Privacy Policies

CTP POLICY 10.4203

HIPAA PRIVACY POLICIES AND PROCEDURES

I. PURPOSE:
To mandate the implementation of reasonable and appropriate documentation requirements for the HIPAA Privacy Policies and Procedures.

II. POLICY:
Came to Pass Recovery will document and maintain HIPAA Privacy Policies and Procedures implemented to comply with the Privacy Rule in written (which may be electronic) form. Where necessary or appropriate, Came to Pass Recovery may develop additional policies, standards, and procedures or change its policies and procedures at any time, provided the changes are documented and are implemented in accordance with HIPAA regulations and the HIPAA Privacy Policies and Procedures.

III. PROCEDURE:
A. Came to Pass Recovery has implemented HIPAA Privacy Policies and Procedures designed to comply with applicable privacy laws.

B. Came to Pass Recovery shall make changes to its HIPAA Privacy Policies and Procedures as necessary and appropriate to comply with changes in the law.

C. Came to Pass Recovery shall also make changes to its HIPAA Privacy Policies and Procedures in the event Came to Pass Recovery determines to change its practices related to PHI.

D. Changes to the HIPAA Privacy Policies and Procedures shall be made only by authorized staff.

E. Came to Pass Recovery maintains all documentation required by applicable privacy laws, including, but not limited to, its HIPAA Privacy Policies and Procedures, the Notice of Privacy Practices, and documentation required to provide individuals with their privacy rights as set forth in this Policy, in written and/ or electronic format.

F. Came to Pass Recovery maintains such documentation for six (6) years from the date of its creation or the date when it was last in effect, whichever is later.

NOTICE OF PRIVACY PRACTICES

THIS NOTICE DESCRIBES HOW HEALTH INFORMATION MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

I. MY PLEDGE REGARDING HEALTH INFORMATION:

I understand that health information about you and your health care is personal. I am committed to protecting health information about you. I create a record of the care and services you receive from me. I need this record to provide you with quality care and to comply with certain legal requirements. This notice applies to all of the records of your care generated by this mental health care practice. This notice will tell you about the ways in which I may use and disclose health information about you.I also describe your rights to the health information I keep about you, and describe certain obligations I have regarding the use and disclosure of your health information. I am required by law to:

  1. Make sure that protected health information (“PHI”) that identifies you is kept private.
  2. Give you this notice of my legal duties and privacy practices with respect to health information.
  3. Follow the terms of the notice that is currently in effect.
  4. I can change the terms of this Notice, and such changes will apply to all information I have about you. The new Notice will be available upon request, in my office, and on our website.

II. HOW I MAY USE AND DISCLOSE HEALTH INFORMATION ABOUT YOU:

The following categories describe different ways that I use and disclose health information. For each category of uses or disclosures I will explain what I mean and try to give some examples. Not every use or disclosure in a category will be listed. However, all of the ways I am permitted to use and disclose information will fall within one of the categories.

For Treatment Payment, or Health Care Operations: Federal privacy rules (regulations) allow health care providers who have direct treatment relationship with the patient/client to use or disclose the patient/client’s personal health information without the patient’s written authorization, to carry out the health care provider’s own treatment, payment or health care operations. I may also disclose your protected health information for the treatment activities of any health care provider. This too can be done without your written authorization. For example, if a clinician were to consult with another licensed health care provider about your condition, we would be permitted to use and disclose your person health information, which is otherwise confidential, in order to assist the clinician in diagnosis and treatment of your mental health condition.

Disclosures for treatment purposes are not limited to the minimum necessary standard. Because therapists and other health care providers need access to the full record and/or full and complete information in order to provide quality care. The word “treatment” includes, among other things, the coordination and management of health care providers with a third party, consultations between health care providers and referrals of a patient for health care from one health care provider to another.

Lawsuits and Disputes: If you are involved in a lawsuit, I may disclose health information in response to a court or administrative order. I may also disclose health information about your child in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute, but only if efforts have been made to tell you about the request or to obtain an order protecting the information requested.

