NOTE TO PATIENTS: This policy does not govern how we handle the information you provide to us while being treated as a patient of our clinic and other Protected Health Information (“PHI”) as defined under the Health Insurance Portability & Accountability Act and related federal and state laws and regulations (collectively referred to as “HIPAA”). ALL PROTECTED HEALTH INFORMATION IS GOVERNED BY OUR NOTICE OF PRIVACY PRACTICES. Please see that notice for information on how we handle PHI and your rights in regard to your PHI.
1. How We Collect Information
We may collect information about you by various means, including through our Services, directly from you in-person or when you contact us, and from your other providers or third parties.
2. Types of Information We Collect
In order to better provide you with our Services, we may collect the following categories of information:
- Contact information, such as your name, e-mail, phone number and mailing address;
- Survey information in response to questions we may send you through the Services, such as for research or feedback purposes;
- Communications between you and us, such as via e-mail, mail, phone or other channels when you contact our support team;
- Online User Activity described in the next section.
As noted above, any Protected Health Information (PHI) we collect is handled separately, subject to our HIPAA Notice of Privacy Practices. If you provide us with information regarding another individual, you represent that you have that person’s authorization and consent to give us his or her information and to permit us to use the information in accordance with this policy.
3. Online User Activity, Cookies, and Information Collected by Other Automated Means
Cookies are a commonly-used web technology that allows websites or mobile apps to store and retrieve certain information about a user’s system and track users’ online activities. We and our service providers may collect information about your use of our Services by such automated means, including but not limited to cookies, pixels, and other similar technologies. These tools can help us automatically identify you when you return to our Services. Cookies help us review traffic patterns, improve our Services, and determine what Services are popular.
When you use the Services, the information we may collect by automated means includes, for example:
- Usage Details about your interaction with our Services (such as the date and time of use, pages visited, features used);
- Device Information including the IP address and other details of a device that you use to connect with our Services (such as device type, model, and operating system information); and
- Location information where you choose to provide the website or app with access to information about your device’s location.
4. How We Use Information We Collect
We may use the information we obtain about you for purposes allowed by applicable laws, including:
- Provide our Services to you, including establishing and maintaining an account or user ID that is created for your use of our Services, and to process transactions;
- Respond to your requests, questions, and comments and provide customer support;
- Operate, evaluate and improve the products and services we offer (including to develop new services), and to diagnose or fix technology problems;
- Comply with and enforce as needed applicable legal requirements, industry standards, our policies, and our contractual rights; and
- Monitor the performance of our Services including metrics such as the number of users.
We may also use or share information in an anonymized or aggregate manner for purposes such as research, analysis, modeling, marketing, and advertising, as well as improvement of our Services.
5. How We Share Your Information
We will not disclose your personal information to third parties without your consent, except in the following circumstances.
- We may share your information as permitted by law, including, for example, with service providers that we believe need the information to perform a technology, business, or other professional function for us (examples include IT services, maintenance, and hosting of our Services, and other vendors). We only provide such vendors with information so they can perform their required functions on our behalf.
- We also may disclose information about you (i) if we are required to do so by law or legal process, (ii)when we believe disclosure is necessary to prevent harm or financial loss, (iii) in connection with an investigation of suspected or actual fraudulent or illegal activity; or (iv) under exigent circumstances to protect the personal safety of our staff, users or the public.
- We reserve the right to transfer the information we maintain in the event we sell or transfer all or a portion of our organization or assets. If we engage in such a sale or transfer, we will make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Website and Mobile ApplicationPrivacyPolicy.
Where appropriate, we will limit sharing of your information in accordance with the choices you have provided us and applicable law.
6. Your Privacy Choices
We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.
- Cookies: Web browsers may offer users the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites and mobile apps may not function correctly.
- Marketing: If you wish to opt-out of receiving any marketing emails or other such communications from us, please notify us as provided below. You may choose not to receive marketing emails from us by clicking on the unsubscribe link in the marketing emails you receive from us.
- Patient records: You are entitled under HIPAA to exercise certain rights regarding your PHI, such as access to patient records. For more information, please see our NOTICE OF PRIVACY PRACTICES.
