Notice of Privacy Practices & Confidentiality of Alcohol and Drug and Alcohol Abuse Student Records
Effective date: 5 September 2015
THIS NOTICE DESCRIBES HOW HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
- CONFIDENTIALITY OF HEALTH INFORMATION. Health information which we receive and/or create about you, personally, in this programme, relating to your past, present, or future health, treatment, or payment for health care services, is “sensitive personal data” under Data Protection Laws. The confidentiality of drug and alcohol abuse student records maintained by this programme is protected. Generally, the programme may not say to a person outside the programme that you attend the programme, or disclose any information identifying you as an alcohol or drug abuser, or use or disclose any other sensitive personal data except in limited circumstances as permitted by law.
- THE CENTRE’S PLEDGE REGARDING HEALTH INFORMATION. The Centre understands that health information about you and your health is personal. The Centre is committed to protecting health information about you. In order to provide you with quality service and to comply with legal requirements, the Centre creates a record of the services you receive at the Centre. This Notice of Privacy Practices & Confidentiality of Drug and Alcohol Abuse Student Records (the “Notice”) applies to all of the records of your service generated by the Centre. This Notice will tell you about the ways in which the Centre may use and disclose sensitive personal data about you. It also describes your rights and certain obligations the Centre has regarding the use and disclosure of sensitive personal data. The Centre is required by law to make sure that health information that identifies you is kept private.
- WHO IS BOUND BY THE NOTICE. This Notice describes the Centre’s practices and those of Centre staff, volunteers, and other personnel who are involved in your services. The Centre and these individuals will follow the terms of this Notice, and may use or disclose health information about you as permitted or required by law. This Notice describes your rights to access and control health information about you, including information that may identify you and that relates to your past, present, or future physical health or mental condition, and health care and related health care services. Your personal doctor may have other policies that he or she follows.
- HOW THE CENTRE MAY USE AND DISCLOSE
HEALTH INFORMATION ABOUT YOU. The Centre collects health information about you and stores it in a chart, on a computer, and in a personal health record. This is your medical record. The medical record is the property of the Centre, but the information in the medical record belongs to you. The following categories describe different ways that the Centre may use or disclose health information. For each category of uses and disclosures, the Centre will explain what is meant and may give some examples. Not every use or disclosure in a category will be listed. However, all of the ways the Centre is permitted to use and disclose information will fall within one of the categories.
4.1. For Internal Communications. Your health information will be used within our programme between and among programme staff who have a need for the information, in connection with our duty to diagnose, treat, or refer you for substance abuse treatment. This means that your health information may be shared between or among personnel for treatment, payment or health care operation purposes. For example: Two or more providers within the programme may consult with each other regarding your best course of treatment. The programme may share your health information in order to receive payment for health care services rendered to you. And/or, your health information may be discussed within the programme about your treatment in connection with others in the programme, in an effort to improve the overall quality of care provided by our programme. Your health information will not be re-disclosed by programme personnel except as is otherwise permitted herein.4.2. To Qualified Service Organizations and/or Business Associates. Some or all of your health information may be subject to disclosure through contracts for services with qualified service organizations and/or business associates, outside of this programme, that assist our programme in providing health care. Examples of qualified service organizations and/or business associates include billing companies, data processing companies, or companies that provide administrative or speciality services. To protect your health information, we require these qualified service organizations and/or business associates to follow the same standards held by this programme through terms detailed in a written agreement. This may involve the transfer of data about you to the Centre’s associates in another country.4.3. In Medical Emergencies. Your health information may be disclosed to medical personnel in a medical emergency, when there is immediate threat to your health, and when immediate medical intervention is required.4.4. To Researchers. Under certain circumstances, this office may use and disclose your health information for research purposes. For example, a research project may involve comparing the health and recovery of all patients who received one test or treatment to those who received another, for the same condition. All research projects, however, must be approved by a Board which has reviewed the research proposal and established protocols to ensure the privacy of your health information.4.5. To Auditors and Evaluators. This programme may disclose health information to regulatory agencies, funders, third-party payers, and peer review organizations that monitor alcohol and drug programmes to ensure that the programme is complying with regulatory mandates and is properly accounting for and disbursing funds received.4.6. Pursuant to Authorising Court Order. This programme may disclose your health information pursuant to an authorizing court order.4.7. Crime on Programme Premises or Against Programme Personnel. This programme may disclose a limited amount of health information to the police when a student commits or threatens to commit a crime on the programme premises or against programme personnel. The law does not protect any information about a crime committed by a student either at the programme or against any person who works for the programme or about any threat to commit such a crime.4.8. Reporting Suspected Child Abuse and Neglect.This programme may report suspected child abuse or neglect. The law does not protect any information about suspected child abuse or neglect from being reported to appropriate authorities.4.9. As Required By Law. This programme will disclose health information as required by law.4.10. Appointment Reminders. This programme reserves the right to contact you, in a manner permitted by law, with appointment reminders or information about treatment alternatives and other health related benefits that may be appropriate to you.4.11. Other Uses and Disclosure of Health Information. Other uses and disclosures of health information not covered by this Notice will be made only with your written authorization or that of your legal representative. If you or your legal representative authorize us to use or disclose health information about you, you or your legal representative may revoke that authorization, at any time, except to the extent that we have already taken action relying on the authorization.
