Privacy Policy

Eleanor Health community members, please read this notice closely. This notice covers: 1) The Eleanor Health privacy and confidentiality rights that you have as an Eleanor Health community member, when Eleanor Health is providing services as a treating provider. 2) How you and other authorized individuals can get access to protected health information (PHI) related to you and your care, when Eleanor Health is providing services as a treating provider. 3) How Eleanor Health collects, uses and discloses information about you online. When Eleanor Health provides services (e.g., case management and care coordination) on behalf of a health plan covered by regulations promulgated under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), it will comply with respective portions of the HIPAA regulations and the Business Associate Agreement executed separately with the health plan. Right to Confidentiality: You have the right to confidentiality at Eleanor Health. Your privacy and confidentiality are protected not just through HIPAA but also through 42cfr Part 2, a federal regulation that provides enhanced protections for people seeking treatment for addictions. Eleanor Health is committed to ensure your protected health information (name, birth date, diagnoses, etc) is not disclosed without legally sufficient reason. We will not disclose any PHI (personal protected health information like your name or birth date or address) or let anyone know that you are our patient unless:

You have completed a release of information and consented in writing. b. A court order has been received that we have to follow. c. There is a medical emergency and the disclosure is to medical personnel (i.e. to an EMT if you’ve fainted on our property). d. It is to a company that we have a Business Associates Agreement to provide services to (like our language translating service or our electronic health record). e. Authorized people auditing our care for quality. These authorized people could be internal from our Eleanor Health Quality team or external from a state or federal or insurance provider auditing arm. f. It is required under state law in an incident of suspected child abuse and neglect g. You have died, and we have to report your death to a public health authority. h. The US Department of Health and Human Services wants to investigate whether we’ve complied with HIPAA privacy rules.

For additional detail, please see our Notice of Privacy Practices below. Personal Information Eleanor Health’s website, www.eleanorhealth.com, does not collect any information that personally identifies you unless you knowingly and willingly provide it by sending it to us via e-mail. Eleanor Health only gathers non-personally identifiable information such as which pages were visited, the order in which they were visited, and which hyperlinks were clicked. Collecting such information involves the logging of IP addresses, operating system and browser software used by each visitor to the site. Although such information is not personally identifiable, we can determine from the IP address a visitor’s Internet Service Provider and the geographic location of his or her point of connectivity. The non-personally identifiable information we collect helps us, among other things, to monitor our internal operations, improve our services, identify the most popular areas of our site and determine the effectiveness of our services and promotional activities. It also helps us make available, more useful online services by performing statistical analyses of the behavior of the users of our site, and by measuring demographics and interests regarding specific areas of our site. Information Security and Quality We have implemented appropriate technical and managerial procedures to maintain information that is accurate, current, and complete. We will make a sincere effort to respond to your requests to correct information inaccuracies in a timely manner. We reserve the right to disclose information contained within our access logs concerning any user as we reasonably feel is necessary to protect our systems or business. We also reserve the right to report any suspected illegal activity to law enforcement for investigation or prosecution. Business Relationships The Eleanor Health website contains links to other websites. Eleanor health is not responsible for the privacy practices or the content of such web sites. Cookies There are various technologies, including one called “cookies”, which can be used to provide you with better or more useful interactions and information from a website. Cookies are small text files placed on the hard drive of a visitor’s computer if permitted by the browser. Cookies are only read by the server that placed them, and are unable to read data from hard disks, execute any code, send you viruses or destroy your files. Cookies allow preferences to be set, and allow the automatic processing of text, monitor, and language preferences, among other things, and help us track user preferences and the pages of the site which they visit. Please check the Help file of your browser to determine how to set these user preferences. Updating Please note that we review and modify our privacy practices from time to time, and that those practices are therefore subject to change. HIPAA Covered Entity Notice of Privacy Practices YOUR INFORMATION. YOUR RIGHTS. OUR RESPONSIBILITIES. This notice describes how medical information about you may be used and disclosed and how you can get access to this information as an Eleanor Health community member and patient of our medical practices. Please review it carefully. Your Rights You have the right to:

Get a copy of your paper or electronic medical record
Correct your paper or electronic medical record
Request confidential communication
Ask us to limit the information we share
Get a list of those with whom we’ve shared your information
Get a copy of this privacy notice
Choose someone to act for you
File a complaint if you believe your privacy rights have been violated

Your Choices You have some choices in the way that we use and share information as we:

Tell family and friends about your condition
Provide disaster relief
Include you in a hospital directory
Provide mental health care
Market our services and sell your information
Raise funds

Our Uses and Disclosures We may use and share your information as we:

Treat you
Run our organization
Bill for your services
Help with public health and safety issues
Do research
Comply with the law
Respond to organ and tissue donation requests
Work with a medical examiner or funeral director
Address workers’ compensation, law enforcement, and other government requests
Respond to lawsuits and legal actions

YOUR RIGHTS When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you. Get an electronic or paper copy of your medical record

You can ask to see or get an electronic or paper copy of your medical record and other health information we have about you. Ask us how to do this.
We will provide a copy or a summary of your health information, usually within 30 days of your request. We may charge a reasonable, cost-based fee.

