NOTICE OF PRIVACY PRACTICES
Effective Date: October 5, 2018
THIS NOTICE DESCRIBES HOW PERSONALLY IDENTIFIABLE INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN ACCESS THIS INFORMATION. PLEASE REVIEW THIS NOTICE CAREFULLY.
WHAT WE DO:
2-1-1 San Diego (“2-1-1”) is a resource and information hub that connects individuals with health and social services ,insurance, financial aid,debt and tax preparation counseling, housing, food, transportation, employment and job training, disaster relief and other service providers through a free, 24/7 stigma-free confidential phone service, searchable online database, care coordination, technology infrastructure. 2-1-1 provides referral, care coordination, outreach, education,and other services in connection with its trusted network of referral providers to deliver services to members of the community.
Information We Collect About You:
To address your needs and connect you to appropriate providers in our network, 2-1-1San Diego may collect and keep a record of information about you.This information may include your name, social security number, telephone number, address and email, your age, gender, nationality, ethnicity, physical and mental health condition, health care, health insurance and care team,finances, debt,and employment, housing and housing needs, names and contact information for your family members, friends and care givers, military background, information about the community programs you have been or are currently enrolled in, and other information that may be required to determine if you are eligible for government benefits,tax credits,income/debt assistance, insurance coverage,housing assistance and other programs and services offered by our referral providers.Some of the information we collect may be considered“protected information”under federal and/or state privacy laws.2-1-1 San Diego maintains information about its Clients, in a secure electronic database and takes precautions to prevent third parties from accessing Client information inappropriately. The 2-1-1 system allows us to document the source of the information, who accessed your information and control what information is shared with 2-1-1’s network of referral providers. 2-1-1 San Diego’s network of referral providers are legally and/or contractually obligated to protect your information.
WHERE THE INFORMATION COMES FROM:
Information about you may also be disclosed to us by your providers if they are a member of our trusted network. The information will be shared with us when they use our services or access our database to provide services to you or to refer you to other providers and programs in the region. For example, we may receive and share information about you with individuals, businesses, government agencies and community programs that provide meals, emergency or low cost shelter, transportation, healthcare, behavioral health counseling and education services,, debt counseling or debt reduction services, tax preparation, employment and job training. This information will also be shared within our organization and with other providers in our referral network in order to provide you with services.In some situations,we may receive protected health information from your healthcare provider. In those situations, we may use and disclose your information only as permitted by the business associate agreement we have entered into with your provider or as expressly permitted by you or as permitted or required by law. Regardless of the source of information, 2-1-1 San Diego and its referral providers are committed to safeguarding your protected information from unlawful use and disclosure.
For information about the referral providers with whom we may share information, please visit: www.ciesandiego.org/parters
2-1-1 San Diego’s Responsibilities
Privacy Information:
Under California and Federal privacy laws we have a responsibility to maintain the privacy of “protected information.”We are required to provide you with this notice of our privacy practices, and follow the terms of the notice currently in effect. We must notify you when we become aware of unauthorized access, use or disclosure of your unsecured protected health and personally identifiable information.
Changes to this notice:
We reserve the right to change this notice at any time. We reserve the right to make the revised or changed notice effective for the protected information we already have about you as well as any protected information we receive about you in the future.
How to Obtain a Copy of this Notice:
We will post a copy of the current notice on our web site at: www.ciesandiego.org/privacy
A copy of the notice currently in effect will be available at the registration area of our facility located at 3860 Calle Fortunada, San Diego, CA 92123. You have a right to receive a paper copy of this Notice and a copy will be mailed to you upon request.
How 2-1-1 May Use and Disclose
Your Protected Information
How to Obtain a Copy of this Notice:
We may disclose protected information about you in accordance with the Privacy Laws, or as permitted by you or as permitted or required under state and federal laws. In some situations,we may disclose your information without your oral or written permission.The following list describes examples of different situations where we may use and disclose your information to individuals outside our organizations.
For more information on how we may use your health information visit:
http://www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html
Legally Permissible Uses and Disclosures of Information About You
To Contact You, a Family Member, Friend or Personal Representative:
When you call us, you will be asked to provide us with contact information for yourself and other persons involved in your care. If you do so, you give us permission to use that information to contact youand the individuals you have identified and to provide services to you by telephone, email or text. We may use the information to communicate necessary information about your appointments,to update you on your care or care management options,programs and benefits you or your family may be eligible for,or to connect you with any of our referral network providers and to follow up with our referral providers about services you have received or programs you have enrolled in. We may contact you or the individuals involved in your care by fax, cell phone, telephone, email or in writing.
To Verify Your Identity:
We may use your protected information and require you to provide us with a copy of a photo or other identification to verify your identity and link it to your record or communicate with you about your information.
