Your privacy is a primary concern at Interface Children & Family Services (Interface). We are committed to ensuring the highest level of confidentiality and security, not just on our Web site, but in all our interactions with clients and their families. This policy addresses how Interface collects, uses, protects or otherwise handles your personally identifiable information in accordance with the Interface public website (ICFS.ORG) and client information. Personally identifiable information, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. By using INTERFACE websites, you consent to the data practices described in this statement.
Additionally, internal policies and procedures help protect your privacy by limiting staff access to your personal information. When we ask for personal information, it is done with the goal of responding to the needs that you directly communicate to us. Our intention is to send e-mail only to persons or organizations that have chosen to receive such e-mails. You have the right, at any time, to stop receipt of communications from us.
COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION
INTERFACE may collect information from you when you subscribe to a mailing list, fill out a form, respond to a survey or enter information on the site. In these instances, you may be asked to provide your name, email address or other details. INTERFACE encourages you to review the privacy statements of other websites that you choose to link to from INTERFACE so that you can understand how those sites collect, use and share your information. INTERFACE is not responsible for the privacy statements or other content on such websites not operated by INTERFACE.
USE OF PERSONALLY IDENTIFIABLE INFORMATION
INTERFACE may use the information collected from you to send periodic emails and newsletters, or to tailor the website’s content to improve your experience. INTERFACE may also use your personally identifiable information to invite you to provide feedback via surveys or other mechanisms regarding your opinion of INTERFACE services or your experience using the INTERFACE website.
INTERFACE does not sell, rent or lease its customer lists to third parties. INTERFACE may share data with trusted partners to help perform statistical analysis, send you email or postal mail or provide customer support. All such third parties are prohibited from using your personal information except to provide these services to INTERFACE, and they are required to maintain the confidentiality of your information.
INTERFACE may disclose your personally identifiable 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 INTERFACE or the website; (b) protect and defend the rights or property of INTERFACE; and, (c) act under exigent circumstances to protect the personal safety of users of the INTERFACE website, or the public.
If you are a subscriber to one of INTERFACE’s mailing lists, you may edit your communication preferences by clicking the “email preferences” link in the footer of any INTERFACE newsletter or project email that you receive. Alternatively, you may contact us directly to request access to the personal data that we have about you (e.g., your name, email address), which we will supply electronically, or to request that we modify or delete that information.
OUR PLEDGE REGARDING MENTAL HEALTH INFORMATION
This notice will tell you about the ways in which we may use and disclose health information about you. We also describe your rights and certain obligations we have regarding the use and disclosure of your mental health information
We understand that information we maintain about you and your health is personal. We are committed to protecting mental health information about you. We create a record of the care and services you receive at Interface. We need this record to provide you with quality care and to comply with certain legal requirements. This notice applies to all your records of care generated by Interface.
INTERFACE CHILDREN & FAMILY SERVICES (INTERFACE) HAS A LEGAL DUTY TO SAFEGUARD YOUR PROTECTED HEALTH lNFORMATION (PHI)
INTERFACE is legally required to protect the privacy of your PHI, which includes information that can be used to identify you that INTERFACE has created or received about your past, present, or future health or condition, the provision of health care to you, or the payment of this health care. INTERFACE must provide you with this Notice about its privacy practices, and such Notice must explain how, when, and why INTERFACE will “use” and “disclose” your PHI. A “use” of PHI occurs when INTERFACE shares, examine, utilize, apply, or analyze such information within our practice; PHI is “disclosed” when it is released, transferred, has been given to, or is otherwise divulged to a third party outside of our practice. With some exceptions, INTERFACE may not use or disclose any more of your PHI than is necessary to accomplish the purpose for which the use or disclosure is made. And, INTERFACE is legally required to follow the privacy practices described in this Notice.
However, INTERFACE reserves the right to change the terms of this Notice and our privacy policies at any time. Any changes will apply to PHI on file with INTERFACE already. Before INTERFACE makes any important changes to our policies, INTERFACE will promptly change this Notice and post a new copy of it online,. You can also request a copy of this Notice from INTERFACE.
HOW INTERFACE MAY USE AND DISCLOSE YOUR PHI.
INTERFACE will use and disclose your PHI for many different reasons. For some of these uses or disclosures, INTERFACE will need your prior authorization; for others, however, INTERFACE does not. Listed below are the different categories of our uses and disclosures along with some examples of each category.
Uses and Disclosures Relating to Treatment, Payment, or Health Care Operations Do Not Require Your Prior Written Consent. INTERFACE can use and disclose your PHI without your consent for the following reasons:
- For treatment. INTERFACE can disclose your PHI to physicians, psychiatrists, psychologists, and other licensed health care providers who provide you with health care services or are involved in your care. For example, if you’re being treated by a psychiatrist, INTERFACE can disclose your PHI to your psychiatrist in order to coordinate your care.
- To obtain payment for treatment. INTERFACE can use and disclose your PHI to bill and collect payment for the treatment and services provided by INTERFACE to you. For example, INTERFACE might send your PHI to your insurance company or health plan to get paid for the health care services that INTERFACE has provided to you. INTERFACE may also provide your PHI to our business associates, such as billing companies, claims processing companies, and others that process our health care claims.
- For health care operations. INTERFACE can disclose your PHI to operate our practice. For example, INTERFACE might use your PHI to evaluate the quality of health care services that you received or to evaluate the performance of the health care professionals who provided such services to you. INTERFACE may also provide your PHI to our accountants, attorneys, consultants, and others to make sure we are complying with applicable laws.