7. Links to Other Websites and Third-Party Content
Our Services may contain links to other websites or apps. Please be aware that we are not responsible for the content or privacy practices of such other websites or apps, and we encourage you to be aware when you leave our Services and to read the privacy statements of any other website or app that collects personal information.
8. How We Protect Information
We endeavor to maintain reasonable administrative, technical, and physical safeguards designed to protect the personal information we maintain against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. However, we cannot ensure the security of any information you transmit to us, or guarantee that this information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures in the event of any compromise of personal information.
To the extent the law allows us to provide such notification via e-mail or conspicuous posting on the Services, you agree to accept notice in that form.
9. Healthcare Providers
If you (on behalf of yourself or your organization) are a healthcare provider under a contractual relationship with us to use these Services in connection with your practice, we may additionally collect your business contact information and other data regarding your use of our Services for analytics, marketing or promotional activities, to the extent permitted by law and our contractual relationship. This may include advertising products or services that may be of interest to you. In addition to communicating with you regarding your and your patients’ use of the Services, we may from time to time contact you to provide announcements, alerts, surveys, or other marketing or general communications. In order to improve our Services, we may be notified when you open an email from us or click on a link therein.
We do not knowingly collect personal data from children under the age of 13 for our Services. If you have reason to believe that a child under the age of 13 has provided personal information to us through our Services, please contact us and we will endeavor to delete that information from our systems. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will endeavor to delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us as directed below.
12. Contacting Us
NOTICE OF PRIVACY PRACTICES
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY. ANY REFERENCES IN THIS DOCUMENT TO MEDICAL PRACTICE, MEDICAL RECORDS, MEDICAL SERVICES, ETC. APPLY ALSO TO PSYCHOTHERAPY
Square 1 Clinics understands the importance of privacy and is committed to maintaining the confidentiality of your medical information. Square 1 Clinics makes a record of the medical care we provide and may receive such records from others. Square 1 Clinics uses these records to provide or enable other health care providers to provide quality medical care, to obtain payment for services provided to you as allowed by your health plan, and to enable Square 1 Clinics to meet professional and legal obligations to properly operate this medical practice. Square 1 Clinics is required by law to maintain the privacy of protected health information, to provide individuals with notice of our legal duties and privacy practices with respect to protected health information, and to notify affected individuals following a breach of unsecured protected health information. This notice describes how Square 1 Clinics may use and disclose your medical information. It also describes your rights and our legal obligations with respect to your medical information. If you have any questions about this Notice, please contact the Privacy Officer at (727) 295-1000.
TABLE OF CONTENTS
- How This Medical Practice May Use or Disclose Your Health Information
- When This Medical Practice May Not Use or Disclose Your Health Information
- Your Health Information Rights:
- Right to Request Special Privacy Protections
- Right to Request Confidential Communications
- Right to Inspect and Copy
- Right to Amend or Supplement
- Right to an Accounting of Disclosures
- Right to a Paper or Electronic Copy of this Notice
- Changes to this Notice of Privacy Practices
A. How This Medical Practice May Use or Disclose Your Health Information
This medical practice collects health information about you and stores it in a chart [and on a computer] [and in an electronic health record/personal health record]. This is your medical record. The medical record is the property of this medical practice, but the information in the medical record belongs to you. The law permits us to use or disclose your health information for the following purposes:
- Treatment. We use medical information about you to provide your medical care. We disclose medical information to our employees and others who are involved in providing the care you need. For example, we may share your medical information with other physicians or other health care providers who will provide services that we do not provide. Or we may share this information with a pharmacist who needs it to dispense a prescription to you, or a laboratory that performs a test. We may also disclose medical information to members of your family or others who can help you when you are sick or injured, or after you die.
- Payment. We use and disclose medical information about you to obtain payment for the services we provide. For example, we give your health plan the information it requires before it will pay us. We may also disclose information to other health care providers to assist them in obtaining payment for services they have provided to you.
