Notice of Privacy Practices
Last Updated: November 2023
This Notice of Privacy Practices (“Notice”) provides information regarding our privacy practices and applies to Protected Health Information (“PHI”) that is created, received and/or maintained at Belle, including any information that we receive from any other organizations. This Notice describes the ways in which Belle may use or disclose PHI and describes individual rights as well as its obligations regarding such uses or disclosures. Belle will abide by the terms of this Notice, including any future revisions that we may make to the Notice as required or authorized by law. Belle reserves the right to change or modify this Notice and apply to PHI that it currently has as well as any information it receives in the future.
Summary of PHI
Belle is committed to protecting the privacy of information. Examples of PHI include:
- Information about your health condition;
- Information about health care services;
- Information about health care benefits under an insurance plan;
- Demographic information (such as race, gender, ethnicity, or marital status);
- Identification numbers (such as social security number, telephone number, or driver’s license);
- Other types of identifiable information.
Important Summary Information
Belle will generally obtain written authorization before using PHI or sharing it with others outside its
organization. Belle must have a written authorization for the use or disclosure of PHI for marketing purposes, the sale of PHI, and/or other uses or disclosures not otherwise covered by this Notice or required by law. Authorizations may be revoked at any time, except to the extent that Belle has already relied upon it. To revoke an authorization, please contact our Privacy Officer.
There are situations in which written authorization is not required before using or sharing PHI:
- Exception for Treatment, Payment, and Health Care Operations. PHI may be used or disclosed for the purpose of treatment payment or health care operations (“TPO”);
- Exception for disclosure to friends and family. Friends or family directly involved in patient care may be granted an exception;
- Exception in emergencies or public health need;
- Exception if information does not identify. Information is no longer considered PHI if identifiable information has been removed.
How to Access PHI
You have the right to inspect and obtain a copy of any of your PHI for as long as Belle maintains this
information in its records. To inspect or obtain a copy of your PHI, please submit your request in writing to our Privacy Officer. You have the right to request that we send a copy of your health information to any third party. Written request must be made that clearly identifies the name and complete address of the party you wish to receive a copy. You must also specify what portion of your health information, if not all, is to be provided.
You may request that Belle provides a copy of your PHI in an electronic format and will do so if the PHI is maintained in that format. If that format is not feasible, Belle may provide the PHI using the electronic format that maintains it. Belle does not expect to incur additional expense to accommodate an electronic format request.
Belle will ordinarily respond to requests within thirty (30) days. If additional time is needed (which will not exceed 30 days), Belle will provide written notification within the time frame to explain the reason for the delay and when a final answer can be expected to the request. Under certain very limited circumstances, Belle may deny a request to inspect or obtain a copy of PHI. If Belle denies part or all a request, a written denial will be provided that explains the reasons for doing so as well as a complete description of your rights to have that decision reviewed and how you can exercise those rights. We will also include information on how to file a complaint about these issues with us or with the Secretary of the Department of Health and Human Services.
Right to Amend PHI
You have the right to request that Belle amend PHI that is believed to be inaccurate or incomplete. You have the right to request an amendment for as long as the PHI is maintained by Belle. Requests for amendment are to be made in writing to Belle’s Privacy Officer and include the reasons requesting the amendment. Belle will typically respond to the request within thirty (30) days. If additional time to respond is needed (which will not exceed 30 additional days), Belle will provide written notification within the time frame to explain the delay as well as when the final answer is to be expected.
If we deny part or the entire request, Belle will provide a written explanation regarding the reasons for doing so. Information relating to the amendment will become part of the PHI. For example, if you disagree with Belle’s decision, you will have an opportunity to submit a statement which we will include as part of the PHI. Belle will also include information on how to file a complaint with us or with the Secretary of the Department of Health and Human Services.
