Housing Authority

Housing Authority of Clackamas County

A. Who May Request

Current and former participants in HACC’s rent assistance or public housing programs may request access to their own client file. This includes:

1. Current Program Participants: Any individual currently participating in the program may request their file at any time.  This includes households who are currently receiving assistance, pending approval for assistance, or on a waiting list.
2. Former Program Participants: Individuals who previously participated in the program may request their file according to the required document retention schedule after termination or voluntary exit.
3. Household Members: Adult household members listed on the lease and assistance documents may request access to records that pertain to them specifically. Access to records of other household members requires written authorization from that household member or documentation of legal authority.
4. Authorized Representatives: Individuals authorized to act on behalf of a client may request records as outlined in Appendix A of this policy.

Note: Requests from landlords, property managers, or other third parties are not considered client access requests and will be processed according to applicable regulations and authorization requirements.

This policy does not apply to public records requests or requests for records made by and through legal process.

B. What Records Are Available

Clients may request specific records or their “client file.” The client file includes all documents related to the client's application, eligibility, and participation in the program. Clients will receive copies of the documents (not originals) unless directed by court order. 

Clients may access:

• Initial application and all supporting documentation
• Income certifications and recertifications
• Verification documents (pay stubs, benefit letters, bank statements)
• Rent calculation worksheets and subsidy determinations
• Housing Assistance Payment (HAP) contracts
• Request for Tenancy Approval (RFTA) forms
• Housing Quality Standards (HQS) inspection reports for their unit
• Written correspondence (letters and emails) between the agency and the client
• Notices of adverse action or termination
• Informal hearing records and decisions
• Reasonable accommodation requests and determinations
• Forms signed by the client (HUD-9886, consent forms, etc.)

Excluded or Restricted Records:

The following materials may be excluded from client access or require special handling:

1. Third-Party Confidential Information: Verification forms or communications from third parties (employers, financial institutions, medical providers) that contain confidentiality restrictions or proprietary information may be redacted or summarized to protect the third party's interests while providing the client with substantive information.
2. Ongoing Investigation Materials: Documents related to active fraud investigations, criminal investigations, or pending litigation may be withheld until the matter is concluded, as disclosure could compromise the investigation or legal proceedings.
3. Internal Deliberative Materials: Preliminary notes, draft determinations, or internal staff communications that do not represent final agency action or decisions are not part of the official client file.
4. Other Household Members' Information: Information specific to other household members (individual income verifications, background checks, personal correspondence) will be redacted unless:
   • The requesting client has written authorization from that household member, OR
   • The requesting client provides documentation of legal authority (guardianship, power of attorney), OR
   • The information is jointly relevant to the household's assistance determination
5. Information Prohibited by Law: Any information that federal or state law prohibits from disclosure.

Example: A client requests their file. The file contains income verification for both the client and their adult son who lives in the household. The agency will provide all documents related to the client's income and the family's overall eligibility determination, but will redact the son's individual pay stubs unless the son provides written consent for release.

C. Request Process

How to Submit a Request:

Clients may request access to their records through any of the following methods:

1. Email: Send request form to hacc@clackamas.us. Please use the subject line “Client Records Request”.

2. In Person or In Writing: Visit during business hours or submit a written request by mail to:

   Housing Authority of Clackamas County
   13930  Gain Street
   Oregon City, OR 97045

3. Phone: Call 503-655-8267 to request records (identity verification required)
4. Online: Please submit the request via the online form.  If you need assistance in completing the form, please call 503-655-8267 or visit the Housing Authority office during business hours. 

Required Information:

To help us process a request efficiently, clients should use the form on our website or provide:

• Full name as it appears on program records
• Date of birth or last four digits of Social Security Number (for verification purposes)
• Current contact information (phone number and/or email)
• Specific records requested, if known (e.g., "all income certifications from 2024" or "most recent inspection report")
• Preferred method of receiving records (pick up, mail, secure email)

Note: If the request is not specific, the client file for the prior 18 months will be provided.

