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 NOTICE OF PRIVACY PRACTICES FOR PROTECTED HEALTH INFORMATION

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU 
MAY BE USED OR DISCLOSED BY 
PLANNED PARENTHOOD OF PASADENA & SAN GABRIEL VALLEY, INC. (PPPSGV) AND
HOW YOU CAN GET ACCESS TO THIS INFORMATION.

PLEASE REVIEW THIS NOTICE CAREFULLY

EFFECTIVE DATE OF THIS NOTICE: November 1, 2021

If you have any questions about this Notice, please contact PPPSGV’s Privacy Officer at (626) 794-5737 or at 2333 Lake Ave., 2nd Floor, Altadena, CA 91001.

OUR PLEDGE REGARDING YOUR HEALTH INFORMATION

We understand that health information about you and your health care is personal. We are committed to protecting health information about you. We will create a record of the care and services you receive from us. We do so to provide you with quality care and to comply with any legal or regulatory requirements.

This Notice applies to all of the records generated or received by PP, whether we documented the health information, or another health care provider forwarded it to us. This Notice will tell you the ways in which we may use or disclose health information about you. This Notice also describes your rights to the health information we keep about you, and describes certain obligations we have regarding the use and disclosure of your health information.

Our pledge regarding your health information is backed up by federal and state law. The privacy and security provisions of the federal Health Insurance Portability and Accountability Act (“HIPAA”) require us to:
⦁    Make sure that health information that identifies you is kept private;
⦁    Provide to you this notice of our legal duties and privacy practices with respect to health information about you; 
⦁    Follow the terms of the notice that is currently in effect; and
⦁    Notify you following a breach of your unsecured protected health information. California law also requires this notification. 

HOW WE MAY USE AND DISCLOSE HEALTH INFORMATION ABOUT YOU

The following categories describe different ways that we may use or disclose health information about you. Unless otherwise noted, each of these uses and disclosures may be made without your permission. For each category of use or disclosure, we will explain what we mean and give some examples. Not every use or disclosure in a category will be listed. However, unless we ask for a separate authorization, all of the ways we are permitted to use and disclose information will fall within one of the categories.

For Treatment: We may use health information about you to provide you with health care treatment and services. We may disclose health information about you to doctors, clinicians, technicians, health students, volunteers or other personnel who are involved in taking care of you. They may work at our offices, at a hospital if you are hospitalized under our supervision, or at another doctor’s office, lab, pharmacy, or other health care provider to whom we may refer you for consultation, to take x-rays, to perform lab tests, to have prescriptions filled, or for other treatment purposes. For example, a doctor treating you may need to know if you have diabetes because diabetes may slow the healing process. We may provide that information to a provider  treating you at another institution.

For Payment: We may use and disclose health information about you so that the treatment and services you receive from us may be billed to and payment collected from you, an insurance company, a government program such as Medi-Cal or Medicare, or a third party. For example, we may need to give your health insurance plan information about your office visit so your health plan will pay us or reimburse you for the visit. Alternatively, we may need to give your health information to Medi-Cal so that we may be reimbursed for providing services to you. In some instances, we may need to 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 for operations of our health care practice. These uses and disclosures are necessary to run our practice and make sure that all of our patients receive quality care. For example, we may use health information to review our treatment and services and to evaluate the performance of our staff in caring for you. We may also combine health information about many patients to decide what additional services we should offer, what services are not needed, whether certain new treatments are effective, or to compare how we are doing with other health care providers and to see where we can make improvements. We may remove information that identifies you from this set of health information so others may use it to study health care delivery without learning who our specific patients are.

To Individuals Involved in Your Care or Payment for Your Care:  Unless you are a minor receiving reproductive health care or have told us in writing you do not want us to do so, we may give medical information about you to family members or others involved in your care.  We may also give medical information to someone who helps pay for your care. In the rare situation of a natural or similar disaster, we may disclose medical information about you to an organization assisting in disaster relief efforts so that your family can be notified about your status, location and condition.

Special Protections for Minors: In California, there are certain circumstances where minors are given special protections from disclosure of their medical information. In those circumstances, if you are a minor, you must provide us with written authorization to disclose information. For example, in most cases, we may not provide your medical information to your parents or guardians without your signed written authorization when the care involves pregnancy, contraception, abortion, contagious or sexually transmitted diseases, AIDS/HIV, mental health care, and drug and alcohol abuse treatment.