- Other disclosures. INTERFACE may also disclose your PHI to others without your consent in certain situations. For example, your consent isn’t required if you need emergency treatment, as long as INTERFACE tries to get your consent after treatment is rendered, or if INTERFACE tries to get your consent but you are unable to communicate with us (for example, if you are unconscious or in severe pain) and INTERFACE thinks that you would consent to such treatment if you were able to do so.
Certain Uses and Disclosures Do Not Require Your Consent. INTERFACE can use and disclose your PHI without your consent or authorization for the following reasons:
- When disclosure is required by federal, state or Iocal law; judicial or administrative proceedings; or, law enforcement. For example, INTERFACE may make a disclosure to applicable officials when a law requires us to report information to government agencies and law enforcement personnel about victims of abuse or neglect; or when ordered in a judicial or administrative proceeding.
- For public health activities. For example, INTERFACE may have to report information about you to the county coroner.
- For health oversight activities. For example, INTERFACE may have to provide information to assist the government when it conducts an investigation or inspection of a health care provider or organization.
- To avoid harm. In order to avoid a serious threat to the PHI to law enforcement personnel or persons able to prevent or lessen such harm.
- For specific government functions. INTERFACE may disclose PHI of military personnel and veterans in certain situations. And INTERFACE may disclose PHI for national security purposes, such as protecting the President of the United States or conducting intelligence operations.
- Appointment reminders and health related benefits or services. INTERFACE may use PHI to provide appointment reminders or give you information about treatment alternatives, or other health care services or benefits we offer.
Certain Uses and Disclosures Require You to Have the Opportunity to Object. Disclosures to family, friends, or others. INTERFACE 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.
Other Uses and Disclosures Require Your Prior Written Authorization. In any other situation not described in sections III A, B, and C above, INTERFACE will ask for your written authorization before using or disclosing any of your PHI. If you choose to sign an authorization to disclose your PHI, you can later revoke such authorization in writing to stop any future uses and disclosures (to the extent that INTERFACE hasn’t taken any action in reliance on such authorization) of your PHI by us.
WHAT RIGHTS YOU HAVE REGARDING YOUR PHI
The Right to Request Limits on Uses and Disclosures of Your PHI. You have the right to ask that INTERFACE limits how we use and disclose your PHI. INTERFACE will consider your request, but we are not legally required to accept it. If INTERFACE accepts your request, INTERFACE will put any limits in writing and abide by them except in emergency situations. You may not limit the uses and disclosures that INTERFACE is legally required or allowed to make.
The Right to Choose How INTERFACE Sends PHI to You. You have the right to ask that INTERFACE sends information to you to at an alternate address (for example, sending information to your work address rather than your home address) or by alternate means (for example, e-mail instead of regular mail) INTERFACE must agree to your request so long as INTERFACE can easily provide the PHI to you in the format you requested.
The Right to See and Get Copies of Your PHI. In most cases, you have the right to look at or get copies of your PHI that INTERFACE has, but you must make the request in writing. If INTERFACE doesn’t have your PHI but we know who does, INTERFACE will tell you how to get it. INTERFACE will respond to you within 30 days of receiving your written request. In certain situations, INTERFACE may deny your request. If INTERFACE does, INTERFACE will tell you, in writing, our reasons for the denial and explain your right to have my denial reviewed. If you request copies of your PHI, INTERFACE will charge you not more than $.25 for each page. Instead of providing the PHI you requested, INTERFACE may provide you with a summary or explanation of the PHI as long as you agree to that and to the cost in advance.
The Right to Get a List of the Disclosures INTERFACE Has Made.
You have the right to get a list of instances in which INTERFACE has disclosed your PHI. The list will not include uses or disclosures that you have already consented to, such as those made for treatment, payment, or health care operations, directly to you, or to your family. The list also won’t include uses and disclosures made for national security purposes, to corrections or law enforcement personnel, or disclosures made before April 15, 2003.
INTERFACE will respond to your request for an accounting of disclosures within 60 days of receiving your request. The list INTERFACE will give you will include disclosures made in the last six years unless you request a shorter time. The list will include the date of the disclosure, to whom PHI was disclosed (including their address, if known), a description of the information disclosed, and the reason for the disclosure. INTERFACE will provide the list to you at no charge, but if you make more than one request in the same year, INTERFACE will charge you a reasonable cost based fee for each additional request.
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, you have the right to request that INTERFACE corrects the existing information or add the missing information. You must provide the request and your reason for the request in writing. INTERFACE will respond within 60 days of receiving your request to correct or update your PHI. INTERFACE may deny your request in writing if the PHI is (i) correct and complete, (ii) not created by our agency, (iii) not allowed to be disclosed, or (iv) not part of our records. Our written denial will state the reasons for the denial and explain your right to file a written statement of disagreement with the denial. If you don’t file one, you have the right to request that your request and our denial be attached to all future disclosures of your PHI. If INTERFACE approves your request, INTERFACE will make the change to your PHI, tell you that INTERFACE has done it, and tell others that need to know about the change to your PHI.
The Right to Get This Notice by E-Mail. You have the right to get a copy of this notice by e-mail. Even if you have agreed to receive notice via e-mail, you also have the right to request a paper copy of it.
INTERFACE may occasionally update this statement, so you are encouraged to periodically review the policy to remain informed of how INTERFACE is protecting your information.
PERSON TO CONTACT FOR INFORMATION ABOUT THIS NOTICE OR TO COMPLAIN ABOUT MY PRIVACY PRACTICES
If you have any questions about this notice or any complaints about our privacy practices, or would like to know how to file a complaint with the Secretary of the Department of Health and Human Services, please contact Interface at: 4001 Mission Oaks Blvd, Camarillo, CA 93012 (805) 485-6114.
This notice went into effect on April 14, 2003.