Notice of Privacy Practices
Effective: March 15, 2013
To our clients: This notice describes how health information about you, as a client of this practice, may be used and disclosed, and how you can get access to your health information. This is required by the Privacy Regulations created as a result of the Health Insurance Portability and Accountability Act of 1996 (HIPAA).
Our commitment to your privacy
Our center is dedicated to maintaining the privacy of your health information. Mid Cities Women’s Clinic (MCWC) is required by law to maintain the confidentiality of your health information. MCWC realizes that these laws are complicated, but we must provide you with the following important information:
Use and disclosure of your health information in certain special circumstances:
The following circumstances may require us to use or disclose your health information:
Treatment: to provide, coordinate or manage your health care and related services. Mid Cities Women’s Clinic may consult with other health care providers regarding your treatment and coordinate and manage your health care with others. MCWC may use or disclosure protected health information about your treatment activities to another health care provider.
Health Care Operations: Mid Cities Women’s Clinic may use or disclose protected health information to allow us to improve the quality of care MCWC provides and to reduce health care costs, which may include training programs for our staff.
Cooperating with outside legal entities
To public health authorities and health oversight agencies that are authorized by law to collect information.
Lawsuits and similar proceedings in response to a court or administrative order.
If required to do so by a law enforcement official.
When necessary to reduce or prevent a serious threat to your health and safety or the health and safety of another individual or the public. Mid Cities Women’s Clinic will only make disclosures to a person or organization able to help prevent the threat.
If you are a member of U.S. or foreign military forces (including veterans) and if required by the appropriate authorities.
To federal officials for intelligence and national security activities authorized by law.
To correctional institutions or law enforcement officials if you are an inmate or under the custody of a law enforcement official.
For Workers Compensation and similar programs.
Your rights regarding your health information:
Communications. You can request that Mid Cities Women’s Clinic communicate with you about your health and related issues in a particular manner or at a certain location. For instance, you may ask that MCWC contact you at home, rather than work. MCWC will accommodate reasonable requests.
You can request a restriction in our use or disclosure of your health information for treatment or health care operations. Additionally, you have the right to request that Mid Cities Women’s Clinic restrict our disclosure of your health information to only certain individuals involved in your care, such as family members and friends. MCWC is not required to agree to your request; however, if we do agree, we are bound by our agreement except when otherwise required by law, in emergencies, or when the information is necessary to treat you.
You have the right to inspect and obtain a copy of the health information that may be used to make decisions about you, including client medical records and billing records, but not including psychotherapy notes. You must submit your request in writing to our Privacy Official.
You may ask us to amend your health information if you believe it is incorrect or incomplete, and as long as the information is kept by or for our practice. To request an amendment, your request must be made in writing and submitted to our Privacy Official. You must provide us with a reason that supports your request for the amendment.
Right to a copy of this notice. You are entitled to receive a copy of this Notice of Privacy Practices. You may ask us to give you a copy of this Notice at any time. To obtain a copy of this notice, contact our Privacy Official.
Right to file a complaint. If you believe your privacy rights have been violated, you may file a complaint with our practice or with the Secretary of the Department of Health and Human Services. To file a complaint with our practice, contact our Privacy Official. All complaints must be submitted in writing. You will not be penalized for filing a complaint.
Right to provide an authorization for other uses and disclosures. Our practice will obtain your written authorization for uses and disclosures that are not identified by this notice or permitted by applicable law.
In accordance with the standards of implementation specifications of 45 C.F.R. § 164.524, Provider may grant an individual access to inspect and obtain a copy of protected health information about the individual in a designated record set.
The designated record set that is subject to access by an individual is as follows:
The titles of the persons or offices responsible for receiving and processing requests for access by individuals are as follows:
Privacy Official: _also uses protected health information for the following reasons: (you may opt out of this authorization). Special initial authorization is required and attached.
Marketing; internal referral board, testimonials, pictures on bulletin board, sending newsletters or information unrelated to healthcare and other marketing materials.
If you have any questions regarding this notice or our health information privacy policies, please contact: B. Grace Schwenkmeyer, R.N., Privacy Official.
If B. Grace Schwenkmeyer is not available you make speak with Paula Odom, Executive Director.
You can reach the Privacy Official at:
A message may be left for our privacy official any time the clinic is open and your call will be returned within 7 business days.
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Sharing of Personal Information
We never sell, rent, lease or exchange your personal information with other organizations. We assure you that the identity of all who contact us through this Web site will be kept confidential.