Appointment Reminders: We may use and disclose health information to contact you as a reminder that you have an appointment. Please let us know if you do not wish to have us contact you concerning your appointment, or if you wish to have us use a different telephone number or address to contact you for this purpose. If you give us your verbal permission we can also text you appointment reminders. You can opt out of this service at any time. 

Customer Survey: We may use and disclose health information to contact you and ask that you complete a survey on your experience with PPPSGV. You may choose not to complete it or request to opt out of receiving surveys. 

Fundraising Activities: We may use health information about you to contact you in an effort to raise money for our not-for-profit operations. You have the right to opt out of receiving these communications. Please let us know if you do not want us to contact you for our fundraising efforts.

Research: There may be situations where we want to use and disclose health information about you for research purposes. For example, a research project may involve comparing the efficacy of one medication over another. For any research project that uses your health information, we will either obtain an authorization from you or ask an Institutional Review or Privacy Board to waive the requirement to obtain authorization. A waiver of authorization will be based upon assurances from a Review Board that the researchers will adequately protect your health information. 

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

Victims of Abuse and Neglect: We may disclose health information about you to a local, state or federal government authority. This includes social services or a protective services agency authorized by law to have these reports.  We will do this if we have a reasonable belief of abuse, neglect or intimate partner violence.

To Avert a Serious Threat to Health or Safety: We may use and disclose health information about you when necessary to prevent or lessen a serious or imminent threat.  This includes threats the health and safety of a person or the public. Any disclosure, however, would only be to someone able to help prevent the threat.

Military and Veterans: If you are a member of the armed forces or are separated/discharged from military services, we may release health information about you as required by military command authorities or the Department of Veterans Affairs as may be applicable. We may also release health information about foreign military personnel to the appropriate foreign military authorities.

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 activities. These activities generally include the following:
⦁    To prevent or control disease, injury or disability;
⦁    To report births and deaths;
⦁    To report child abuse or neglect; 
⦁    To report reactions to medications or problems with products;
⦁    To notify people of recalls of products they may be using;
⦁    To notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition;
⦁    To notify the appropriate government authority if we believe you have been the victim of abuse, neglect, or domestic violence. We will only make this disclosure if you agree or when required or authorized by law. 

Health Oversight Activities: We may disclose health information to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure. These activities are necessary for the government 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 an order issued by a court or administrative tribunal. We may also disclose health information about you in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute, but only after efforts have been made to tell you about the request and you have time to obtain an order protecting the information requested.

Law Enforcement: We may release health information to law enforcement officials:
⦁    In response to a court order, subpoena, warrant, summons or similar process. If you have not provided consent, we may release this health information to a Special Master under seal who will present it to the court to determine if the need for the information outweighs your privacy interests in the information;
⦁    To identify or locate a suspect, fugitive, material witness, or missing person when asked by law enforcement officials or those assisting them (e.g., missing persons announcements on TV, radio, newspapers, Amber alerts);
⦁    If you are the victim of a crime and (1) you consent or (2) we are unable to obtain your consent because of your incapacity or other emergency;
⦁    About a death we believe may be the result of criminal conduct;
⦁    In an instance of criminal conduct at our facility; and
⦁    In emergency circumstances to report a crime; the location of the crime or victims; or the identity, description, or location of the person who committed the crime. 

Coroners, Health Examiners and Funeral Directors: We may release health information to a coroner or health examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death. We may also release health information about patients to funeral directors as necessary to carry out their duties.

Inmates: If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release health information about you to the correctional institution or law enforcement official. This release would be necessary: (1) for the institution to provide you with health care; (2) to protect your health and safety or the health and safety of others; or (3) for the safety and security of the correctional institution.

Special Categories of Information: In some circumstances, your health information may be subject to restrictions that may limit or preclude some uses or disclosures described in this notice. For example, there are special restrictions on the use or disclosure of certain categories of information, e.g., tests for HIV or treatment for mental health conditions or alcohol and drug abuse. Government health benefit programs, such as Medi-Cal, may also limit the disclosure of beneficiary information for purposes unrelated to the program.

