Policy Effective December, 2017
At Family Care Path (“FCP”), we understand, acknowledge and respect your right to privacy and the concerns you may have with regards to the privacy and security of your information. We are committed to respecting your data and information, and we are required by law to protect your information and confidentiality in particular ways. This Policy provides information about how FCP or our affiliates may use your information and healthcare related data, including as it relates to the use of FCP’s products, services, networks, systems, or websites, including those provided by third parties (the “Services”). As used in this Policy, “you” means any user of our products, services, websites, or networks, including any customers, patients, providers, family members or other general users of our products, services, or website. Your use or access to the Services
I. GENERAL USE OF INFORMATION
II. FCP USE AND DISCLOSE OF HEALTH INFORMATION
We may use your healthcare and other information within FCP and disclose your information outside FCP for the reasons described in this Policy. The following describe some of the ways that we may use and disclose your information.
A. Medical Treatment and FCP Services. Doctors or other caregivers affiliated with FCP, including those not employed by FCP, may exchange information about you with FCP employees or affiliates in association with the delivery of the Services. In connection with the health care that these health care practitioners may provide to you outside of FCP, they may also provide you with their own additional privacy policies or notices related to their practices, and in such a case such terms will apply. Other hospitals, doctors, entities, foundations, facilities, and services may share your information with each other for reasons of treatment, payment, and health care operations, including but not limited to as further described below.
B. Treatment. We may use your information to provide you with health care services. We may disclose your information to doctors, nurses, technicians, medical or nursing students, or other persons affiliated with FCP who need the information to provide you with Services, which may involve communicating with doctors and others not employed by us. We also may disclose your information to people outside FCP who may be involved in your health care, such as treating doctors, home care providers, pharmacies, drug or medical device experts, and family members.
C. Payment. We may use and disclose your information so that the health care you receive can be billed and paid for by you, your insurance company, or another third party. We may also tell your health plan about services you are going to receive so we can get prior payment approval or learn if your plan will pay for the treatment.
D. Health Care Operations. We may use your information and disclose it outside FCP for our health care or other operations. These uses and disclosures help us operate FCP to maintain and improve Services. We may disclose information to doctors, nurses, technicians, medical students, and other persons affiliated with FCP for learning and quality improvement purposes. We may remove information that identifies you so people outside FCP can study your health data or other wise use the data without identifying you.
E. Improvement and Development of Products and Services. We may use your information, including in combination with other customers and patient information, to monitor, troubleshoot or improve existing products and services, or to develop new and additional product and service offerings.
F. Authorized Third-Party Vendors and Service Providers. We may share your information with third-party contractors, vendors or service-providers that help us create or offer our Services, including but not limited to video conferencing, telemedicine, billing, payment processing, customer service, payors, email deployment, business analytics, marketing (including but not limited to advertising, attribution, mobile marketing, optimization and retargeting), performance monitoring, hosting, and data processing.
G. Corporate Affiliates and Transfers. We may share your information with our corporate affiliates that are subject to this policy, and in connection with corporate transactions, including but not limited to collaboration agreements, mergers, consolidations, asset sale or other transaction or disposition of the business.
H. Contacting You. We may use and disclose information to reach you about your account, appointments and other matters. We may contact you by mail, telephone or email. For example, we may leave voice messages at the telephone number you provide us with, and we may respond to your email address. We may use and disclose information about you to send you mailings about health-related products and services available at FCP.
I. Health Information Exchanges. We may participate in certain information exchanges whereby we may disclose your information, as permitted by law, to other health care providers or entities for treatment, payment, or health care operations purposes.
J. Organized Health Care Arrangements. We may participate in joint arrangements with other health care providers or health care entities whereby we may use or disclose your information, as permitted by law, to participate in joint activities involving treatment, review of health care decisions, quality assessment or improvement activities, or payment activities.
K. Legal Matters. We may disclose information about you outside FCP when required to do so by federal, state, or local law, or by the court process. We may disclose information about you for public health reasons, like reporting births, deaths, child abuse or neglect, reactions to medications or problems with medical products. We may release information to help control the spread of disease or to notify a person whose health or safety may be threatened. We may disclose information to a health oversight agency for activities authorized by law, such as for audits, investigations, inspections, and licensure.
III. YOUR RIGHTS REGARDING YOUR HEALTH INFORMATION
FCP may have access to your health information in the form of Protected Health Information (“PHI”). In such a case you may have rights ion accordance with applicable regulations related to such information. In the delivery of Services to you by FCP, if FCP has access to your PHI, and if required by applicable regulation, then you will have the following rights. Note: FCP’s ability to provide you the following is subject to its ability to access and make available such information in a commercially reasonable manner.