III. CERTAIN USES AND DISCLOSURES REQUIRE YOUR AUTHORIZATION:

  1. Psychotherapy Notes. I do keep “psychotherapy notes” as that term is defined in 45 CFR § 164.501, and any use or disclosure of such notes requires your Authorization unless the use or disclosure is:
    1. For my use in treating you.
    2. For my use in training or supervising mental health practitioners to help them improve their skills in group, joint, family, or individual counseling or therapy.
    3. For my use in defending myself in legal proceedings instituted by you.
    4. For use by the Secretary of Health and Human Services to investigate my compliance with HIPAA.
    5. Required by law and the use or disclosure is limited to the requirements of such law.
    6. Required by law for certain health oversight activities pertaining to the originator of the psychotherapy notes.
    7. Required by a coroner who is performing duties authorized by law.
    8. Required to help avert a serious threat to the health and safety of others.
  2. Marketing Purposes. As a psychotherapist, I will not use or disclose your PHI for marketing purposes.
  3. Sale of PHI. As a psychotherapist, I will not sell your PHI in the regular course of my business.

IV. CERTAIN USES AND DISCLOSURES DO NOT REQUIRE YOUR AUTHORIZATION.
Subject to certain limitations in the law, I can use and disclose your PHI without your Authorization for the following reasons:

  1. When disclosure is required by state or federal law, and the use or disclosure complies with and is limited to the Came to Pass Recovery 1813 N Main St Flagstaff, AZ 86004 Page 1 of 3 relevant requirements of such law.
  2. For public health activities, including reporting suspected child, elder, or dependent adult abuse, or preventing or reducing a serious threat to anyone’s health or safety.
  3. For health oversight activities, including audits and investigations.
  4. For judicial and administrative proceedings, including responding to a court or administrative order, although my preference is to obtain an Authorization from you before doing so.
  5. For law enforcement purposes, including reporting crimes occurring on my premises.
  6. To coroners or medical examiners, when such individuals are performing duties authorized by law.
  7. For research purposes, including studying and comparing the mental health of patients who received one form of therapy versus those who received another form of therapy for the same condition.
  8. Specialized government functions, including, ensuring the proper execution of military missions; protecting the President of the United States; conducting intelligence or counter-intelligence operations; or, helping to ensure the safety of those working within or housed in correctional institutions.
  9. For workers’ compensation purposes. Although my preference is to obtain an Authorization from you, I may provide your PHI in order to comply with workers’ compensation laws.
  10. Appointment reminders and health related benefits or services. I may use and disclose your PHI to contact you to remind you that you have an appointment with me. I may also use and disclose your PHI to tell you about treatment alternatives, or other health care services or benefits that I offer.

V. CERTAIN USES AND DISCLOSURES REQUIRE YOU TO HAVE THE OPPORTUNITY TO OBJECT.

  1. Disclosures to family, friends, or others. I may provide your PHI to a family member, friend, or other person that you indicate is involved in your care or the payment for your health care, unless you object in whole or in part. The opportunity to consent may be obtained retroactively in emergency situations.

VI. YOU HAVE THE FOLLOWING RIGHTS WITH RESPECT TO YOUR PHI:

  1. The Right to Request Limits on Uses and Disclosures of Your PHI. You have the right to ask me not to use or disclose certain PHI for treatment, payment, or health care operations purposes. I am not required to agree to your request, and I may say “no” if I believe it would affect your health care.
  2. The Right to Request Restrictions for Out-of-Pocket Expenses Paid for In Full. You have the right to request restrictions on disclosures of your PHI to health plans for payment or health care operations purposes if the PHI pertains solely to a health care item or a health care service that you have paid for out-of-pocket in full.
  3. The Right to Choose How I Send PHI to You. You have the right to ask me to contact you in a specific way (for example, home or office phone) or to send mail to a different address, and I will agree to all reasonable requests.
  4. The Right to See and Get Copies of Your PHI. Other than “psychotherapy notes,” you have the right to get an electronic or paper copy of your medical record and other information that I have about you. I will provide you with a copy of your record, or a summary of it, if you agree to receive a summary, within 30 days of receiving your written request, and I may charge a reasonable, cost based fee for doing so.
  5. The Right to Get a List of the Disclosures I Have Made.You have the right to request a list of instances in which I have disclosed your PHI for purposes other than treatment, payment, or health care operations, or for which you provided me with an Authorization. I will respond to your request for an accounting of disclosures within 60 days of receiving your request. The list I will give you will include disclosures made in the last six years unless you request a shorter time. I will provide the list to you at no charge, but if you make more than one request in the same year, I will charge you a reasonable cost based fee for each additional request.
  6. The Right to Correct or Update Your PHI. If you believe that there is a mistake in your PHI, or that a piece of important information is missing from your PHI, you have the right to request that I correct the existing information or add the missing information. I may say “no” to your request, but I will tell you why in writing within 60 days of receiving your request.
  7. The Right to Get a Paper or Electronic Copy of this Notice. You have the right get a paper copy of this Notice, and you have the right to get a copy of this notice by e-mail. And, even if you have agreed to receive this Notice via e-mail, you also have the right to request a paper copy of it.

