentiality, Anonymity, and Open Government Standards

New information systems acquired after the effective date of this Policy should, to the extent practicable, have the ability to anonymize, de-identify, or pseudonymize personally identifying information in such a way that it no longer can be related back to a given individual. When updating existing legacy systems, the Authority shall make a reasonable effort to ensure that such systems have the ability to anonymize, deidentify, or pseudonymize this information.

E. PROCEDURAL RESPONSIBILITIES

The Executive Director shall not have the right to terminate this Policy without prior written approval of the Board of Commissioners. In the event the Executive Director modifies or amends this Policy, copies of such modification and/or amendment shall be delivered to the Board of Commissioners.

The Executive Director shall have the right, in their discretion, to waive any of the prohibitions outlined in this Personnel Policy, to the extent such waiver is necessary to;

  1. provide a reasonable accommodation,
  2. comply with applicable law, or
  3. address unforeseen circumstances that require the waiving of policy standards to uphold the mission and values of the Authority and/or the Board of Commissioners.