A. Right to Accounting. You may request an accounting, which is a listing of the entities or persons (other than yourself) to whom FCP has disclosed your information without your written authorization. The accounting would not include disclosures for treatment, payment, health care operations, and certain other disclosures exempted by law. Your request for an accounting of disclosures must be in writing, signed, and dated. It must identify the time period of the disclosures and the FCP facility that maintains the records about which you are requesting the accounting. We will not list disclosures made earlier than six (6) years before your request. Your request should indicate the form in which you want the list (for example, on paper or electronically). You must submit your written request to Family Care Path, Inc. 1801 E. 9th Street, Suite 1700, Cleveland, Ohio 44114, Attn: Privacy Officer. We will respond to you within 60 days. We will give you the first listing within any 12-month period free of charge, but we will charge you for all other accountings requested within the same 12 months.
B. Right to Amend. If you feel that information we have about you is incorrect or incomplete, you have the right to ask us to amend your medical records. Your request for an amendment must be in writing, signed, and dated. It must specify the records you wish to amend and give the reason for your request. You must address your request to Family Care Path, Inc. 1801 E. 9th Street, Suite 1700, Cleveland, Ohio 44114, Attn: Privacy Officer. FCP will respond to you within 60 days. We may deny your request; if we do, we will tell you why and explain your options.
C. Right to Inspect and Obtain Copy. You have the right to inspect and obtain a copy of your completed health records unless your doctor believes that disclosure of that information to you could harm you. You may not see or get a copy of information gathered for a legal proceeding or certain research records while the research is ongoing. Your request to inspect or obtain a copy of the records must be submitted in writing, signed and dated, to Family Care Path, Inc. 1801 E. 9th Street, Suite 1700, Cleveland, Ohio 44114, Attn: Privacy Officer. (Requests for billing records should be sent to the billing department.) We may charge a fee for processing your request. If FCP denies your request to inspect or obtain a copy of the records, you may appeal the denial in writing to Family Care Path, Inc. 1801 E. 9th Street, Suite 1700, Cleveland, Ohio 44114, Attn: Privacy Officer
IV. USE OF FCP WEBSITE OR SYSTEMS.
A. Forms. Our website may contains forms to collect telephone numbers, email addresses or return addresses that are required so that we can supply requested information to you, and in other cases, names and addresses are required to process credit card payments. After you fill out a form, we may use such information to contact you with follow-up information, or for payment information or collection purposes.
B. User Name and Password. In the event you access any service requiring a User Name and Password, you are solely responsible for keeping such User Name and Password strictly confidential.
C. IP Addresses. Our Web servers or system may automatically collect the IP (which stands for Internet Protocol) address of the computers that access our site. An IP address is a number that is assigned to your computer when you access the Internet. It is not truly personally identifiable information because many different individuals can access the Internet via the same computer. We may use this information in aggregate form to understand how our site is being used and how we can better serve visitors. Please note that although such information is not personally identifiable, we can determine from an IP address a visitor’s Internet Service Provider and the geographic location of his or her point of connectivity.
D. First Party Cookies. We collect information about visitors to our site using “first party cookies”, which are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser. Cookies are never associated with specific personal identities. First party cookies are distinct from third party cookies in that they are created and directly served by the company hosting the website.
E. We may use other cookies, on our site, including: 1) persistent cookies to recognize a repeat visitor, enabling us the opportunity to offer the visitor a set of services or information requested in a previous visit, or; 2) session cookies to track a visitor’s path through our site during a visit, to help us understand how people use our site. You can delete such cookies at any time. The “help” section, located on the toolbar of most browsers, will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie or how to disable cookies altogether. Since cookies allow you to take full advantage of some of our website’s best features, we recommend that you leave them turned on.
V. SECURITY OF YOUR INFORMATION
We use reasonable measures to help protect information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be completely secure. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information. FCP periodically reviews and modifies, where appropriate, its security policies and procedures, and may do so without notice.
VI. INTERNATIONAL USERS
FCP products and services are intended for use by people over the age of 18, and we do no knowingly allow individuals under the age of 18 to create accounts that allow access to our products or services.
If you believe your privacy rights have been violated, you may file a complaint with the Privacy Officer at Family Care. To file a complaint with FCP, you must submit your complaint in writing to the Family Care Path, Inc. 1801 E. 9th Street, Suite 1700, Cleveland, Ohio 44114, Attn: Privacy Officer. You will not be penalized for filing a complaint.
IX. CHANGES TO THIS POLICY
FCP may change this Policy at any time. Any change in the Policy could apply to medical information we already have about you, as well as any information we receive in the future. The effective date of the Policy is the date indicated on this document, or the date the Policy is posted to a FCP website.
If you have questions about this Policy, or which to obtain a paper copy of this Policy, you may call the Family Care Path, Inc. 1801 E. 9th Street, Suite 1700, Cleveland, Ohio 44114, Attn: Privacy Officer or at 216-228-9619.
You have the right to a paper copy of this Policy. You may ask us to give you a copy of this Policy at any time. Even if you have agreed to receive this Policy electronically, you are still entitled to a paper copy.
NOTICE: If you send information to Family Care Path via email, please know that your message may be sent in an unencrypted email. An unencrypted email means there is a risk that the information in the email and any attachments could potentially be read by a third party when it is sent through the internet.