- YOUR RIGHTS REGARDING HEALTH INFORMATION WE MAINTAIN ABOUT YOU. You have the following rights regarding your health information. In order to exercise these rights, you must contact the Data Protection Officer at the Centre. You may be asked to submit a written request. The Data Protection Officer may be contacted using the following information:
Attn: Data Protection Officer
Phone: +20 100 2 671 671
5.1. Right to Inspect and Copy. With certain exceptions, you have the right to inspect and receive copies of your health information that we maintain about you. In some very limited circumstances we may, as authorized by law, deny your request to inspect and obtain a copy of your health information. You will be notified of a denial to any part or parts of your request. Some denials, by law, are reviewable, and you will be notified regarding the procedures for invoking a right to have a denial reviewed. Other denials, however, as set forth in the law, are not reviewable. Each request will be reviewed individually, and a response will be provided to you in accordance with the law.5.2. Right to Amend Your Health Information. If you believe that health information about you is incorrect or incomplete, you may ask the Centre to amend the information. We may deny your request if it is not in writing or does not include a reason that supports the request. In addition, we may deny your request if you ask us to amend health information that we believe: (i) is accurate and complete; (ii) was not created by us, unless the person or entity that created the health information is no longer available to make the amendment; (iii) is not part of the health information kept by or for us; or (iv) is not part of the health information which you would be permitted to inspect and copy. If your right to amend is denied, we will notify you of the denial and provide you with instructions on how you may exercise your right to submit a written statement disagreeing with the denial and/or how you may request that your request to amend and a copy of the denial be kept together with the health information at issue, and disclosed together with any further disclosures of the health information at issue.5.3. Right to an Accounting of Disclosures. You have the right to receive a list of certain disclosures that we may have made of your health information. This list will not include certain disclosures: those made for treatment, payment, or health care operations within our programme or made pursuant to your authorization or made directly to you.5.4. Right to Request Restrictions. You have the right to request a restriction or limitation on the health information that the Centre uses or discloses about your treatment, payment or health care operations within our programme. While we will consider your request, we are not required to agree to it. If we do agree to it, we will comply with your request, except in emergency situations where your health information is needed to provide you with emergency treatment. We will not agree to restrictions on uses or disclosures that are legally required, or those which are legally permitted and which we reasonably believe to be in the best interest of your health.5.5. Request Confidential Communications. You have the right to request that the Centre communicate with you about your health information in a specific way or at a specific location. For example, you can ask that we only contact you at work or by mail. We will accommodate all reasonable requests.5.6. Right to File a Complaint. If you have any questions or believe that your privacy rights have been violated, you may contact the Centre’s Data Protection Officer in person or mail a written summary of your concern to the address listed above. You will not be penalized or retaliated against for filing a complaint.5.7. Receive a Copy. You have the right to obtain a copy of this Notice.
- CHANGES TO THIS NOTICE. The Centre reserves the right to change the terms of this Notice at any time. The Centre reserves the right to make the revised or changed notice effective for health information the Centre already has about you as well as any health information the Centre receives in the future. The Centre will post a copy of the current Notice. The Notice will contain an effective date.