We are committed to ensuring the security of your personal information. To prevent unauthorized access, maintain data accuracy, and ensure the proper use of information, we have established and implemented appropriate physical, electronic and managerial procedures to safeguard and secure the information we collect online.
Many Web sites place cookies on your hard drive. You can choose whether to accept cookies by changing the settings of your browser. Your browser can refuse all cookies, or show you when a cookie is being sent. If you choose not to accept these cookies, your experience at our site and other Web sites may be diminished and some features may not work as intended.
Links to Outside Sites
This Web site links to documents located on Web sites maintained by other organizations or individuals. Once you access a link to another Web site, please be aware that we are not responsible for the privacy practices or the content of such Web sites.
POLICY: COMMUNICATING PROTECTED HEALTH- INFORMATION VIA ELECTRONIC MAIL (EMAIL)
This policy describes procedures that govern an individual’s use of the Mid Cities Women’s Clinic’s (MCWC’S) email system. It also defines the steps that must be taken by MCWC’s clients who wish to engage in email with MCWC. This policy applies to the informational uses of email.
This policy applies to MCWC’s personnel and other persons affiliated with or authorized by MCWC to read, create, store, respond, or transmit information via a MCWC email system (Users). This policy also applies only to the use of email for both internal and external communications of PHI.
MCWC will permit email of unencrypted Protected Health Information (PHI) under limited circumstances where the appropriate safeguards described herein are applied.
Note: For the purpose of this policy, the term “Mid Cities Women’s Clinic (MCWC) electronic mail systems” does not refer to the physical location of the email system but its use by MCWC personnel to transmit PHI.
Communicating PHI via Email Internally
ü As a general rule, unencrypted email should not be used to communicate PHI.
ü Email is inherently less secure than other forms of communication. However,
email of PHI will be permitted at MCWC if certain safeguards are
ü MCWC will implement the following safeguards when communicating PHI in or attached to an email message:
- Email communications containing PHI about MCWC clients will be transmitted only on a MCWC email system and cannot be forwarded to an email account outside MCWC.
- PHI will not be transmitted in the subject line of the email message.
- The email message will include the following confidentiality notice.
- PHI that is specially protected (i.e., HIV/AIDS information, substance abuse treatment information, and mental health information) will not be communicated via email.
- If a document that contains PHI is attached to the message, the User should verify before transmitting the email message that he/she has attached the proper attachment.
- Before transmitting the email message, Users should double-check the message and any attachments to verify that no unintended information is included.
- Users who communicate PHI via email will comply with all other MCWC policies and procedures including, but not limited to, the Confidentiality of PHI Policy and the Minimum Necessary Policy. (See HIPAA Manual)
- Any User who is unsure whether an email message or attachment contains PHI should contact his/her supervisor or the HIPAA Privacy Officer before initiating the email communication.
Communicating PHI with Clients
ü Clients have the right to request that MCWC communicate with them via email.
ü If a client requests email communications containing their PHI, the individual receiving the request must obtain a completed Client Request for Email Communications form from the client AND must provide the client with the Important Information about Provider/Client Email form prior to processing the client’s request.
ü Both forms are available at MCWC’s website or located in hard copy at the MCWC’s office.
ü MCWC reserves the right to deny a client’s request to communicate with him/her via email. For example, a client’s request for email communications may be denied by MCWC if the client refuses to sign the Client Request for Email Communications.
ü If the client’s initial request to communicate via email is granted by MCWC, the client will be required to complete the following prior to engaging, for the first time, in licensed healthcare professional/client emails with MCWC:
- Respond to a test email with answers to a question specific to that client (i.e., the client’s date of birth, father’s name, mother’s name, etc.) to verify the client’s email address and identity; and
- Read and understand the Important Information about Client Email form confirming the client’s understanding of the risks of engaging in email communications with his/her licensed healthcare professional.
- No specially protected PHI (i.e., HIV/AIDS information, substance abuse treatment information, and mental health information) will be communicated via email even if the client’s request for email communications is granted.
- All completed Request for Email Communications forms will be maintained by the office processing the client’s request for a minimum of six (6) years.
- Approved requests are valid regardless of the time period as long as a hard copy of the form is maintained.
- An approved Request will be effective for only the Organization identified on the Request.
- The client must revoke each Request to discontinue email communications.
