InHouse Physicians Privacy Policy/Notice 

WEB AND MOBILE PRIVACY POLICY

CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

HIPAA NOTICE OF PRIVACY PRACTICES

While using our website, you may provide us with certain information about you. We also may automatically collect information through the use of cookies.

Personal Information that we collect through your use of the Website may include:

• IP Address,
• Device ID, and
• online identifier.

We may use that Personal Information and link it to the Internet or other electronic network activity information, and we may draw inferences about you from the information we collect.

HOW WE COLLECT PERSONAL INFORMATION

We may collect Personal Information using the following methods:

• Directly from you when you provide it to us (such as information you enter into web forms, inquiries, responses, activity on the Website, and during registration to use a Secure Platform).
• From third parties, such as analytics and email marketing service providers.
• Automatically through tracking technologies such as cookies, web beacons (also known as pixels), and log files, including overtime and across a third-party website or other online services.
• "Cookies" are small files that a website stores on a user's computer or device. The Website may use cookies for various purposes, including to keep the information you enter on multiple pages together. Some of the cookies we use are "session" cookies, meaning that they are automatically deleted from your hard drive after you close your browser at the end of your session. Session cookies are used to optimize the performance of the Website and to limit the amount of redundant data that is downloaded during a single session. We also may use "persistent" cookies, which remain on your computer or device unless deleted by you (or by your browser settings). We may use persistent cookies for various purposes, such as statistical analysis of performance to ensure the ongoing quality of our services. We and third parties may use session and persistent cookies for analytics and advertising purposes, as described herein. Most web browsers automatically accept cookies, but you may set your browser to block certain cookies (see below). In accordance with applicable law, we may obtain your consent separately before collecting information by automated means using cookies or similar devices.

Our website may use Google Analytics, a vendor's service that uses cookies, web beacons, web pixels and/or similar technology to collect and store anonymous information about you. You can learn more about Google Analytics' privacy policy and ways to opt-out of Google Analytics tracking by visiting the Google Analytics website.

For more information about how we use Personal Information collected through tracking technologies and how you may be able to manage it, see below.



HOW WE USE YOUR INFORMATION

We may use your Personal Information for the following purposes:

• Operate, maintain, supervise, administer, and enhance the Website, including monitoring and analyzing the effectiveness of content on the Website, aggregated site usage data, and other usages of the Website, such as checking your eligibility and assisting you in completing the registration process.
• Provide you with a tailored and user-friendly experience navigating our website.
• Promote our website and market our services to you.
• To complete the activity you specifically asked for, e.g., register on a Secure Platform, obtain more information, request a demo, or request an RFP.
• Conduct research on users' demographics, interests, and behavior based upon information provided during the use of our Website.
• Anonymize and aggregate information for analytics and reporting.
• Respond to law enforcement requests and court orders, and legal process , carry out our legal and contractual obligations, and enforce our rights.
• Authenticate use, detect potentially fraudulent use and otherwise maintain the security of the Website and the safety of users.
• Develop, test, improve, and demonstrate the Website.
• Any other purpose consistent with your consent.

HOW WE SHARE YOUR INFORMATION

We may share Personal Information with third parties in certain circumstances or for certain purposes, including:

For business purposes. We may share your Personal Information with vendors and service providers, including our data hosting and data storage partners, analytics and advertising providers, technology services and support, and data security. We also may share Personal Information with professional advisors, such as auditors, law firms, and accounting firms. We may disclose your name, email address, date of birth, phone number, and address if you provided it to us via a form on the website or during an incomplete or failed registration to Service Providers.

With your direction or consent. We may share your Personal Information with third parties if you request or direct us to do so. This includes your use of social media widgets on our website.

With affiliates within our corporate group. We may share your Personal Information with any subsidiaries within our corporate group.

Compliance with the law. We may share your Personal Information to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.

In the context of a transaction. We may share your Personal Information in connection with an asset sale, merger, bankruptcy, or other business transaction.

For other business reasons. We may share your Personal Information to enforce any applicable Legal Disclaimer and ensure the safety and security of the Website and/or our users.



For advertising. Using cookies and web beacons, we may disclose Personal Information regarding your activity on our website to our advertising partners to optimize marketing. The Personal Information we share for this purpose is limited to IP address, device ID, and online identifier. We do not share identifying information such as names, email addresses, phone numbers, or any health information.

