San Diego County CoC Homeless Management Information System (HMIS)
Summary of Privacy Practices
THIS NOTICE DESCRIBES HOW INFORMATION ABOUT YOU MAY BE USED SHARED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.
PLEASE READ IT CAREFULLY
Effective Date: April 21, 2016
Our Duty to Safeguard Your Protected Information
Lifeline Community Services collects information about who uses our services. We will ask for your permission to enter the information we collect about you and your family into a computer program called the Homeless Management Information System (HMIS) for the use of housing and services. Although the HMIS helps us to keep track of your information, individually identifiable information about you is considered “Protected Information.” We are required to protect the privacy of your identifying information and to give you notice about how, when and why we may use or disclose any information you may give us.
We are also required to follow the privacy practices described in this Notice, although Lifeline Community Services reserves the right to change our privacy practices and the terms of this notice at any time. You may request a copy of the notice from any agency that participates in the HMIS.
How We May Use and Share Your Information
We use and share collective information for a variety of reports. We have a limited right to include some of your information for reports on homelessness. Information that could be used to tell who you are will never be used for these reports. We will not turn your information over to a state, local, private, or national database without your consent. We must have your written consent to use or disclose your information unless the law permits or requires us to make the use or disclosure without your permission.
Please review the Client Consent to Share and/or Disclose Information for details. You must sign this form before we can use your information, but you do not have to sign the form in order to receive services.
Your Rights Regarding Your Information
✔ You have the right to get services even if you choose NOT to participate in the HMIS. However, clients may be refused program entry for not meeting other agency eligibility criteria.
✔ You have the right to ask for information about who has seen your information.
✔ You have the right to see your information and change it, if it is not correct.
✔ You have the right to revoke your consent to release information at any time. Information regarding the Client Revocation of Consent to Release Information is available at www.rtfhsd.org.
✔ You have the right to file a Grievance (complaint) if you feel your rights have been violated. Information regarding this HMIS Grievance Procedure is available at www.rtfhsd.org
San Diego County CoC HMIS Summary of Privacy Practices Approved by the Governance Board April 21, 2016 Updated June 23, 2020
THIS NOTICE DESCRIBES HOW INFORMATION ABOUT YOU MAY BE USED AND
DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE
REVIEW IT CAREFULLY.
At Lifeline Community Services, Inc. we are committed to treating and using Protected Health Information (PHI) about you responsibly. This Notice of Privacy Practices describes the personal information we collect and how and when we use or disclose that information. It also describes your rights as they relate to your protected health information. This notice is effective January 1, 2016, and applies to all protected health information as defined by federal regulations.
Understanding Your Health Record/Information
Each time you visit Lifeline Community Services, Inc. a record of your visit is made. Typically, this record contains your symptoms, examination and test results, diagnoses, treatment, and a plan for future care or treatment. This information, often referred to as your health or medical record,
serves as a:
- Basis for planning your care and treatment,
- Means of communication among the many health professionals who contribute to your care,
- Legal document describing the care you received,
- Means by which you or a third-party payer can verify that services billed were actually provided,
- A tool in educating health professionals,
- A source of data for medical research,
- A source of information for public health officials charged with improving the health of this state and the nation,
- A source of data for our planning and marketing, and
- A tool with which we can assess and continually work to improve the care we render and the outcomes we achieve. Understanding what is in your record and how your health information is used helps you to ensure its accuracy, better understand who, what, when, where, and why others may access your health information, and make more informed decisions when authorizing disclosure to others.
Lifeline Community Services, Inc. is required to:
- Maintain the privacy of your health information,
- Provide you with this notice as to our legal duties and privacy practices with respect to information we collect and maintain about you,
- Abide by the terms of this notice,
- Only use and disclose your information using the minimum necessary rule, meaning only those who need to know will have access to the relevant information,
- Notify you if we are unable to agree to a requested restriction, and
- Accommodate reasonable requests you may have to communicate health information by alternative means or at alternative locations.