VII. EFFECTIVE DATE OF THIS NOTICE

  1. This notice went into effect on the first date of services ith Came to Pass Recovery, 1813 N Main St Flagstaff, AZ 86004. Page 2 of 3 Acknowledgement of Receipt of Privacy Notice Under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), you have certain rights regarding the use and disclosure of your protected health information. By signing below, you are acknowledging that you have received a copy of HIPAA Notice of Privacy Practices.

Website Privacy

Came to Pass Recovery is committed to protecting your privacy and developing technology that gives you the most powerful and safe online experience. This Statement of Privacy applies to the Came to Pass Recovery website (https://cametopassrecovery.com/) and governs data collection and usage. By using the Came to Pass Recovery website, you consent to the data practices described in this statement.

COLLECTION OF YOUR PERSONAL INFORMATION

Came to Pass Recovery collects personally identifiable information, such as your e-mail address, name, home or work address or telephone number. Came to Pass Recovery also collects anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, preferences, interests and favorites.

There is also information about your computer hardware and software that is automatically collected by Came to Pass Recovery. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used by Came to Pass Recovery for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Came to Pass Recovery website.

Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through Came to Pass Recovery public message boards, this information may be collected and used by others. Note: Came to Pass Recovery does not read any of your private online communications.

Came to Pass Recovery encourages you to review the privacy statements of websites you choose to link to from Came to Pass Recovery so that you can understand how those websites collect, use and share your information. Came to Pass Recovery is not responsible for the privacy statements or other content on websites outside of the Came to Pass Recovery and Came to Pass Recovery family of websites.

USE OF YOUR PERSONAL INFORMATION

Came to Pass Recovery collects and uses your personal information to operate the Came to Pass Recovery website and deliver the services you have requested. Came to Pass Recovery also uses your personally identifiable information to inform you of other products or services available from Came to Pass Recovery and its affiliates. Came to Pass Recovery may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.

Came to Pass Recovery does not sell, rent or lease its customer lists to third parties. Came to Pass Recovery may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party. In addition, Came to Pass Recovery may share data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to Came to Pass Recovery, and they are required to maintain the confidentiality of your information.

Came to Pass Recovery does not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent.

Came to Pass Recovery keeps track of the websites and pages our customers visit within Came to Pass Recovery, in order to determine what Came to Pass Recovery services are the most popular. This data is used to deliver customized content and advertising within Came to Pass Recovery to customers whose behavior indicates that they are interested in a particular subject area.

Came to Pass Recovery websites will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Came to Pass Recovery or the site; (b) protect and defend the rights or property of Came to Pass Recovery; and, (c) act under exigent circumstances to protect the personal safety of users of Came to Pass Recovery, or the public.

USE OF COOKIES

The Came to Pass Recovery website use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a webpage server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalize Came to Pass Recovery pages, or register with Came to Pass Recovery site or services, a cookie helps Came to Pass Recovery to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Came to Pass Recovery web site, the information you previously provided can be retrieved, so you can easily use the Came to Pass Recovery features that you customized.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Came to Pass Recovery services or websites you visit.

SECURITY OF YOUR PERSONAL INFORMATION

Came to Pass Recovery secures your personal information from unauthorized access, use or disclosure. Came to Pass Recovery secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

CHANGES TO THIS STATEMENT

Came to Pass Recovery will occasionally update this Statement of Privacy to reflect company and customer feedback. Came to Pass Recovery encourages you to periodically review this Statement to be informed of how Came to Pass Recovery is protecting your information.