We also may disclose de-identified information. Note that if you make any Personal Information publicly available on the Website, anyone may see and use such information.

SOCIAL FEATURES

Certain features of the Website permit you to initiate interactions between the Website and third-party services or platforms, such as social networks ("Social Features"). Social Features include features that allow you to click and access InHouse Physicians pages on certain third-party platforms, such as Facebook, Twitter, and LinkedIn as applicable, and from there to "like" or "share" our content on those platforms. Use of Social Features may entail a third party's collection and/or use of your data. If you use Social Features or similar third-party services, the information you post or otherwise make accessible may be publicly displayed by the third-party service you are using. Both InHouse Physicians and the third party may have access to information about you and your use of both the Website and the third-party service.

THIRD PARTY WEBSITE AND LINKS

Our website may contain links to other online platforms operated by third parties. We do not control such other online platforms and are not responsible for their content, their privacy policies, or their use of your information. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Facebook, LinkedIn or Twitter) may also be viewable by other users of the Website and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Website. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of Personal Information by third parties. Any information submitted by you directly to these third parties is subject to that third party's privacy policy.

COOKIES AND INFORMATION USED FOR ADVERTISING

As discussed above, on our website, we may collect and disclose Personal Information about your online activities for use in providing you with advertising about products and services tailored to your individual interests. This section of our Privacy Policy provides details and explains how to exercise your choices. You may see certain ads on other websites because we participate in advertising networks. Ad networks allow us to target our messaging to users through demographic, interest-based and contextual means. These networks track your online activities over time by collecting information through automated means, including through the use of cookies, web server logs, and web beacons (also known as pixels). The networks use this information to show you advertisements that may be tailored to your individual interests. The information our ad networks may collect includes information about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the website. This data collection takes place both on our website and on a third-party website that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts.

Each type of web browser offers ways to restrict and delete cookies. For more information on how to manage cookies visit the appropriate link below.

Microsoft Internet Explorer

Microsoft Edge

Mozilla Firefox

Google Chrome

Apple Safari

Other

You may disable or delete browser cookies through your browser settings. Cookies generally are easy to disable or delete, but the method varies between browsers. If you disable or delete cookies, or if you are running third-party software that intercepts or deletes cookies, please note that some parts of our website may not work properly.

You can opt out of third parties collecting your Personal Information for targeted advertising purposes in the United States by visiting the National Advertising Initiative's (NAI) opt-out page and the Digital Advertising Alliance's (DAA) opt-out page.

Your browser settings also may allow you to transmit a "Do Not Track" signal when you visit various websites. Some of the websites may not be configured to respond to "Do Not Track" signals received from browsers. To learn more about "Do Not Track" signals, you can visit here.

If you have further questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

CHILDREN'S PRIVACY

Our website is not intended for children under 16 years of age, and we do not knowingly collect or sell Personal Information from children under 16. If you are under 16, do not use or provide any information on the website or through any of its features. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete it. If you are the parent or guardian of a child under 16 years of age whom you believe might have provided us with their Personal Information, you may contact us using the below information to request that it be deleted.

SECURITY OF PERSONAL INFORMATION

We take steps to secure Personal Information through administrative, technical, and physical safeguards designed to protect against the risk of accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Unfortunately, we cannot guarantee the security of information transmitted through the Internet, and where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential.

RETENTION OF PERSONAL INFORMATION

We generally retain records only as long as necessary and as required for our business operations, for archival purposes, and/or to satisfy legal requirements. When determining the appropriate retention period for Personal Information, we take into account various criteria, such as the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure; purposes for which we process your Personal Information; whether we can achieve those purposes through other means; and business operations and legal requirements. Because we maintain our website to protect from accidental or malicious loss and destruction, residual copies of your Personal Information may be retained in our backup and archival systems for a limited period of time, after which the information will be automatically deleted or put beyond use where deletion is not possible.

Server Log Information
We log IP addresses to analyze trends, administer the site, track patterns of page views, and gather broad demographic information, such as browser type, for aggregate use. iHP does not, however, link IP addresses to personally identifiable information.