Ownership of Electronic Mail
ü The email systems at MCWC belong to MCWC, and are password protected.
ü MCWC’s personnel will adhere to this policy when sending PHI and MCWC’s email policy when sending email that doesn’t contain PHI.
ü MCWC reserves the right to override individual passwords and access the email system at any time for valid business purposes such as system maintenance and repair and security investigations.
Retention of Email
Once email has been printed and filed in a client’s chart, the email is to be deleted.
User means any personnel or other person authorized by MCWC to read, enter or update information created or transmitted via the electronic mail system.
Protected Health Information (PHI) means information, including demographic information that may identify the client, that relates to the past, present or future physical or mental health or condition of an individual, the provision of health care to an individual or the past, present or future payment for the provision of health care to an individual and identifies or could reasonably be used to identify the individual.
Personnel means employees, volunteers, trainees, and other persons whose conduct, in the performance of work for MCWC, is under the direct control of MCWC, whether or not they are paid by MCWC.
RESPONSIBILITY: HIPAA Privacy Officer
Important Information about Client Email
As a Client at Mid Cities Women’s Clinic (MCWC), you may request we communicate with you by electronic mail (email). This Fact Sheet will inform you about the risks of communicating with MCWC via email and how MCWC will use and disclose organization/ Client email.
PLEASE READ THIS INFORMATION CAREFULLY
As a Client at Mid Cities Women’s Clinic (MCWC), you may request we communicate with you by electronic mail (email). This Fact Sheet will inform you about the risks of communicating with MCWC via email and how MCWC will use and disclose MCWC/ Client email.
Mid Cities Women’s Clinic’s preferred method of communication is by telephone. Email will be used if unable to contact by phone at clients written request.
Email communications are two-way communications. However, responses and replies to emails sent to or received by either you or MCWC may be hours or days apart. This means that there could be a delay in receiving results or answers to questions that you may have regarding your condition.
If you have an urgent or an emergency situation, you should not rely solely on MCWC/Client email to request assistance or to describe the urgent or emergency situation. Instead, you should act as though MCWC/Client email is not available to you – and seek assistance by means consistent with your needs.
Email messages on your computer, your laptop, and/or your phone have inherent privacy risks – especially when your email access is provided through your employer or when access to your email messages is not password protected.
Unencrypted email provides as much privacy as a postcard. You should not communicate any information with MCWC that you would not want to be included on a postcard that is sent through the Post Office.
Email messages may be inadvertently missed. You can help minimize this risk by using only the email address that you have provided on your consent form to communicate with MCWC.
Email is sent at the touch of a button. Once sent, an email message cannot be recalled or cancelled. Errors in transmission, regardless of the sender’s caution, can occur.
In order to forward or to process and respond to your email, individuals at MCWC other than your licensed healthcare professional may read your email message. Your email message is not a private communication between you and your licensed healthcare professional.
Neither you nor the person reading your email can see the facial expressions or gestures or hear the voice of the sender. Email can be misinterpreted.
It is the policy of MCWC that your email messages and any and all responses to them become part of your medical record.
Client Request for Email Communication Consent Form
Client Name: ___________________________________Date of Birth: _____/_____/_____
Phone Number: _____________________ Email Address: ___________________________
Communications over the Internet and/or using the email system may not be encrypted and may not be secure. There is no assurance of confidentiality when communicated via email.
To request that Mid Cities Women’s Clinic (MCWC) communicate with you via email you must complete this form and return it to the MCWC office.
Please be advised that:
This request applies only to Mid Cities Women’s Clinic. If you would like to request to communicate via email with another organization, you must complete a separate request for that office.
MCWC will not communicate health information that is specially protected under state and federal law (e.g., HIV/AIDS, substance abuse, mental health information) via email.
I understand and agree to the following:
ü I certify the email address provided on this request is accurate, and that I accept full responsibility for messages sent to or from this address.
ü I have read and understand the backside of this form, which is Important Information about Client Email.
ü I understand and acknowledge that communications over the Internet and/or using the email system may not be encrypted and may not be secure; that there is no assurance of confidentiality of information when communicated this way.
ü I understand that all email communications in which I engage may be forwarded to other licensed healthcare providers within MCWC for purposes of providing treatment to me.
ü I agree to hold MCWC and individuals associated with it harmless from any and all claims and liabilities arising from or related to this request to communicate via email.
Signature of Client or Personal Representative Date
Mid Cities Women’s Clinic Representative Date