Privacy

LEGAL / PRIVACY POLICY

Effective as August 3, 2009

Legal / Privacy Policy Effective as of August 3, 2009

This Notice describes how medical information about you may be used and disclosed and how you can get access to this information. Please review it carefully. If you have any questions about this notice, to make changes to your contact information, or to opt out of receiving information, please contact Terri Wager, Senior Vice President, Administrative Services at 303-238-8151, send a written request to 3227 Chase Street, Denver, CO 80212 or e-mail info@SRCAging.org. Seniors’ Resource Center provides non-medical services to our customers. In order to provide service, however, it is frequently necessary for us to have access to health information. The Health Insurance Portability and Accountability Act (HIPAA) guidelines require specific language be used in our notice of privacy practices. Therefore, referrals will be made to ‘treatment’ within this notice even though we are not a direct provider of what we consider medical treatment. For purposes this and other HIPAA-related documents from SRC, the term “treatment” will be defined for SRC purposes as non-medical services received from one of the Center’s programs including but not limited to: Adult Day & Respite Services, Homemaker and Personal Care Program Services, Transportation Services, Case Management Services, Nutrition Services and Volunteer Services.

Who Will Follow This Notice

This notice describes the information privacy practices followed by our employees and other office personnel. The practices described in this notice will also be followed by staff members that you may consult with by telephone.

Your Health Information

This notice applies to the information and records we have about your health, health status, and the health care and services you receive from Seniors’ Resource Center, Incorporated.

We are required by law to give you this notice. It will tell you about the ways in which we may use and disclose health information about you and describes your rights and our obligations regarding the use and disclosure of that information.

How We May Use and Disclose Health Information About You

For Treatment or provision of Services: We may use health information about you to provide you with treatment or services. We may disclose health information about you to doctors, nurses, technicians, office staff or other personnel or entities who are involved in taking care of you and your health.

For example, your doctor may be treating you for a heart condition and may need to know if you have other health problems that could complicate your treatment. The doctor may use your medical history to decide what treatment is best for you. The doctor may also tell another doctor about your condition so that doctor can help determine the most appropriate care for you. Your doctor could also contact us about information that may be related to your health status in order to further determine treatment measures for you. We may also contact your doctor or members of his/her staff in order to acquire information that will allow us to better create a plan of care or to determine what services will be required to best meet your needs.

Different personnel in our office may share information about you and disclose information to people who do not work in our office in order to coordinate your care, such as helping you to set up doctor, treatment, or therapy appointments, scheduling lab work or assisting you in coordinating transportation. Family members and other health care providers may be part of your medical care outside this office and may require information about you from us. We may also request information from them if it is believed to be in your best interest.

For Payment: We may use and disclose health information about you so that the services you receive from the Seniors’ Resource Center may be billed to and payment may be collected from you, an insurance company or a third party. For example, we may need to give your health plan information about a service you received from the Center so that we will be paid or so that you may be reimbursed for the service. We may also tell your health plan about a treatment you are going to receive to obtain prior approval, or to determine whether your plan will cover the treatment.

For Health Care Operations: We may use and disclose health information about you in order to run the office and make sure that you and our other customers receive quality care. For example, we may use your health information to evaluate the performance of our staff in caring for you. We may also use health information about all or many of our customers to help us decide what additional services we should offer, how we can become more efficient, or whether certain new services are effective.

Appointment Reminders: We may contact you as a reminder that you have an appointment for service.

Service Alternatives: We may tell you about or recommend possible service options or alternatives that may be of interest to you.

Health-Related Products and Services: We may tell you about health-related products or services that may be of interest to you.

Please notify us if you do not wish to be contacted for appointment reminders, or if you do not wish to receive communications about service or treatment alternatives or health-related products and services. If you advise us in writing (at the address listed at the top of this Notice) that you do not wish to receive such communications, we will not use or disclose your information for these purposes.

You may revoke your Consent at any time by giving us written notice. Your revocation will be effective when we receive it, but it will not apply to any uses and disclosures which occurred before that time.

If you do revoke your Consent, we will not be permitted to use or disclose information for purposes of service, payment or health care operations, and we may therefore choose to discontinue providing you with health care service and services.