- Care Operations. We may use and disclose medical information about you to operate this medical practice. For example, we may use and disclose this information to review and improve the quality of care we provide, or the competence and qualifications of our professional staff. Or we may use and disclose this information to get your health plan to authorize services or referrals. We may also use and disclose this information as necessary for medical reviews, legal services and audits, including fraud and abuse detection and compliance programs and business planning and management. We may also share your medical information with our “business associates,” such as our billing service, that perform administrative services for us. We have a written contract with each of these business associates that contains terms requiring them and their subcontractors to protect the confidentiality and security of your protected health information. We may also share your information with other health care providers, health care clearinghouses or health plans that have a relationship with you, when they request this information to help them with their quality assessment and improvement activities, their patient-safety activities, their population-based efforts to improve health or reduce health care costs, their protocol development, case management or care-coordination activities, their review of competence, qualifications and performance of health care professionals, their training programs, their accreditation, certification or licensing activities, or their health care fraud and abuse detection and compliance efforts.
- Appointment Reminders. We may use and disclose medical information to contact and remind you about appointments. If you are not home, we may leave this information on your answering machine or in a message left with the person answering the phone.
- Sign In Sheet. We may use and disclose medical information about you by having you sign in when you arrive at our office. We may also call out your name when we are ready to see you.
- Notification and Communication With Family. We may disclose your health information to notify or assist in notifying a family member, your personal representative or another person responsible for your care about your location, your general condition or, unless you had instructed us otherwise, in the event of your death. In the event of a disaster, we may disclose information to a relief organization so that they may coordinate these notification efforts. We may also disclose information to someone who is involved with your care or helps pay for your care. If you are able and available to agree or object, we will give you the opportunity to object prior to making these disclosures, although we may disclose this information in a disaster even over your objection if we believe it is necessary to respond to the emergency circumstances. If you are unable or unavailable to agree or object, our health professionals will use their best judgment in communication with your family and others.
- Marketing. Provided we do not receive any payment for making these communications, we may contact you to give you information about products or services related to your treatment, case management or care coordination, or to direct or recommend other treatments, therapies, health care providers or settings of care that may be of interest to you. We may similarly describe products or services provided by this practice and tell you which health plans this practice participates in. We may also encourage you to maintain a healthy lifestyle and get recommended tests, participate in a disease management program, provide you with small gifts, tell you about government sponsored health programs or encourage you to purchase a product or service when we see you, for which we may be paid. Finally, we may receive compensation which covers our cost of reminding you to take and refill your medication, or otherwise communicating about a drug or biologic that is currently prescribed for you. We will not otherwise use or disclose your medical information for marketing purposes or accept any payment for other marketing communications without your prior written authorization. The authorization will disclose whether we receive any compensation for any marketing activity you authorize, and we will stop any future marketing activity to the extent you revoke that authorization.
- Sale of Health Information. We will not sell your health information without your prior written authorization. The authorization will disclose that we will receive compensation for your health information if you authorize us to sell it, and we will stop any future sales of your information to the extent that you revoke that authorization.
- Required by Law. When required by law, we will use and disclose your health information, but we will limit our use or disclosure to the relevant requirements of the law. When the law requires us to report abuse, neglect or domestic violence, or respond to judicial or administrative proceedings, or to law enforcement officials, we will further comply with the requirement set forth below concerning those activities.
- Public Health. We may, and are sometimes required by law, to disclose your health information to public health authorities for purposes related to: preventing or controlling disease, injury or disability; reporting child, elder or dependent adult abuse or neglect; reporting domestic violence; reporting to the Food and Drug Administration problems with products and reactions to medications; and reporting disease or infection exposure. When we report suspected elder or dependent adult abuse or domestic violence, we will inform you or your personal representative promptly unless in our best professional judgment, we believe the notification would place you at risk of serious harm or would require informing a personal representative we believe is responsible for the abuse or harm.
- Health Oversight Activities. We may, and are sometimes required by law, to disclose your health information to health oversight agencies during audits, investigations, inspections, licensure and other proceedings, subject to the limitations imposed by law.
B. When This Medical Practice May Not Use or Disclose Your Health Information
Except as described in this Notice of Privacy Practices, this medical practice will, consistent with its legal obligations, not use or disclose health information which identifies you without your written authorization. If you do authorize this medical practice to use or disclose your health information for another purpose, you may revoke your authorization in writing at any time.