Verification of Identity:

To protect client confidentiality, the agency will verify the identity of the requestor before releasing records:

• In-person requests: Valid government-issued photo identification (driver's license, state ID, passport)
• Written or email requests: The agency may contact the client at the phone number or address on file to verify the request
• Phone requests: Security questions based on information in the file (address, household composition, etc.)

D. Response Timeline

Standard Timeline:

The agency will respond to client record requests within five (5) business days of receiving a complete request. "Business days" are defined as Monday through Thursday, excluding county, state and federal holidays.

The response will include either:

• The requested records
• Notice that records are ready for pickup and location
• Notice that records will be mailed on a specific date
• Explanation if any records are not available or are excluded with legal basis

When Delays May Occur:

If the agency cannot provide the records within the standard timeline due to unusual circumstances, the agency will:

1. Notify the client within the initial response period
2. Explain the reason for the delay (e.g., voluminous records, need to consult with legal counsel, staff absence)
3. Provide an estimated date when records will be available
4. Provide a partial response if some records are immediately available
5. Provide referral to the public records request process as appropriate

E. Fees

HACC does not charge clients for copies of their own records. Clients may receive one complete copy of their file at no cost once per year. Additional copies within the same year may be subject to the Clackamas County public records request fee schedule.

F. Method of Delivery

Available Options:

Clients may choose how they would like to receive their records:

1. In-Person Pickup:
   • Records will be available at HACC Admin Office during business hours
   • Client must show photo identification
   • Records will be held for 30 days before being returned to the file
2. U.S. Mail:
   • Records will be mailed to the address on file or an alternate address specified by the client
   • If records are sent to an alternate address, the agency will confirm the request with the client using contact information on file
   • Sent via First Class Mail in a sealed envelope marked "Confidential"
3. Secure Email:
   • Client must confirm email address
   • Sent as password-protected PDF files
   • Password will be provided separately via phone call

Questions or Concerns

If you have questions about accessing your records or believe your request was not handled appropriately, please contact:

Michell Paresi

mparesi@clackamas.us
503-655-8267

In case of conflict between this policy and applicable law, the law shall prevail. 

Effective Date: 11/01/2025
Last Revised: 11/01/2025
Next Review Date: 11/01/2026

Appendix A

Authorized Representative Requests

An authorized representative is an individual who has legal authority to act on behalf of a client or has been designated by the client to receive information from their file. The following individuals may qualify as authorized representatives:

1. Individuals with Legal Authority

• Court-Appointed Guardian or Conservator
• Power of Attorney Holder
• Legal Representative of Estate
• Parent or Legal Guardian of a Minor

2. Client-Designated Representatives

• Authorized Representative via HUD Form 9886
• Form must specify the authorized individual by name
• Form must indicate what information may be released
• Authorization remains valid until revoked by client or specified expiration date 

Required Documentation

To establish authority to act as a representative, appropriate documentation must be provided and verified.  For individuals with legal authority, documentation may be reviewed by HACC counsel to ensure authorization.  If you do not have a completed HUD Form 9886 and are unsure what documentation to provide, please contact Michell Paresi (mparesi@clackamas.us or 503-655-8267).

Response Timeline

Requests from authorized representatives will be processed within ten (10) business days of receiving complete request with valid authorization documents.  This timeline is slightly longer than client access requests due to the additional verification requirements.

When Delays May Occur:

If the agency cannot provide the records within the standard timeline due to unusual circumstances, the agency will:

1. Notify the client within the initial response period
2. Explain the reason for the delay (e.g., voluminous records, need to consult with legal counsel, staff absence)
3. Provide an estimated date when records will be available
4. Provide a partial response if some records are immediately available
5. Provide referral to the public records request process as appropriate

Client's Right to Revoke

Clients may revoke authorization at any time by:

• Submitting written revocation to the agency
• Sending letter or email stating authorization is revoked
• Appearing in person and signing revocation

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