Special Situations

We may use or disclose health information about you without your permission for the following purposes, subject to all applicable legal requirements and limitations:

To Avert a Serious Threat to Health or Safety: We may use and disclose health information about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person.

Required By Law: We will disclose health information about you when required to do so by federal, state or local law.

Research: We may use and disclose health information about you for research projects that are subject to a special approval process. We will ask you for your permission if the researcher will have access to your name, address or other information that reveals who you are, or will be involved in your care at the office.

Organ and Tissue Donation: If you are an organ donor, we may release health information to organizations that handle organ procurement or organ, eye or tissue transplantation or to an organ donation bank, as necessary to facilitate such donation and transplantation.

Military, Veterans, National Security and Intelligence: If you are or were a member of the armed forces, or part of the national security or intelligence communities, we may be required by military command or other government authorities to release health information about you. We may also release information about foreign military personnel to the appropriate foreign military authority.

Workers’ Compensation: We may release health information about you for workers’ compensation or similar programs. These programs provide benefits for work-related injuries or illness.

Public Health Risks: We may disclose health information about you for public health reasons in order to prevent or control disease, injury or disability; or report births, deaths, suspected abuse or neglect, non-accidental physical injuries, reactions to medications or problems with products.

Health Oversight Activities: We may disclose health information to a health oversight agency for audits, investigations, inspections, or licensing purposes. These disclosures may be necessary for certain state and federal agencies to monitor the health care system, government programs, and compliance with civil rights laws.

Lawsuits and Disputes: If you are involved in a lawsuit or a dispute, we may disclose health information about you in response to a court or administrative order. Subject to all applicable legal requirements, we may also disclose health information about you in response to a subpoena.

Law Enforcement: We may release health information if asked to do so by a law enforcement official in response to a court order, subpoena, warrant, summons or similar process, subject to all applicable legal requirements.

Coroners, Medical Examiners and Funeral Directors: We may release health information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death.

Information Not Personally Identifiable: We may use or disclose health information about you in a way that does not personally identify you or reveal who you are.

Family and Friends: We may disclose health information about you to your family members or friends if we obtain your verbal agreement to do so or if we give you an opportunity to object to such a disclosure and you do not raise an objection. We may also disclose health information to your family or friends if we can infer from the circumstances, based on our professional judgment, that you would not object. For example, we may assume you agree to our disclosure of your personal health information to your family or friend when you have another person in the room with you when we meet with you or when you receive services from one of our staff or volunteers.

In situations where you are not capable of giving consent (because you are not present or due to your incapacity or medical emergency), we may, using our professional judgment, determine that a disclosure to your family member, friend, or care-giver is in your best interest. In that situation, we will disclose only health information relevant to the person’s involvement in your care. For example, we may inform the person who followed you to the emergency room that you appeared to suffer an acute health situation requiring us to assist you in receiving medical care. We may also use our professional judgment and experience to make reasonable inferences that it is in your best interest to allow another person to act on your behalf to pick up, for example, filled prescriptions, medical supplies, etc.

Other Uses and Disclosures of Health Information

We will not use or disclose your health information for any purpose other than those identified in the previous sections without your specific, written Authorization. We must obtain your Authorization separate from any Consent we may have obtained from you. If you give us Authorization to use or disclose health information about you, you may revoke that Authorization, in writing, at any time. If you revoke your Authorization, we will no longer use or disclose information about you for the reasons covered by your written Authorization, but we cannot take back any uses or disclosures already made with your permission.

If we have HIV or substance abuse information about you, we cannot release that information without a special signed, written authorization (different than the Authorization and Consent mentioned above) from you. In order to disclose these types of records for purposes of service, payment or health care operations, we will have to have both your signed Consent and a special written Authorization that complies with the law governing HIV or substance abuse records.

SRC may use demographic information contained in a client/customer’s file (such as names and addresses) for fund-raising purposes for the Center and its services. You may elect to decline to participate in these processes by notifying: Development, Seniors’ Resource Center, 3227 Chase Street, Denver, CO 80212.