• Cookies
  iHP, in common with many website operators, may use standard technology called cookies on this site. Cookies are small data files downloaded onto your computer when you visit a particular website. You can disable cookies by turning them off in your browser. However, some areas of this site may not function properly if you do so.

From job applicants, iHP may collect the following types of personal data: 

• First Name
• Last Name,
• Email Address,
• Resume
• Optional Cover Letter

PURPOSE AND LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

iHP processes personal data for the purposes of:

• Communicating with corporate business partners about business matters or possible contracts for the operation of the business;
• Conducting relevant tasks for legitimate business purposes, including marketing and advertising;
• Evaluating job candidates, profiling prospective customers, or building mailing lists for product information distribution;
• Human Resources administration and internal communications;
• Meeting legal or regulatory requirements and iHP’s internal policies;
• Management of travel, lodging, and related expenses; and
• Other purposes disclosed at the time of collection.

For EEA Visitors to the iHP website and those applying for employment with iHP, consent is the basis for processing personal data. For all other data subjects, such processing has been determined to be limited to processing based on the contractual and legitimate interest of IHP and the respective data subject to promote a business or employment relationship, as applicable.



RECIPIENTS OF PERSONAL DATA

We do not sell or rent, or otherwise dispose of the personal information collected on iHP.com or any other iHP controlled website to third parties that are not under contractual obligations to iHP for business-related processing (sub-processor). We may, however, disclose your personal information when required by law or in the good-faith belief that such disclosure is necessary to comply with local laws.

In addition, as a service provider (data processor) to its clients (data controllers), iHP may be in possession of client data that contains information defined as personal data. In performing these services, iHP does not process, store, or handle personal data in any other manner other than that directed by the primary data controller. Accordingly, iHP does not share, uniquely identify, or in any way use personal data for any commercial purpose other than that defined by the controller. In some cases, in accordance with our client agreements, we may disclose personal data with a subcontractor (sub-processor) contracted to provide services on our behalf to provide service to our clients.

iHP may also execute agreements with third parties to transfer personal data outside of the EU using European Commission-approved Standard Contract Clauses.

OUR COMMITMENT TO DATA SECURITY

This Site incorporates appropriate safeguards using industry-standard technology to heighten the security, accuracy, and privacy of any personal information we have collected. We have put in place reasonable precautions to protect information from loss and misuse. Our security and privacy policies are periodically reviewed and enhanced as required.

NOTICE TO CALIFORNIA RESIDENTS

If you are a California resident, certain Personal Information that we collect about you is subject to the California Consumer Privacy Act (CCPA). Please note that the CCPA does not apply to, among other things,

Information that is lawfully made available from federal, state, or local government records;

Consumer information that is deidentified or aggregated; protected health information that is collected by a covered entity or business associate governed by HIPAA or Medical information maintained by a provider of health care governed the Confidentiality of Medical Information Act (CMIA)

COLLECTION OF PERSONAL INFORMATION - CURRENTLY AND IN THE PRECEDING 12 MONTHS

We collect Personal Information as that term is defined by the CCPA, which is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include de-identified or aggregate information; publicly available information that is lawfully made available from federal, state, or local government records; and information covered by certain sector-specific privacy laws.

InHouse Physicians currently collects and has collected the following categories of Personal Information about consumers in the 12 months preceding the date this Privacy Policy was last modified:

• Identifiers
• Internet Protocol (IP) address
• Online identifier
• Device identifier

We may collect your name, email address, date of birth, phone number, and address only if you provided it to us via a form on the website or during an incomplete or failed registration.

Commercial information, business contact information if you have provided it to us via a form (such to register for services, obtain more information, request a demo, request an RFP) on the website, including name, company name, physical address, email address, telephone, and fax number; information on actions taken on our Website, which may include information about Website considered and information about preferences and behavior that we collect on our Website or purchase from third parties in order to target consumers for digital advertisements or to personalize content we deliver on our Website.

Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with the Website, applications, or advertisements. InHouse Physicians collects Personal Information from the following categories of sources:

Directly and indirectly from you, including through your interaction with the Website

• Social media platforms
• Third party partners such as analytics or marketing providers
• Automatically through tracking technologies.