How to Manage how PHI has been Shared
You have the right to receive a list from us, called an “accounting list,” which provides information about when and how Belle has disclosed PHI to outside persons or organizations. The accounting will not include PHI disclosures that were conducted under the TPO exception. The list will not include disclosures you have authorized. Examples of PHI disclosure not under TPO include:
- Public Health Emergencies;
- Public Health Activities;
- Events requiring PHI release by law (such as a subpoena, law enforcement, lawsuits, disputes);
- Workers compensation or other programs that provide benefits for work-related injuries;
- Events that prevent a serious threat to your health and safety or another person.
A copy of the full accounting list can be obtained by contacting Belle’s Privacy Officer. The request must state a time for the disclosures. Belle typically responds to an accounting list within thirty (30) days. If additional time is needed (which will not exceed 30 days), Belle will provide written notification about the reason for the delay and the date when the list can be expected.
How to Request Additional Privacy Protections
You have the right to request further restrictions on the way your PHI is used or shared with others. Subject to applicable law, Belle is not required to agree to the requested restrictions; however, if granted, Belle will be bound by the agreement.
You have the right to request that we further restrict the way PHI is used to arrange for treatment of a health condition, collect payment or for normal healthcare business operations. You may also request that we limit how we disclose PHI to others involved in your healthcare. To request restrictions, please write to our Privacy Officer. Your request should be signed and dated and should include (1) full details regarding what information is limited; (2) how the information is to be limited and/or shared with others; and (3) to whom the limits apply. You have the right, to which we must agree, to request we not disclose or limit disclosure to your health plan about treatment provided so long as it has been paid separately from the health plan.
Except with respect to your right to restrict disclosure to a health plan under the circumstances described above, Belle is not required to agree to restriction requests, and in some cases the restriction may not be permitted under law. If Belle does agree, it will be bound by the agreement unless the PHI is needed to provide emergency treatment or comply with the law. Once we have agreed to a restriction, you have the right to revoke it at any time. Under some circumstances, Belle may also have the right to revoke the restriction if we notify you before doing so. In most cases, Belle will need written permission before a restriction can be revoked.
How to Request More Confidential Communications
You have the right to request that Belle contact you in a way that is more confidential, such as at home instead of at work. Belle will try to accommodate all reasonable requests. You have the right to name a personal representative who may act on your behalf to control the privacy of your PHI. To request more confidential communications, please write to our Privacy Officer. Belle will not ask the reasons for the request and will try to accommodate all reasonable requests.
Special Protections For HIV, Substance Abuse, and Mental Health Information
Special privacy protections apply to HIV-related information, substance abuse and mental health information. Some parts of this Notice may not apply to these types of information. If your PHI involves this information, you should contact our Privacy Official for more information.
Events Involving PHI for Research
In most cases, Belle will ask for written authorization before using or sharing PHI for research. However, under some circumstances, Belle may use and disclose PHI without authorization if the information is obtained through a de-identification process to ensure it poses minimal risk to privacy. Under no circumstances should researchers be permitted to use names or identify persons publicly without written authorization. PHI that is viewed for research purposes will also not be permitted to be removed from a Belle office.
How to Obtain a Copy of This Notice
You may request a paper copy of this Notice at any time, even if previous copies were received electronically. To do so, please call our Privacy Officer. We may change our privacy practices from time to time and will revise this Notice so that the summary of our practices is up to date. The revised Notice will apply to all PHI, whether collected before or after the effective date of the Notice.
How to File a Complaint
If you believe your privacy rights have been violated, you may:
- File a complaint with Belle’s Privacy Officer at firstname.lastname@example.org
- File a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting https://www.hhs.gov/ocr/privacy/hipaa/complaints/.
- No one working for or in association with Belle will retaliate or take any action against you for filing a complaint.
Rights to Access and Control of PHI
Belle respects individuals’ rights regarding PHI. These rights are important because they will help you make sure that your PHI is accurate. They may also help you control the way we use your information and share it with others, or the way we communicate with you about your medical matters.