ANNUAL NOTICE OF PARENTAL RIGHTS

REGARDING PERSONALLY IDENTIFIABLE INFORMATION

This Annual Notice of Parental Rights (“Notice”) describes your rights regarding your student’s record held by the Institute for Human and Social Development, Inc. (“IZZI”) and the circumstances in which IZZI discloses these records.

DEFINITIONS:

“Child Records” means records that contain PII and:

(1) Are directly related to a student at IZZI;

(2) Are maintained by IZZI, or by a party acting for IZZI; and

(3) Include information recorded in any way, such as print, electronic, or digital means, including media, video, image, or audio format.

“Disclosure” or any grammatical variants thereof means to permit access to or the release, transfer, or other communication of PII contained in child records by any means, including oral, written, or electronic means, to any party except the party identified as the party that provided or created the record.

“Parent” means a Head Start child's mother or father, other family member who is a primary caregiver, foster parent or authorized caregiver, guardian or the person with whom the child has been placed for purposes of adoption pending a final adoption decree.

“Personally identifiable information” or “PII” means any information that could identify an individual student at IZZI, including but not limited to the student's name, name of the student's family member, street address of the child, social security number, or other information that is linked or linkable to the student.

PARENTS’ RIGHTS:

The Head Start regulations provide Parents of IZZI students the following rights with respect to the student’s Child Records:

The right to inspect the Child Records within 45 days after the day that IZZI receives your request for access.

The right to request the amendment of the Child Records that you believe are inaccurate, misleading, or otherwise violates the child’s privacy.

If IHSD decides not to amend the Child Records as you requested, you have a right to a hearing. IZZI will notify you if your request to amend the Child Records is denied and provide additional information about your right to a hearing.

The right to only allow Disclosure by IZZI of Child Records to third parties with your written consent, except to the extent that the Head Start regulations authorize Disclosure without consent.

The right to a copy of any of the Child Records Disclosed to third parties with your consent.

Upon your request, the right to a copy of any of the Child Records Disclosed to third parties without your consent, unless the Disclosure was in response to a subpoena and a court ordered that the subpoena, the contents of the subpoena, and the information in response to the subpoena not be Disclosed.

The right to review any written agreements between IZZI and third parties regarding Child Records Disclosed by IHSD to those third parties.

DISCLOSURES OF PII WITHOUT YOUR CONSENT:

IHSD is required to obtain your consent to Disclose your child’s PII from Child Records except as necessary to:

Officials within IZZI or acting for IZZI, such as contractors and subrecipients, if the official provides services for which IHSD would otherwise use employees, IZZI determines it is necessary for Head Start services, and IZZI maintains oversight with respect to the use, further Disclosure, and maintenance of Child Records, such as through a written agreement;

Officials within IZZI, acting for IZZI or from a federal or state entity, in connection with an audit or evaluation of education or child development programs, or for enforcement of or compliance with federal legal requirements of IZZI; provided IZZI maintains oversight with respect to the use, further Disclosure, and maintenance of child records, such as through a written agreement, including the destruction of the PII when no longer needed for the purpose of the Disclosure, except when the Disclosure is specifically authorized by federal law or by the responsible HHS official;

Officials within IZZI, acting for IZZI, or from a federal or state entity, to conduct a study to improve child and family outcomes, including improving the quality of programs, for, or on behalf of, IZZI, provided IZZI maintains oversight with respect to the use, further Disclosure, and maintenance of Child Records, such as through a written agreement, including the destruction of the PII when no longer needed for the purpose of the Disclosure;

Appropriate parties in order to address a disaster, health or safety emergency during the period of the emergency, or a serious health and safety risk such as a serious food allergy, if IZZI determines that Disclosing the PII from Child Records is necessary to protect the health or safety of children or other persons;

Comply with a judicial order or lawfully issued subpoena, provided IZZI makes a reasonable effort to notify the Parent about all such subpoenas and court orders in advance of the compliance therewith, unless:

A court has ordered that neither the subpoena, its contents, nor the information provided in response be Disclosed;

The Disclosure is in compliance with an expert court order obtained by the United States Attorney General (or designee not lower than an Assistant Attorney General) concerning investigations or prosecutions of an offense listed in 18 U.S.C. 2332b(g)(5)(B) or an act of domestic or international terrorism as defined in 18 U.S.C. 2331.

A Parent is a party to a court proceeding directly involving child abuse and neglect (as defined in section 3 of the Child Abuse Prevention and Treatment Act (42 U.S.C. 5101)) or dependency matters, and the order is issued in the context of that proceeding, additional notice to the Parent by IZZI is not required; or,

IZZI initiates legal action against a Parent or a Parent initiates legal action against IZZI, then IZZI may Disclose to the court, also without a court order or subpoena, the Child Records relevant for IZZI to act as plaintiff or defendant.

The Secretary of Agriculture or an authorized representative from the Food and Nutrition Service to conduct program monitoring, evaluations, and performance measurements for the Child and Adult Care Food Program under the Richard B. Russell National School Lunch Act or the Child Nutrition Act of 1966, if the results will be reported in an aggregate form that does not identify any individual;

A caseworker or other representative from a state, local, or tribal child welfare agency, who has the right to access a case plan for a child who is in foster care placement, when such agency is legally responsible for the child's care and protection, under state or tribal law, if the agency agrees in writing to protect PII, to use information from the child's case plan for specific purposes intended of addressing the child's needs, and to destroy information that is no longer needed for those purposes; and,

Appropriate parties in order to address suspected or known child maltreatment and is consistent with applicable federal, state, local, and tribal laws on reporting child abuse and neglect.