We may use your Personal Information for the following purposes:

• Operate, maintain, supervise, administer, and enhance the Website, including monitoring and analyzing the effectiveness of content on the Website, aggregate site usage data, and other usage of the Website such as checking your eligibility and assisting you in completing the registration process.
• Provide you with a tailored and user-friendly experience as you navigate our website.
• Promote and market our website to you.
• To complete the activity you specifically asked for, e.g., register on a Secure Platform, obtain more information, request a demo, or request an RFP.
• Conduct research on users’ demographics, interests, and behavior based upon information provided during use of our Website.
• Anonymize and aggregate information for analytics and reporting.
• Respond to law enforcement requests and court orders and legal process and carry out our legal and contractual obligations and enforce our rights.
• Authenticate use, detect potential fraudulent use, and otherwise maintain the security of the Website and safety of users.
• Develop, test, improve, and demonstrate the Website.
• Any other purpose with your consent.

DISCLOSURE OF PERSONAL HEALTH INFORMATION IN THE PRECEDING 12 MONTHS

In the 12 months preceding the date of this Privacy Policy, InHouse Physicians has shared Personal Information with the following categories of third parties and has disclosed the following categories of Personal Information for a business purpose, for commercial purpose, to comply law, in the context of a transaction, or for other business reasons:

If you are a California resident, and in accordance with the CCPA, you have the right to:

Request to know and access the Personal Information we collect, use, and disclose;

• Request deletion of Personal Information;
• Opt-out of the sale of Personal Information; and
• Not receive discriminatory treatment by InHouse Physicians for exercising these rights.

REQUEST TO KNOW AND ACCESS

• You have the right to request that we disclose to you the following information:
• Categories of Personal Information that InHouse Physicians has collected about you, disclosed about you for a business purpose, or sold;
• Categories of sources from which the Personal Information is collected;
• Categories of third parties with whom InHouse Physicians shares or to whom InHouse Physicians sells Personal Information;
• The business or commercial purpose for collecting and selling Personal Information; and
• Specific pieces of Personal Information that InHouse Physicians has collected about you.
• Instructions for submitting a verifiable request are provided below.
• You may only make a request for access twice within a 12-month period.

REQUEST TO DELETE

You have the right to request that we delete Personal Information about you that we have collected, subject to certain exceptions. Instructions for submitting a verifiable request are provided below.



REQUESTS TO NOT SELL YOUR PERSONAL INFORMATION

InHouse Physicians does not sell your Personal Information.

During the past 12 months, we may have engaged in delivering online advertising that was tailored to your interests through the use of analytics and/or targeting cookies. We did not disclose data that would identify you by name, address, or phone number. Going forward, and before using analytics and/or targeting cookies, the Website will deploy a banner seeking your consent, or opt-in, to the use of such cookies.

As required under applicable law, we must take steps to verify your request before we can provide Personal Information to you, delete Personal Information, or otherwise process your request. To verify your request, we may require you to provide your name, physical address, email address, contact information, and information about your account or previous transactions with us. If you have only visited our public website and did not provide any Personal Information to us via a web form or through the registration process, we will need you to provide us with your IP address or device ID in order for us to determine if we have that information. We will not be able to determine if we have your IP address or device ID from your name, physical address, email address, contact information, or account information.

We will further verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as your date of birth or government identifier, in order to protect against fraudulent requests.

We will deliver Personal Information that we are required by law to disclose to you in the manner required by law within 45 days after receipt of a verifiable request, unless we notify you that we require additional time to respond, in which case we will respond within such additional period of time required by law. We may deliver the Personal Information to you electronically or by mail at your option. If electronically, then we will deliver the information in a portable and, to the extent technically feasible, in a readily useable format that allows you to transmit the information from one entity to another without hindrance.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us by the information provided in the "How to Contact Us" section below to make a request on your behalf. Even if you choose to use an agent, we may, as permitted by law, require verification of the agent's authorization to act on your behalf, require you to confirm you have authorized the agent to act on your behalf, or require you to verify your own identity.

RIGHT TO NONDISCRIMINATION

You have the right to be free from discriminatory treatment for exercising the privacy rights conferred by the CCPA, including not being: denied goods or services; charged different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provided a different level or quality of goods or services; or suggested that you will receive a different price or rate for goods or services or a different level or quality of goods or services.



UPDATING THIS PRIVACY POLICY

This Privacy Policy may be updated periodically to reflect changes in our privacy practices. It is your responsibility to review the Privacy Policy from time to time to view any such changes.