Referral for Treatment, Care Coordination,Case Management and the Determination of Eligibility for Disability Benefits and Programs:
We may gather, use and disclose your protected information to network referral providers to facilitate the delivery of healthcare, care coordination,for health and human services agencies, case management, the determination of eligibility for governmental or other private program benefits, in an emergency or for other purposes permitted by you or permitted by or required by law. Our referral network providers may include doctors, nurses and other healthcare professionals, public health agencies and officials, insurers, social workers, housing officials, and other professionals that provide or coordinate healthcare, mental health or behavioral health treatment, housing and emergency shelter, transportation, education, food and financial assistance among other things. Different departments within our organization may also share protected information about you in order to coordinate the referral of services you need to and amongst members of our referral network.
For Payment, Qualification for Government Benefits:
We may disclose your protected information to insurance or managed care companies, Health and Human Services Agency, Medicare, Medicaid, Social Security Administration, Public Agencies, utility companies and other providers to assist in the payment of your bills, reduce debt, or tax liability or to qualify your government benefits or other programs.
For Business Operations:
We may use and disclose your protected information for our business operations. For example, we may use protected information to review the quality of our referral services, and to evaluate the performance of our staff. We may use your information for our business planning and program development, and to investigate complaints.
Business Associates:
We may use and disclose your protected information for our business operations. For example, we may use protected information to review the quality of our referral services, and to evaluate the performance of our staff. We may use your information for our business planning and program development, and to investigate complaints.
Marking and Fund Raising:
We may contact you to give you information about products, services or programs related to your treatment, case management, care coordination or other healthcare, social, and financial needs. We may also use demographic information and dates of service for our own fundraising purposes. If you do not want to receive fundraising material, you may choose to opt out of receiving those communications. We will not use or disclose your protected information for marketing purposes without your written authorization.
Disclosure Required by Law
We may use or disclose your protected information when required or permitted to do so by federal, state, or local law. The following are examples of some of the situations where we may be required to use or disclosure information about you without your consent:
Public Health Activities:
We may use or disclose your protected information when required or permitted to do so by federal, state, or local law. The following are examples of some of the situations where we may be required to use or disclosure information about you without your consent:
Health Oversight Activities:
We may disclose your protected information to a health oversight agency for activities authorized by law. Oversight activities may include audits; investigations; inspections; licensure or disciplinary actions; or civil, administrative, or criminal proceedings or actions. Oversight agencies include government agencies that oversee the health care system, government benefit programs, other government regulatory programs, and government agencies that ensure compliance with civil rights laws.
Lawsuits and Other Legal Proceedings:
We may disclose your protected information in the course of a judicial or administrative proceeding or in response to an order of a court or administrative tribunal,a subpoena, a discovery request, or other lawful process.
Law Enforcement:
We may be required to disclose your protected information to law enforcement officials for law enforcement purposes, such as to: (1) respond to a court order; (2) locate or identify a suspect, fugitive, material witness, or missing person; (3) report suspicious wounds, burns or other physical injuries; or (4) report a crime or identify a victim.
Abuse and Neglect:
We may disclose your protected information to a government authority that is authorized by law to receive reports of abuse, neglect, or domestic violence. If we believe you have been a victim of abuse, neglect, or domestic violence, we may disclose your protected health information to a governmental entity authorized to receive such information.
To Avert a Serious Threat to Health or Safety:
We may disclose your protected informationif disclosure is necessary to prevent or lessen a serious and imminent threat to your health or safety or the health or safety of another person or the public.
Research:
We may use and share your protected information for certain kinds of health or social services research. For example, a project may involve comparing the housing outcomes of all clients who received services from a referral agency to those received from another. Some research projects may require a special approval process and your written authorization. In some instances, the law allows us to do some research using your protected information without your approval.
Shared Medical Record/Health Information or Social Information Exchanges:
Some of our referral providers maintain protected information about their clients in a common electronic record that allows business associates to share protected information. We may participate in various electronic health or social information exchanges that facilitate the sharing of protected information among healthcare, health and human service agencies or other referral network providers.
Military:
If you are a member of the armed forces, we may use and disclose protected information as required by military command authorities, Department of Veteran Affairs, or other authorized federal officials.
Military:
If you are a member of the armed forces, we may use and disclose protected information as required by military command authorities, Department of Veteran Affairs, or other authorized federal officials.
National Security, Intelligence and Emergencies:
2-1-1 San Diego Notice of Privacy We may disclose health information about you to authorized federal officials for intelligence, counterintelligence and other national security activities authorized by law, and in emergencies.
Other Uses and Disclosure of Your Protected Information
Disclosures Requiring Your Written Authorization:
Most uses and disclosures of psychotherapy notes, substance use disorders, and uses and disclosures of protected health information, disclosures for marketing purposes and disclosures that constitute the sale of protected information require your written authorization. A written authorization may be created in paper or electronic format. Once received, we will store a copy of your authorization electronically.
Your Rights Regarding Your Protected Information