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PII Policy: Workload Uploads and File Confirmation

This policy is part of the Filevia policy set, alongside the Privacy Policy and the Data Handling and No-PII Agreement. It covers how workload uploads are kept free of participant names, and the one confirmation a processor may complete when opening a file that was imported under the earlier roster process. Filevia is operated by imHER Innovative Solutions, LLC, doing business as Filevia (formerly FILE READY).

1. The rule

Filevia never stores participant personally identifiable information (PII). Inside Filevia, a participant is an ID and a label, nothing more: files are identified by Participant ID and processor-chosen labels, and household members are referenced by number only (Member 1, Member 2), never by name. Because no name is stored, no name can be displayed, searched, or exported. The two sections below describe the only exceptions that prove the rule, and neither one stores the name.

2. Workload uploads by agency owners

An agency owner may upload a workload roster so Filevia can create and assign files. Filevia handles that upload as follows:

• The roster is read once, to create and assign the files. The uploaded file itself is never stored. Only the import counts and any exception rows (row number, Participant ID, and the reason) are kept, in the agency's import log.
• The Participant ID is the only identifier stored on a file. It is the tenant ID from the agency's own system, kept exactly as issued, including any leading zeros. Names are never stored on a file.
• The agency owner removes the First Name and Last Name columns before uploading, and Filevia refuses any upload that still contains a name column. Filevia also refuses or flags other identifying fields outside the approved import format, so no name enters Filevia through an upload at all.
• Columns Filevia does not recognize are discarded at import and flagged to the owner in the import results. They are not carried into Filevia.
• Files imported before uploads were held to this standard may carry a one-way verification fingerprint created from a last name at that time; the name itself was discarded then, too. The fingerprint can later confirm whether a typed name matches; it cannot be turned back into the name, and it is never displayed or exported. No new fingerprints are created.

3. Confirming a file when it is opened

A file imported under the earlier roster process may carry that file's verification fingerprint. Files imported under the current upload rules carry none, because uploads no longer include names. When the assigned processor opens a file that carries a fingerprint, Filevia asks the processor to confirm they have the right file before any work can be saved:

• The processor types the participant's last name exactly as it appears in the agency's system of record (for example, Yardi).
• Filevia compares the entry against the fingerprint and answers only "match" or "no match." The typed name is used for that comparison alone. It is never stored, displayed, or exported, and nothing about it is kept afterward.
• Saving work on the file stays blocked until the confirmation passes.
• A file the agency created by hand, with no roster behind it, carries no fingerprint and has no confirmation step. The same is true of every file imported under the current upload rules.

4. When the roster itself is wrong

A "no match" answer can mean the roster row was wrong, not the processor. In that case the agency owner can clear the check on that file, or correct the row and re-import it, and the processor can proceed. Clearing a check is recorded in the audit trail.

5. Everywhere else, the no-PII rule stands

The confirmation prompt in Section 3 is the only place a last name is ever typed into Filevia, and it is a comparison, never storage. Every other field follows the Data Handling and No-PII Agreement: names and other participant information must never be typed into file labels, checklist answers, work-log notes, messages, or document titles, and Filevia screens entries for participant-information patterns. Training and practice files use fictional data only.

6. Questions and mistakes

If participant information is entered anywhere it should not be, or you have a question about this policy, contact Filevia at filevia@imherstudio.com. Mistaken entries are handled under the incident section of the Data Handling and No-PII Agreement.