Ask us to correct your medical record

You can ask us to correct health information about you that you think is incorrect or incomplete. Ask us how to do this.
We may say “no” to your request, but we’ll tell you why in writing within 60 days.

Request confidential communications

You can ask us to contact you in a specific way (for example, home or office phone) or to send mail to a different address.
We will say “yes” to all reasonable requests.

Ask us to limit what we use or share

You can ask us not to use or share certain health information for treatment, payment, or our operations. We are not required to agree to your request, and we may say “no” if it would affect your care.
If you pay for a service or health care item out-of-pocket in full, you can ask us not to share that information for the purpose of payment or our operations with your health insurer. We will say “yes” unless a law requires us to share that information.

Get a list of those with whom we’ve shared information

You can ask for a list (accounting) of the times we’ve shared your health information for six years prior to the date you ask, who we shared it with, and why.
We will include all the disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make). We’ll provide one accounting a year for free but will charge a reasonable, cost-based fee if you ask for another one within 12 months.

Get a copy of this privacy notice You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly. Choose someone to act for you

If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information.
We will make sure the person has this authority and can act for you before we take any action.

File a complaint if you feel your rights are violated

You can complain if you feel we have violated your rights by contacting us using the information listed under Contact Information.
You can file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/.
We will not retaliate against you for filing a complaint.

YOUR CHOICES For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, talk to us. Tell us what you want us to do, and we will follow your instructions. In these cases, you have both the right and choice to tell us to:

Share information with your family, close friends, or others involved in your care
Share information in a disaster relief situation
Include your information in a hospital directory

If you are not able to tell us your preference, for example if you are unconscious, we may go ahead and share your information if we believe it is in your best interest. We may also share your information when needed to lessen a serious and imminent threat to health or safety. In these cases we never share your information unless you give us written permission:

Substance abuse treatment records
Marketing purposes
Sale of your information
Most sharing of psychotherapy notes
Fundraising efforts

OUR USES AND DISCLOSURES How do we typically use or share your health information? We typically use or share your health information in the following ways. Treat you We can use your health information and share it with other professionals who are treating you. Example: A doctor treating you for an injury asks another doctor about your overall health condition. Run our organization We can use and share your health information to run our practice, improve your care, and contact you when necessary. Example: We use health information about you to manage your treatment and services. Bill for your services We can use and share your health information to bill and get payment from health plans or other entities. Example: We give information about you to your health insurance plan so it will pay for your services. HOW ELSE CAN WE USE OR SHARE YOUR HEALTH INFORMATION? We are allowed or required to share your information in other ways – usually in ways that contribute to the public good, such as public health and research. We have to meet many conditions in the law before we can share your information for these purposes. For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html. Help with public health and safety issues We can share health information about you for certain situations such as:

Preventing disease
Helping with product recalls
Reporting adverse reactions to medications
Reporting suspected abuse, neglect, or domestic violence
Preventing or reducing a serious threat to anyone’s health or safety

Do research We can use or share your information for health research. Comply with the law We will share information about you if state or federal laws require it, including with the Department of Health and Human Services if it wants to see that we’re complying with federal privacy law. Respond to organ and tissue donation requests We can share health information about you with organ procurement organizations. Work with a medical examiner or funeral director We can share health information with a coroner, medical examiner, or funeral director when an individual dies. Address workers’ compensation, law enforcement, and other government requests We can use or share health information about you:

For workers’ compensation claims
For law enforcement purposes or with a law enforcement official
With health oversight agencies for activities authorized by law
For special government functions such as military, national security, and presidential protective services

Respond to lawsuits and legal actions We can share health information about you in response to a court or administrative order, or in response to a subpoena. OUR RESPONSIBILITIES

We are required by law to maintain the privacy and security of your protected health information.
We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.
We must follow the duties and privacy practices described in this notice and give you a copy of it.
We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.

For more information see:www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html. CHANGES TO THE TERMS OF THIS NOTICE We can change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available upon request, in our office, and on our website. CONTACT INFORMATION For questions, requests for information, or more information about our privacy policy or concerns, please contact us at compliance@eleanorhealth.com.