HIPAA NOTICE OF PRIVACY PRACTICES

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.

This Notice of Privacy Practices describes how we may use and disclose your protected health information to carry out treatment, payment or health care operations and for other purposes that are permitted or required by law. It also describes your rights to access and control your protected health information. “Protected health information” is information about you, including demographic information, that may identify you and that relates to your past, present or future physical or mental health or condition and related health care services.

We are required to abide by the terms of this Notice of Privacy Practices. We may change the terms of our notice, at any time. The new notice will be effective for all protected health information that we maintain at that time. Upon your request, we will provide you with any revised Notice of Privacy Practices. You may request a revised version by accessing our website or calling the office and requesting that a revised copy be sent to you in the mail or asking for one at the time of your next appointment.

USES AND DISCLOSURES OF PROTECTED HEALTH INFORMATION

Your protected health information may be used and disclosed by your physician, our office staff and others outside of our office who are involved in your care and treatment for the purpose of providing health care services to you. Your protected health information may also be used and disclosed to pay your health care bills and to support the operation of your physician’s practice.

Following are examples of the types of uses and disclosures of your protected health information that your physician’s office is permitted to make. These examples are not meant to be exhaustive, but to describe the types of uses and disclosures that may be made by our office.

Treatment: We will use and disclose your protected health information to provide, coordinate, or manage your health care and any related services. This includes the coordination or management of your health care with another provider. For example, we would disclose your protected health information, as necessary, to a home health agency that physicians who may be treating you. For example, your protected health information may be provided to a physician to whom you have been referred to ensure that the physician has the necessary information to diagnose or treat you. In addition, we may disclose your protected health information from time-to-time to another physician or health care provider (e.g., a specialist or laboratory) who, at the request of your physician, becomes involved in your care by providing assistance with your health care diagnosis or treatment to your physician.

Payment: Your protected health information will be used and disclosed, as needed, to obtain payment for your health care services provided by us or by another provider. This may include certain activities that your health insurance plan may undertake before it approves or pays for the health care services, we recommend for you such as: making a determination of eligibility or coverage for insurance benefits, reviewing services provided to you for medical necessity, and undertaking utilization review activities. For example, obtaining approval for a hospital stay may require that your relevant protected health information be disclosed to the health plan to obtain approval for the hospital admission.

Health Care Operations: We may use or disclose, as needed, your protected health information in order to support the business activities of your physician’s practice. These activities include, but are not limited to, quality assessment activities, employee review activities, training of medical students, licensing, fundraising activities, and conducting or arranging for other business activities.

We will share your protected health information with third-party “business associates” that perform various activities (for example, billing or transcription services) for our practice. Whenever an arrangement between our office and a business associate involves the use or disclosure of your protected health information, we will have a written contract that contains terms that will protect the privacy of your protected health information.

We may use or disclose your protected health information, as necessary, to provide you with information about treatment alternatives or other health-related benefits and services that may be of interest to you. You may contact the privacy officer to request that these materials not be sent to you.

We may use or disclose your demographic information and the dates that you received treatment from your physician, as necessary, in order to contact you for fundraising activities supported by our office. If you do not want to receive these materials, please contact Scarlet Wheeler and request that these fundraising materials not be sent to you.

Other Permitted and Required Uses and Disclosures That May Be Made Without Your Authorization or Opportunity to Agree or Object

We may use or disclose your protected health information in the following situations without your authorization or providing you the opportunity to agree or object. These situations include:

Public Health: We may disclose your protected health information for public health activities and purposes to a public health authority that is permitted by law to collect or receive the information. For example, a disclosure may be made for the purpose of preventing or controlling disease, injury or disability.

Communicable Diseases: We may disclose your protected health information, if authorized by law, to a person who may have been exposed to a communicable disease or may otherwise be at risk of contracting or spreading the disease or condition.

Health Oversight: We may disclose protected health information to a health oversight agency for activities authorized by law, such as audits, investigations, and inspections. Oversight agencies seeking this information include government agencies that oversee the health care system, government benefit programs, other government regulatory programs and civil rights laws.

Abuse or Neglect: We may disclose your protected health information to a public health authority that is authorized by law to receive reports of child abuse or neglect. In addition, we may disclose your protected health information if we believe that you have been a victim of abuse, neglect or domestic violence to the governmental entity or agency authorized to receive such information. In this case, the disclosure will be made consistent with the requirements of applicable federal and state laws.