We reserve the right to change our practices and to make the new provisions effective for all protected health information we maintain. Should our practices change, you will be able to view a current copy on our website at www.nclifeline.org. Additionally, current copies are kept in the lobby of all of our locations and a paper copy is available to you at any time. We will not use or disclose your health information without your authorization, except as described in this notice. We will also discontinue using or disclosing your health information after we have received a written revocation of the authorization according to the procedures included in the authorization. Examples of uses and disclosures related to treatment, payment and health care operations:
1. We will use your PHI for treatment.
For example, information obtained by a counselor, case manager, nurse, physician or other members of your health care team will be recorded in your record and used to determine the course of treatment that should work best for you. Your clinician will document in your record his or her expectations of the members of your health care team. Members of your health care team will then record the actions they took and their observations. In that way, the clinician will know how you are responding to treatment. We will also provide your clinician/physician or a subsequent health care provider with copies of various reports that should assist him or her in treating you once you are discharged from this
2. We will use your PHI to obtain payment for treatment.
We can use and disclose your PHI to bill and collect payment for the treatment and services provided to you by Lifeline Community Services, Inc. For example, we might send your PHI to your insurance company or health plan to get paid for the health care services that we have provided to you. We might also provide your PHI to business associates. There are some services in our organization that are provided through contacts with business associates. Examples include schools, case managers, agency providers, physician services, certain laboratory tests, and administrative services. When these services are contracted, we may disclose your health information to our business associate so that they can perform the job we’ve asked them to do and bill you or your third-party payer for services rendered. To protect your health information, however, we require the business associate to appropriately safeguard your information.
3. We will use your health care information for health care operations.
We can disclose your PHI to operate our agency. For example, we 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. We may also provide your PHI to our accountants, attorneys, consultants, and others to make sure we’re complying with applicable laws.
Examples of other disclosures:
We may also disclose your PHI to others without your consent in certain situations.
1. For emergency treatment
Your consent isn’t required if you need emergency treatment as long as we try to obtain your consent after treatment is rendered, or if we try to obtain your consent but you are unable to communicate with us (for example, if you are unconscious or in severe pain) and we think that you would consent to such treatment if you were able to do so.
2. When disclosure is required by federal, state or local law, judicial or administrative proceedings, or law enforcement
For example, we 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.
3. For public health activities
For example, we may need to report information about you to the county coroner.
4. For health oversight activities
For example, we may need to provide information to assist the government when it conducts an investigation or inspection of a health care provider or organization.
5. To avoid harm
In order to avoid a serious threat to the health or safety of a person or the public, we may provide PHI to law enforcement personnel or persons able to prevent or lessen such harm.
6. For workers’ compensation purposes
We may provide PHI in order to comply with workers’ compensation laws.
7. Appointment reminders and health related benefits or services
We may use PHI to provide appointment reminders, give you information about treatment or
treatment alternatives, or other health care services or benefits we offer.
Using professional judgement, we may use or disclose information to notify or assist in notifying
a family member, personal representative, or another person responsible for your care, your
location, and general condition.
9. Communication with family
Health professionals, using their best judgment, may disclose to a family member, other relative, close personal friend or any other person you identify, health information relevant to that person’s involvement in your care or payment related to your care.
We may disclose information to researchers when their research has been approved by an institutional review board that has reviewed the research proposal and established protocols to ensure the privacy of your health information.
11. Public health
As required by law, we may disclose your health information to public health or legal authorities charged with preventing or controlling disease, injury, or disability.
We may contact you as part of fundraising or marketing efforts to solicit donations from you. You will always be provided the option to no longer receive fundraising or marketing information.
13. Food and Drug Administration (FDA)
We may disclose to the FDA health information relative to adverse events with respect to food, supplements, product and product defects, or post-marketing surveillance information to enable product recalls, repairs, or replacement.
Disclosures that require your prior written authorization:
In any other situation not already described, we will ask for your written authorization before using or disclosing any of your PHI. This includes the sale of your PHI for marketing and most psychotherapy notes. 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 we haven’t taken any action in reliance on such authorization) of your PHI by us.
WHAT RIGHTS YOU HAVE REGARDING YOUR PHI
A. The right to request limits on uses and disclosures of your PHI. You have the right to ask that we limit how we use and disclose your PHI. We will consider your request, but we are not legally required to accept it. If we accept your request, we will put any limits in writing and abide by them except in emergency situations. You may not limit the uses and disclosures that we are legally required or allowed to make. Additionally, if you pay for a service or health care item out-of-pocket in full, you can ask us not to share that information with your health insurer for the purpose of payment or our operations.
B. The right to choose how we send PHI to you. You have the right to ask that we send information to you 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). We must agree to your request so long as we can easily provide the PHI to you in the format you requested.
C. The right to see and obtain copies of your PHI. In most cases, you have the right to look at or receive copies of your PHI that we have, but you must make the request in writing. If we don’t have the PHI but we know who does, we will tell you how to obtain it. We will respond to you within 15 days of receiving your written request regarding a decision to supply a copy and 5 days for a request for inspection. In some instances, a summary of your record or a denial of your request may be provided. In cases of denial, we will tell you, in writing, our reasons and explain your right to have the denial reviewed. We have the right to charge a reasonable fee for requested copies.