C. Your Health Information Rights
- Right to Request Special Privacy Protections. You have the right to request restrictions on certain uses and disclosures of your health information by a written request specifying what information you want to limit, and what limitations on our use or disclosure of that information you wish to have imposed. If you tell us not to disclose information to your commercial health plan concerning health care items or services for which you paid for in full out-of-pocket, we will abide by your request, unless we must disclose the information for treatment or legal reasons. We reserve the right to accept or reject any other request and will notify you of our decision.
- Right to Request Confidential Communications. You have the right to request that you receive your health information in a specific way or at a specific location. For example, you may ask that we send information to a particular email account or to your work address. We will comply with all reasonable requests submitted in writing which specify how or where you wish to receive these communications.
- Right to Inspect and Copy. You have the right to inspect and copy your health information, with limited exceptions. To access your medical information, you must submit a written request detailing what information you want access to, whether you want to inspect it or get a copy of it, and if you want a copy, your preferred form and format. We will provide copies in your requested form and format if it is readily producible, or we will provide you with an alternative format you find acceptable, or if we can’t agree and we maintain the record in an electronic format, your choice of a readable electronic or hardcopy format. We will also send a copy to any other person you designate in writing. We will charge a reasonable fee which covers our costs for labor, supplies, postage, and if requested and agreed to in advance, the cost of preparing an explanation or summary. We may deny your request under limited circumstances. If we deny your request to access your child’s records or the records of an incapacitated adult you are representing because we believe allowing access would be reasonably likely to cause substantial harm to the patient, you will have a right to appeal our decision. If we deny your request to access your psychotherapy notes, you will have the right to have them transferred to another mental health professional.
- Right to Amend or Supplement. You have a right to request that we amend your health information that you believe is incorrect or incomplete. You must make a request to amend in writing and include the reasons you believe the information is inaccurate or incomplete. We are not required to change your health information and will provide you with information about this medical practice’s denial and how you can disagree with the denial. We may deny your request if we do not have the information, if we did not create the information (unless the person or entity that created the information is no longer available to make the amendment), if you would not be permitted to inspect or copy the information at issue, or if the information is accurate and complete as is. If we deny your request, you may submit a written statement of your disagreement with that decision, and we may, in turn, prepare a written rebuttal. All information related to any request to amend will be maintained and disclosed in conjunction with any subsequent disclosure of the disputed information.
- Right to an Accounting of Disclosures. You have a right to receive an accounting of disclosures of your health information made by this medical practice, except that this medical practice does not have to account for the disclosures provided to you or pursuant to your written authorization, or as described in paragraphs 1 (treatment), 2 (payment), 3 (health care operations), 6 (notification and communication with family) and 8 (specialized government functions) of Section A of this Notice of Privacy Practices or disclosures for purposes of research or public health which exclude direct patient identifiers, or which are incident to a use or disclosure otherwise permitted or authorized by law, or the disclosures to a health oversight agency or law enforcement official to the extent this medical practice has received notice from that agency or official that providing this accounting would be reasonably likely to impede their activities.
- Right to a Paper or Electronic Copy of this Notice. You have a right to notice of our legal duties and privacy practices with respect to your health information, including a right to a paper copy of this Notice of Privacy Practices, even if you have previously requested its receipt by email. If you would like to have a more detailed explanation of these rights or if you would like to exercise one or more of these rights, contact our Privacy Officer listed at the top of this Notice of Privacy Practices.
D. Changes to this Notice of Privacy Practices
We reserve the right to amend this Notice of Privacy Practices at any time in the future. Until such amendment is made, we are required by law to comply with the terms of this Notice currently in effect. After an amendment is made, the revised Notice of Privacy Protections will apply to all protected health information that we maintain, regardless of when it was created or received. We will keep a copy of the current notice posted in our reception area, and a copy will be available at each appointment. We will also post the current notice on our website.
Complaints about this Notice of Privacy Practices or how this medical practice handles your health information should be directed to our Privacy Officer listed at the top of this Notice of Privacy Practices. If you are not satisfied with the way this office handles a complaint, you may submit a formal complaint using options available at hhs.gov. You will not be penalized in any way for filing a complaint.