Food and Drug Administration: We may disclose your protected health information to a person or company required by the Food and Drug Administration for the purpose of quality, safety, or effectiveness of FDA-regulated products or activities including, to report adverse events, product defects or problems, biologic product deviations, to track products; to enable product recalls; to make repairs or replacements, or to conduct post marketing surveillance, as required.

Legal Proceedings: We may disclose protected health information in the course of any judicial or administrative proceeding, in response to an order of a court or administrative tribunal (to the extent such disclosure is expressly authorized), or in certain conditions in response to a subpoena, discovery request or other lawful process.

Law Enforcement: We may also disclose protected health information, so long as applicable legal requirements are met, for law enforcement purposes. These law enforcement purposes include (1) legal processes and otherwise required by law,

• limited information requests for identification and location purposes,
• pertaining to victims of a crime,
• suspicion that death has occurred as a result of criminal conduct,
• in the event that a crime occurs on the premises of our practice, and
• medical emergency (not on our practice’s premises) and it is likely that a crime has occurred.

Coroners, Funeral Directors, and Organ Donation: We may disclose protected health information to a coroner or medical examiner for identification purposes, determining cause of death or for the coroner or medical examiner to perform other duties authorized by law. We may also disclose protected health information to a funeral director, as authorized by law, in order to permit the funeral director to carry out their duties. We may disclose such information in reasonable anticipation of death. Protected health information may be used and disclosed for cadaveric organ, eye or tissue donation purposes.

Research: We may disclose your protected health 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 protected health information.

Criminal Activity: Consistent with applicable federal and state laws, we may disclose your protected health information, if we believe that the use or disclosure is necessary to prevent or lessen a serious and imminent threat to the health or safety of a person or the public. We may also disclose protected health information if it is necessary for law enforcement authorities to identify or apprehend an individual.

Military Activity and National Security: When the appropriate conditions apply, we may use or disclose protected health information of individuals who are Armed Forces personnel (1) for activities deemed necessary by appropriate military command authorities; (2) for the purpose of a determination by the Department of Veterans Affairs of your eligibility for benefits, or (3) to foreign military authority if you are a member of that foreign military services. We may also disclose your protected health information to authorized federal officials for conducting national security and intelligence activities, including for the provision of protective services to the President or others legally authorized.

Workers’ Compensation: We may disclose your protected health information as authorized to comply with workers’ compensation laws and other similar legally-established programs.

Inmates: We may use or disclose your protected health information if you are an inmate of a correctional facility and your physician created or received your protected health information in the course of providing care to you.

Uses and Disclosures of Protected Health Information Based upon Your Written Authorization

Other uses and disclosures of your protected health information will be made only with your written authorization unless otherwise permitted or required by law as described

below. You may revoke this authorization in writing at any time. If you revoke your authorization, we will no longer use or disclose your protected health information for the reasons covered by your written authorization. Please understand that we are unable to take back any disclosures already made with your authorization.

Your prior written authorization is required for:

1)        Most uses and disclosures of psychotherapy notes (if applicable).

2)        Uses and disclosures of PHI for marketing purposes.

3)        Disclosures of PHI that constitute a “sale”.

Other Permitted and Required Uses and Disclosures That Require Providing You the Opportunity to Agree or Object

We may use and disclose your protected health information in the following instances. You have the opportunity to agree or object to the use or disclosure of all or part of your protected health information. If you are not present or able to agree or object to the use or disclosure of the protected health information, then your physician may, using professional judgment, determine whether the disclosure is in your best interest.

Others Involved in Your Health Care or Payment for your Care: Unless you object, we may disclose to a member of your family, a relative, a close friend or any other person you identify, your protected health information that directly relates to that person’s involvement in your health care. If you are unable to agree or object to such a disclosure, we may disclose such information as necessary if we determine that it is in your best interest based on our professional judgment. We may use or disclose protected health information to notify or assist in notifying a family member, personal representative, or any other person that is responsible for the care of your location, general condition, or death. Finally, we may use or disclose your protected health information to an authorized public or private entity to assist in disaster relief efforts and to coordinate uses and disclosures to family or other individuals involved in your health care.