USES OF HEALTH INFORMATION REQUIRING AN AUTHORIZATION

The following uses and disclosures of health information will be made only with your written permission: 
⦁    Use and disclosures of protected health information for marketing purposes;
⦁    Use and disclosures that constitute the sale of your protected health information;
⦁    Other uses and disclosures of health information not covered by this Notice or the laws that apply to us.
If you provide us permission to use or disclose health information about you, you may revoke that permission, in writing, at any time. If you revoke your permission, we will no longer use or disclose health information about you for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain the records of the care that we provided to you.

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 certain rights to inspect and copy health information that may be used to make decisions about your care. Usually, this includes health and billing records. 

If you want to access your information and it is not on the patient portal or you cannot access the patient portal, you can let us know by telling us in person, calling, emailing, or sending us a request in the mail.  You may ask to view your information in person, have us mail it to you or email you, or view it on our patient portal.  We will try to provide your information in the format and via the method you ask for, but we may have to provide information in an alternative manner if it’s not feasible to follow your request. Under California law, you may review your health information within five business days of our receiving your request. If you request a copy your health information, we must furnish the copy within 15 days of receiving the request. 

There are apps you can download on your cell phone to collect and organize your health information for you.  You can ask us to send your electronic information to such apps, and we will follow your request unless it is infeasible to do so or sending the information creates a security risk.

Unlike PPPSGV, these apps typically are not subject to HIPAA and other health care privacy laws.  Some apps may be careful to protect your health information, but others may not.  Before you decide to use any, we recommend that you review the app's Privacy Statement and Terms of Use to see how it will handle your data.

Limits on Information: We may deny your request to inspect and copy in certain very limited circumstances. For example, if we believe supplying you with certain information could lead to physical harm to you or someone else, we will withhold that information. If you are denied access to your health information, you may in certain instances appeal that denial. Another licensed health care professional chosen by our practice will review your request and the denial. The person conducting the review will not be the person who denied your initial request. We will comply with the outcome of the review. 

Right to Amend: If you feel that 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 for as long as we keep the information. To request an amendment, your request must be made in writing.

We may deny your request for an amendment if it is not the form provided by us and does not include a reason to support the request. In addition, we may deny your request if you ask us to amend information that:
⦁    Was not created by us, unless the person or entity that created the information is no longer available to make the amendment;
⦁    Is not part of the health information kept by or for our practice;
⦁    Is not part of the information that you would be permitted to inspect and copy; or 
⦁    Is accurate and complete.

Any amendment we make to your health information will be disclosed to those with whom we disclose information as previously specified.

Right to Accounting of Disclosures: You have the right to request a list of any disclosures of your health information we have made, except for uses and disclosures for treatment, payment, and health care operations, as previously described. To request this list of disclosures, you must submit your request in writing. 

Right to Request Restrictions: You have the right to request restrictions on certain uses and disclosures of your health information by a written or verbal request specifying what information you want to limit, and what limitations on our use or disclosure of that information you wish to have imposed.  If you tell us not to disclose information to your commercial health plan concerning health care items or services for which you paid for in full out-of-pocket, we will abide by your request, unless we must disclose the information for treatment or legal reasons. We reserve the right to accept or reject any other request, and will notify you of our decision.
Right to Request Confidential Communications: You have the right to request that we communicate with you about health matters in a certain manner or at a certain location. For example, you can ask that we only contact you at work or by mail to a post office box. During our registration process, we will ask you how you wish to receive communications about your health care or any other instructions on notifying you about heath information. We will accommodate all reasonable requests.
Right to a Paper Copy of This Notice: You have the right to obtain a paper copy of this Notice at any time upon request, even if you have received the Notice electronically. You may obtain a copy of this Notice on our website www.pppsgv.org.
CHANGES TO THIS NOTICE
We reserve the right to change this Notice. We reserve the right to make the revised or changed Notice effective for health information we already have about you as well as any information we receive in the future. We will post a copy of the current Notice in our health centers and on our website. The Notice contains the effective date on the first page.
COMPLAINTS
If you believe your privacy rights have been violated, you may file a complaint with us by contacting the PPPSGV Privacy Officer at the telephone number and address at the beginning of this Notice. You can also file a complaint with the U.S. Department of Health and Human Services 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.  All complaints must be submitted in writing. You will not be retaliated against for filing a complaint.

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