Your Rights Regarding Health Information About You

You have the following rights regarding health information we maintain about you:

Right to Inspect and Copy: You have the right to inspect and copy your health information, such as medical and billing records, that we use to make decisions about your care. You must submit a written request to Terri Wager, Senior Vice President, Administrative Services in order to inspect and/or copy your health information. If you request a copy of the information, we may charge a fee for the costs of copying, mailing or other associated supplies. We may deny your request to inspect and/or copy in certain limited circumstances. If you are denied access to your health information, you may ask that the denial be reviewed. If such a review is required by law, we will select a licensed health care professional to review your request and our denial. The person conducting the review will not be the person who denied your request, and we will comply with the outcome of the review.

Right to Amend: If you believe health information we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment as long as the information is kept by this office.

To request an amendment, complete and submit a Medical Record Amendment/Correction Form to Terri Wager, Senior Vice President, Administrative Services. We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to amend information that:

A. We did not create, unless the person or entity that created the information is no longer available to make the amendment.

B. Is not part of the health information that we keep.

C. You would not be permitted to inspect and copy.

D. Is accurate and complete.

Right to an Accounting of Disclosures

You have the right to request an “accounting of disclosures.” This is a list of the disclosures we made of medical information about you for purposes other than service, payment and health care operations. To obtain this list, you must submit your request in writing to Terri Wager, Senior Vice President, Administrative Services. It must state a time period, which may not be longer than six years and may not include dates before April 14, 2003. Your request should indicate in what form you want the list (for example, on paper, electronically). We may charge you for the costs of providing the list. We will notify you of the cost involved and you may choose to withdraw or modify your request at that time before any costs are incurred.

Right to Request Restrictions

You have the right to request a restriction or limitation on the health information we use or disclose about you for service, payment or health care operations. You also have the right to request a limit on the health information we disclose about you to someone who is involved in your care or the payment for it, like a family member or friend. For example, you could ask that we not use or disclose information about a surgery you had.

We Are Not Required to Agree to Your Request

If we do agree, we will comply with your request unless the information is needed to provide you emergency service. We may also agree to a modified version of your request and will inform you of what information we will agree NOT to disclose.

To request restrictions, you may complete and submit the Request For Restriction On Use/Disclosure Of Medical Information to Terri Wager, Senior Vice President, Administrative Services.

Right to Request Confidential Communications

You have the right to request that we communicate with you about medical matters in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail.

To request confidential communications, you may complete and submit the Request For Restriction On Use/Disclosure Of Medical Information And/Or Confidential Communication to Terri Wager, Director of Human Resources We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must clearly specify how or where you wish to be contacted.

Right to a Paper Copy of This Notice

You have the right to a paper copy of this notice. You may ask us to give you a copy of this notice at any time. Even if you have agreed to receive it electronically, you are still entitled to a paper copy. To obtain such a copy, contact Terri Wager, Senior Vice President, Administrative Services.

Changes to This Notice

We reserve the right to change this notice, and to make the revised or changed notice effective for medical information we already have about you as well as any information we receive in the future. We will post a summary of the current notice in the office with its effective date in the top right hand corner. You are entitled to a copy of the notice currently in effect.

Complaints

If you believe your privacy rights have been violated, you may file a complaint with our office or with the Secretary of the Department of Health and Human Services. To file a complaint with our office, contact Terri Wager, Senior Vice President, Administrative Services, Seniors’ Resource Center, 3227 Chase Street, Denver, CO 80212. You may also contact Ms. Wager at (303) 238-8151 but we request that you also follow-up your phone contact with a written complaint to insure that all information is communicated clearly and we can address all of your concerns in a timely manner. You will not be penalized for filing a complaint.

Personally Identifiable Information

We do not collect Personally Identifiable Information about you on the Seniors’ Resource Center website without your knowledge or action. Your inoformation is collected through the membership registration form, e-mail newsletter registration and/or event registration forms. This information includes, but is not limited to, your name (first and last), company name, company address, phone number, fax number, e-mail address and credit card information. You should be aware that if you disclose any information on a bulletin board or in a chat room or other open forum that is hosted by Seniors’ Resource Center, others may collect that information to send you unsolicited information from outside Seniors’ Resource Center, or for other purposes.