YOUR RIGHTS

• Following is a statement of your rights with respect to your protected health information and a brief description of how you may exercise these rights.
• You have the right to receive electronic copies of your health information.
• You have the right to opt-out of any communication made to you for fundraising purposes. Each fundraising communication will specify the opt-out option(s) available
• You have the right to inspect and copy your protected health information. This means you may inspect and obtain a copy of protected health information about you for so long as we maintain the protected health information. You may obtain your medical record that contains medical and billing records and any other records that your physician and the practice use for making decisions about you. As permitted by federal or state law, we may charge you a reasonable copy fee for a copy of your records.
• Under federal law, however, you may not inspect or copy the following records: psychotherapy notes; information compiled in reasonable anticipation of, or use in, a civil, criminal, or administrative action or proceeding; and laboratory results that are subject to law that prohibits access to protected health information. Depending on the circumstances, a decision to deny access may be reviewable. In some circumstances, you may have a right to have this decision reviewed. Please contact Scarlet Wheeler if you have questions about access to your medical record.
• You have the right to request a restriction of your protected health information. This means you may ask us not to use or disclose any part of your protected health information for the purposes of treatment, payment or health care operations. You may also request that any part of your protected health information not be disclosed to family members or friends who may be involved in your care or for notification purposes as described in this Notice of Privacy Practices. Your request must state the specific restriction requested and to whom you want the restriction to apply.
• Your physician is not required to agree to a restriction that you may request. If your physician does agree to the requested restriction, we may not use or disclose your protected health information in violation of that restriction unless it is needed to provide emergency treatment. With this in mind, please discuss any restriction you wish to request with your physician.
• You have the right to restrict certain disclosures of PHI to health plans when you have paid in full for the health care item or service. We are required to comply with your request no to disclose health information to a health plan when you have paid in full out-of-pocket for the item or service.
• You have the right to request to receive confidential communications from us by alternative means or at an alternative location. We will accommodate reasonable requests. We may also condition this accommodation by asking you for information as to how payment will be handled or the specification of an alternative address or other methods of contact. We will not request an explanation from you as to the basis for the request. Please make this request in writing to our Privacy Officer.
• You may have the right to have your physician amend your protected health information. This means you may request an amendment of protected health information about you in a designated record set for so long as we maintain this information. In certain cases, we may deny your request for an amendment. If we deny your request for amendment, you have the right to file a statement of disagreement with us and we may prepare a rebuttal to your statement and will provide you with a copy of any such rebuttal. Please contact our Privacy Officer if you have questions about amending your medical record.
• You have the right to receive an accounting of certain disclosures we have made, if any, of your protected health information. This right applies to disclosures for purposes other than treatment, payment or health care operations as described in this Notice of Privacy Practices. It excludes disclosures we may have made to you if you authorized us to make the disclosure, for a facility directory, to family members or friends involved in your care, or for notification purposes, for national security or intelligence, to law enforcement (as provided in the privacy rule) or correctional facilities, as part of a limited data set disclosure. You have the right to receive specific information regarding these disclosures that occur after April 14, 2003. The right to receive this information is subject to certain exceptions, restrictions and limitations.
• You have the right to receive a notification of a breach of your unsecured PHI in appropriate circumstances. We have an obligation to notify you of a breach of our unsecured PHI.
• You have the right to obtain a paper copy of this notice from us, upon request, even if you have agreed to accept this notice electronically.

HOW TO CONTACT US

Should you have other questions or concerns about these privacy policies and practices, please call us at or 1.800.356.3627 (toll-free), or send us an e-mail at privacy@iHPhysicians.com. If you wish to review or change information gathered about you via the InHouse Physicians website but you do not know how, the Privacy Officer will assist in locating the persons responsible for that site so that you may make your request directly to them.



HOW ACCESS TO, MODIFICATION, AND DELETION OF PERSONAL INFORMATION

EU and US data subjects are permitted to exercise the right to access, correct, restrict, object to, update, move, or delete any personal data collected and stored by IHP. IHP may have a legitimate or legal basis to retain certain personal information. IHP will respond to all requests within 30 days.



MAILING ADDRESS

InHouse Physicians

Attention: Privacy Officer

1560 Wall St

Suite 335,

Naperville, IL 60563