Privacy Policy

HousingAI Recertification Determination Service

DRAFT for counsel review. Not legal advice. Bracketed items must be completed.

Last updated: [date]

This Policy explains what information HousingAI LLC ("HousingAI", "we") collects through the Recertification Determination Service (the "Service"), how we use and protect it, and the choices available. The Service is used by housing agency staff; it is not offered to the public or to assisted families directly.

1. Who this covers

• Agency staff (Users): people who sign in to the Service on behalf of a housing agency.
• Household members: people whose income documents an agency submits to the Service. We do not have a direct relationship with household members; the agency is responsible for its notices to them under HUD rules and its own policies. Questions about a household's data should go to the agency.

2. Information we collect

From Users: name, work email address, role, agency, and a log of actions taken in the Service (sign-ins, documents viewed, determinations accepted or overridden, with time stamps). We store a session token and small preferences (such as a selected tab) in the browser.

From agencies about households: agency-assigned household and member reference identifiers; images or PDFs of income evidence, which may contain a household member's name, address, Social Security number (usually masked), employer, and account or employee numbers; and the income figures, methods, flags, and specialist actions that make up a determination. Determination records contain no names, Social Security numbers, or account numbers.

Automatically: server logs containing IP address, request path, time, and browser type. Logs never contain document content, query parameters, or household identifiers.

We never collect or process Enterprise Income Verification (EIV) data.

3. How we use information

• To read income evidence and produce determinations for agency review.
• To show a User the source page a figure came from, so it can be verified.
• To keep an audit trail that agencies need for tenant disputes and HUD monitoring.
• To secure the Service, prevent abuse, and provide support.
• To improve the Service's label dictionaries and rules, using specialist corrections in a form that contains no household information.

We do not sell personal information, do not use it for advertising, and do not use evidence documents to train machine-learning models.

4. Redaction and third-party processing

Before any part of a document is processed by a machine-learning model, the page is processed on our own servers to remove the household member's name, address, Social Security number, and account, employee, and check numbers. Only the redacted page is sent to our model provider, Anthropic, PBC, in the United States, to read the figures and labels. What is sent contains no household or agency identifier. Anthropic's commercial terms prohibit training on this data; we have requested [or: maintain] zero-data-retention so inputs are not kept after processing. A page that cannot be redacted with confidence is never sent; the agency's specialist enters the figures manually.

5. Where information is stored and how it is protected

Information is hosted by Render Services, Inc. in the United States. Evidence documents are encrypted at rest with a key unique to each agency and in transit with TLS. Access is limited to authorized agency Users and to HousingAI personnel who need it to operate or support the Service. Every document view is logged. We maintain a written information security program consistent with Massachusetts 201 CMR 17.00.

6. Retention

Evidence documents are permanently deleted [90] days after upload, or sooner if the agency configures a shorter period. Determination records are kept for [7] years or as the agency directs. User account data is kept while the account is active and for [1] year after. Server logs are kept for [30] days.

7. Sharing

We share information only with the subprocessors named above, with an agency's own authorized Users, as required by law or legal process, or to protect the security of the Service. If HousingAI is acquired or merges, agency data transfers only under terms at least as protective as this Policy, with notice to affected agencies.

8. Your choices and rights

Users may review and correct their account information through their agency administrator. Household members should direct requests about their information to their housing agency, which controls the data; we will assist the agency in responding. Massachusetts residents have rights under M.G.L. c. 93H regarding security breach notification; we support agencies in meeting those obligations.

9. Security incidents

If we confirm a security incident affecting agency data, we notify the affected agency without unreasonable delay, and within 72 hours, with the information it needs to assess and respond.

10. Children

The Service is for agency staff and is not directed to children. Household documents may concern minors; they are handled under the agency's authority and the protections above.

11. Changes

We will post changes here with a new "last updated" date and notify agency administrators of material changes at least 30 days before they take effect.

12. Contact

HousingAI LLC, [address], [privacy email].