Use of Personally Identifiable Information

We reserve the right to share your contact information with certain third parties. These can include financial institutions, service providers, contractors, or affiliate organizations. You will always have the ability to opt out from receiving information from Seniors’ Resource Center as well as from said third parties.

Non-Personally Identifiable Information

Non-Personally Identifiable Information includes, but is not limited to, information we automatically collect on your use and/or actions on our website (e.g., user traffic patterns, page views on the website, click-through rates, search terms that users enter into our search utility). In addition, when a visitor arrives at our site, we collect the IP address, operating system, and browser software used. An IP address (which is not the same as an e-mail address) can tell us the user’s internet service provider and, based on that, can suggest the geographic location of the connection. Seniors’ Resource Center recognizes that certain User information of a key demographic nature (e.g., race, age, gender, national origin, income), while Non-Personally Identifiable Information, is still of a sensitive nature to users. As a general matter, Seniors’ Resource Center does not collect such information about you through its website. However, in recognition of the sensitive nature of such information, in the event Seniors’ Resource Center comes into possession of such information, whether through your voluntary submission of such information in response to a special feature on the website or by receiving such information from any of our business partners, such information shall, when coupled with any of your Personally Identifiable Information, itself be deemed to be Personally Identifiable Information and treated by Seniors’ Resource Center as such.

Use of Non-Personally Identifiable Information

As a general matter, Non-Personally Identifiable Information helps us determine how the Seniors’ Resource Center website is being used, helps us identify popular areas of the website, and helps determine the effectiveness of our promotional activities regarding the website.

Use of Cookies

Our website uses “cookies” (i.e., a small data file that our website writes to a user’s hard drive) to help track your usage of our site, including what advertising you have seen. SRCAging.org’s cookies do not include personal information about you, but they are unique to each user and include a member ID # (a randomly generated unique number) that enables the Seniors’ Resource Center website to identify you when you visit, so you: (1) do not have to remember your username and password each time you visit the website; and (2) receive any personalized services you requested when you registered.

Neither our website, nor the cookies we write to the hard drives of our users, read any data off of your hard drive outside of our cookies. This includes not reading any cookie files created by other websites. You can refuse our cookies by turning them off in your browser (for more information on how to do this, please refer to your browser’s documentation). You do not need to have cookies turned on in your browser to use our website; however, without cookies certain elements of the automated functions and features of our website will not be available to you. We also use cookies to measure the click through rate on e-mails delivered.

Third Party Use of Personal Information

The Seniors’ Resource Center website contains links to other Internet websites, including co-branded or other affiliated sites. Unless otherwise explicitly stated, we are not responsible for the privacy practices or the content of such websites, including such sites’ use of any information.

Security

You understand and agree that perfect security does not exist anywhere, including on the Internet. When you send credit card information, we encrypt this information between your computer and our server. Other information you send to this site, including e-mail messages, will not be encrypted unless we advise you otherwise. Our website is protected by a firewall and monitored for security.

Legal Disclaimer

This site provides information designed to help users cope with their own legal, business, financial, and other needs. This information is not the same as retaining experts in those fields for advice. Although we go to great lengths to ensure the information is accurate, we strongly recommend you consult an expert, including but not limited to a lawyer, accountant, financial services consultant, or other professional as appropriate. Nothing contained in this website is to be considered as the rendering of legal, financial, professional or other advice for specific cases, and users are responsible for obtaining such advice from their own legal, financial or other counsel. The information contained on this site is intended for educational, background and informational purposes only.

Correcting, Updating or Deleting Information

The Seniors’ Resource Center website gives users the option to correct, update or delete any information previously provided to us by the user; howerver, we will maintain copies of user information to the extent retained as part of our website’s standard backup/archive process. In addition, these procedures will not remove such of your information that has been provided by you to, or collected from you by, the websites of our business partners. We are not responsible for ensuring the removal or deletion from the websites of our business partners of your information provided by us to our business partners as permitted by you or otherwise in accordance with this Privacy Statement.

E-mail: info@srcaging.org