FileviaData Handling and No-PII Agreement
This Data Handling and No-PII Agreement (the "Exhibit") is part of the Agency Services Agreement between imHER Innovative Solutions, LLC, doing business as Filevia (formerly FILE READY) ("Filevia"), and the agency ("Agency"). The Agency accepts it during onboarding, before activation.
1. The rule
Filevia is a label-only system. The Agency will use Filevia with processor-chosen file labels only and will never enter participant personal information into the app. This rule applies to every user, every field, and every upload, including file labels, checklist answers, work-log notes, support questions, team messages, document titles, and file names.
2. What counts as a label
A label is an identifier the Agency's processors already use in their own tracker system, such as a Participant ID (leading zeros kept). A label must never be a Social Security number or be shaped like one, and must not contain a name, address, or date of birth.
3. Prohibited information
The Agency will not enter, upload, or store in Filevia:
- Participant or household member names
- Social Security numbers or ITINs, in whole or in part
- Dates of birth
- Street addresses, unit numbers, or other location details tied to a person
- Phone numbers or personal email addresses of participants
- Bank account, payment card, or benefit card numbers
- Medical or disability details about an identified person
- Any document whose content is a participant record, except reference-only handbooks and published program guidance (see Section 4)
4. Reference-only material
Program handbooks, advisory documents, and worked examples published by a housing authority are resources, not participant records. When such a document trips the app's participant-pattern screening, Filevia stores it flagged as reference-only: it is never indexed, never searchable by the in-app assistant, and never usable in processing or training spaces. The Agency will keep genuine participant records out of its uploads entirely; reference-only is not a route for case documents.
5. Agency promises
The Agency agrees to:
- Train every user on this Exhibit before they process files in Filevia, and use the app's own training requirement setting as directed.
- Keep access invite-only: no shared accounts, no shared invite codes, and two-factor sign-in on for every user.
- Remove user access promptly when a team member leaves, using the app's deactivate and removal controls.
- Keep its own systems (tracker, document storage, email) as the systems of record for participant information. Filevia is never the system of record for participant data.
6. Incidents
If the Agency believes participant personal information was entered into Filevia by mistake, the Agency will notify Filevia at filevia@imherstudio.com the same business day, identify the file label and field involved, and stop further use of that file until Filevia confirms removal. Filevia will remove the information, check audit records and backups for copies, and confirm completion to the Agency.
7. Filevia's side
Filevia will: screen typed fields and intake submissions for participant-record patterns; keep agencies' data separated server-side; maintain an audit trail of key actions; provide the morning digest and notifications using labels and dates only; and, on an agency's permanent departure, delete its stored profile photos and uploaded documents and scrub its saved backups and audit-trail emails, as described in the Privacy Policy.
8. Signatures
The Agency signs this Exhibit on the Filevia signing page during onboarding; the typed name there is the agency's electronic signature, and the signed acknowledgment is filed in the platform owner's File Cabinet. Filevia (imHER Innovative Solutions, LLC) accepts the Exhibit when the agency's acknowledgment is filed.