D. The right to obtain a list of those with whom we’ve shared information. You have the right to obtain a list of instances in which we have 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 will not include uses and disclosures made for national security purposes, to corrections or law enforcement personnel, or disclosures made before April 15, 2003.
E. We will respond to your request for an accounting of disclosures within 60 days of receiving your request. The list we will give you will include disclosures made in the last six years from the date of the request, 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. We will provide the list to you at no charge, but if you make more than one request in the same year, we will charge you a reasonable cost-based fee for each additional request.
F. The right to correct or update your PHI. If you believe that there is a mistake in your PHI or that an important piece of information is missing, you have the right to request that we correct the existing information or add the missing information. You must provide the request and your reason for the request in writing. We will respond within 60 days of receiving your request to correct or update your PHI. We may deny your request in writing if the PHI is (i) correct and complete, (ii) not created by us, (iii) not allowed to be disclosed, or (iv) is 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 do not file one, you have the right to request that your request and our denial be attached to all future disclosures of
your PHI. If we approve your request, we will make the change to your PHI, notify you when it has been done, and inform others that need to know about the change to your PHI.
G. The right to be notified in the event of a breach. Should your information be disclosed in a manner that compromises the privacy and security of your information, we will notify you promptly.
H. The right to obtain a copy of this request. You have the right to obtain 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. You may also read and obtain a copy of this notice at our website: www.nclifeline.org.
FOR MORE INFORMATION OR TO REPORT A PROBLEM:
If you have questions or would like additional information, you may contact Lifeline’s Privacy Officer, Human Resources Manager, at (760) 842-6253. If you believe your privacy rights have been violated, you may file a complaint with Lifeline’s Privacy Officer or with the Office for Civil Rights (OCR), U.S. Department of Health and Human
Services. The complaint must be filed within 180 days of the date of that the complainant knew or should have known about of the reported incident. There will be no retaliation for filing a complaint with either the Privacy Officer or the Office for Civil Rights. The contact information for the OCR is listed below:
U.S. Department of Health and Human Services
Office of Civil Rights
Centralized Case Management Operations
200 Independence Avenue, S.W.
Suite 515F, HHH Building
Washington, D.C. 20201
Telephone: (877) 696-6775
Federal law makes provision for your health information to be released to an appropriate health oversight agency, public health authority or attorney provided that a work force member or business associate believes in good faith that we have engaged in unlawful conduct or have otherwise violated professional or clinical standards and are potentially endangering one or more clients, workers, or the public.
Collection of your Personal Information
We do not collect any personal information about you unless you voluntarily provide it to us. In order to better provide you with the services offered on our Site, Lifeline Community Services may collect personally identifiable information, such as your:
- First and Last Name
- E-mail Address
- Phone Number
Use of your Personal Information
Lifeline collects and uses your personal information to operate its website and deliver the services you have requested. The information we collect is used to improve the content of our website and is not shared. Sharing Information with Third Parties Lifeline does not sell, rent, or lease personal information or consumer lists to third parties. Lifeline may share data with trusted partners, such as Mailchimp, to send you emails. All such third parties are prohibited from using your personal information except to provide these services to Lifeline, and they are required to maintain the confidentiality of your information.
Automatically Collected Information
Information about your computer hardware and software may be automatically collected by Lifeline. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Lifeline website.
The Lifeline website may use "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.
Do Not Track
Lifeline Community Services is a California based agency. We are subject to the regulations of the California Online Privacy Protection Act (CalOPPA), including the requirement to post the Do Not Track (DNT) disclosure. Lifeline does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track signals.
This website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information. Security of your Personal Information
Lifeline Community Services secures your personal information from unauthorized access, use, or disclosure. Lifeline uses the following methods for this purpose:
- SSL Protocol
We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100 percent secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.
Children Under Thirteen
Lifeline does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use this website.
If you would like to stop receiving marketing or promotional communications via email from Lifeline, you may opt out of such communications by clicking on the “Unsubscribe” button.
Changes to this Statement
Lifeline Community Services welcomes your questions or comments regarding this Statement of Privacy. If you believe that Lifeline has not adhered to this Statement, please contact Lifeline at: firstname.lastname@example.org
Lifeline Community Services
3142 Vista Way, Suite 400
Oceanside, CA 92056
Email Address: email@example.com
Telephone number: 760-726-4900
Please click for Lifeline’s Privacy Practices in English
Please click for Lifeline’s Privacy Practices in Spanish
Effective as of January 01, 2020