PRIVACY POLICY – PCCI

 Parkland Center for Clinical Innovation 
Notice of Privacy Practices and Security Policy Summary 

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.  

 This Notice also describes how we gather, use an disclose non-medical information.   

PLEASE REVIEW THIS NOTICE CAREFULLY. 

At the Parkland Center for Clinical Innovation (“PCCI”) we know you value your privacy.  That is why we are committed to the confidentiality and security of your health information.  We maintain physical, administrative, and technical safeguards to protect against unauthorized access, use, or disclosure of your health information, which we generally obtain from health care providers, health plans and government entities.  We are required by law to maintain the privacy and protect the security of this information and to explain our legal duties and privacy practices.  We collect and use this information to assist your health care providers, health plans and government entities in their health care operations or for research purposes. PCCI applies the practices described in this Notice of Privacy Practices and Security Policy Summary (“Notice”) to all health information that we collect, use or maintain.  PCCI may also gather, use and disclose non-medical information, as described in the “Non-Medical Information” section of this Notice We abide by the Notice that is currently in effect.  This Notice is effective July 15, 2020. 

Your Rights   

Inspection and Copies.  You have the right to request an inspection or copies of the health information that your health care provider or insurance (employee benefits) plan maintains about you in a “designated record set,” except for psychotherapy notes, certain information subject to the Clinical Laboratory Improvements Amendments of 1988, and information that we or your health care provider or insurance plan compiled in anticipation of, or for use in, a civil, criminal or administrative proceeding.  A “designated record set” is a group of records relating to your health care, payment for your health care, or that contains information your health care provider or insurance plan uses to make decisions about you.  If you make a request to PCCI related to your health information, we will forward your request to your health care provider or insurance plan to handle according to the policies they have in place.  We send your request along to the health care provider or insurance plan because as their “Business Associate” we are required to follow their rules.    We will keep a copy of your request for six years after the date we receive it.  

Notice.  You have the right to receive a paper copy of this Parkland Center for Clinical Innovation Notice of Privacy Practices and Security Policy Summary upon request. 

Accounting and Access.  You have the right to request a list of certain disclosures of your protected health information and may have a right to access that information and make corrections to it.  If you make a request to PCCI for accounting or access, we will send your request to your health care provider or insurance plan to answer according to their policies.    We will keep a copy of your request for six years after we receive it. 

 Complaints about Privacy Violations.  You have the right to submit a complaint if you believe PCCI has violated your privacy rights.  To submit a complaint, write to: Parkland Health & Hospital System, Privacy Officer, 5201 Harry Hines Blvd., Dallas, TX 75235 or call 214-590-1171.  You also have the right to submit a complaint to the Secretary of the U.S. Department of Public Health & Human Services.  Be assured that we will not retaliate against you for submitting a complaint. 

Complaints About the Security of Your Information.  If you believe your health information is not being treated in a secure manner, you may submit a complaint by writing to: Parkland Health & Hospital System, Chief Information Security Officer, 5201 Harry Hines Blvd., Dallas, TX 75235 or call 214-590-1171.  Be assured that we will not retaliate against you for submitting a complaint. 

Breach Notification.  IPCCI discovers an unauthorized use or disclosure of unsecured protected health information which constitutes a breach, you have the right to receive notice of the breach if it impacts protected health information PCCI maintained about you.  

Permitted Uses and Disclosures 

PCCI will follow the policies and procedures of your health care providers, insurance plans and government entities with respect to using and disclosing your health information.   In general, those policies and procedures permit the following uses and disclosures of your health information: 

Disclosure by your health care provider or insurance plan.  Your health care provider or insurance plan may use and disclose your health information according to legal requirements and their own policies. This Notice describes why PCCI may receive, use or disclose your health information on their behalf. 

Treatment.  PCCI may use and disclose health information to coordinate care with your health care providers or insurance plans, give your health care providers or insurance plans information about you or to assist with coordinating your care, such as by providing appointment or medication refill reminders. 

Operations.  PCCI may receive health information about you from your health care providers, insurance plans or government entities.  PCCI may use or disclose that health information to assist you, your health care providers or insurance planin facilitating health care operations, including purposes such as credentialing physicians, quality improvement programs, case management, and for the detection and prevention of fraud.  PCCI may also use or disclose your health information to fulfill PCCI’s obligations under government grants or government contracts but will only do so if the grant or contract specifically gives PCCI the right to use or disclose your health information. 

Research.  PCCI may receive health information about you when we are assisting a health care provider, insurance plan or government entity with research that has been approved as required by law.  PCCI may use or disclose the health information about you to assist with that approved research. 

Business Associates.  Occasionally, PCCI contracts with other Business Associates or vendors who agree to the same protections as PCCI does so that they can perform services on PCCI’s and our customer’s behalf.  We may disclose health information to these Business Associates or vendors.  They may also collect, use or disclose health information on our behalf.   Our Business Associates and vendors must provide the same privacy and security protections that we provide. 

Required by Law.  PCCI will use or disclose health information as required by law.   

Public Health Activities.  PCCI may use or disclose health information for public health activities.  These activities include prevention and control of disease or infection; activities performed by the medical examiner or coroner; organ or tissue donation and transplantation services; Food and Drug Administration activities; medical research; activities necessary to avert a serious threat to the health or safety of a person; and activities relating to the administration of workers’ compensation benefits. 

Health Oversight Activities.  PCCI may disclose health information to health oversight agencies.  These agencies are authorized by law to conduct audits, perform inspections and investigations, license hospitals and health care providers, oversee insurance plans and HMO’s, and to enforce regulatory requirements.  Examples of these types of agencies include the U.S. Department of Health & Human Services, the Centers for Medicare and Medicaid Services, the Texas Board of Medicine, the Texas Department of Insurance, the Texas Health & Human Services Commission and the U.S. Department of Labor. 

Legal Proceedings.  PCCI may disclose health information in the course of a judicial or administrative proceeding when lawful to do so or in response to a court order, subpoena, or discovery request 

Law Enforcement.  PCCI may disclose health information to law enforcement officials in response to a qualified administrative request, subpoena or warrant.  PCCI also may disclose limited health information for the purpose of reporting a crime on our premises or to locate a suspect, victim or witness. 

Military and National Security.  PCCI may disclose health information to armed forces personnel and to authorized federal officials for national security or intelligence activities. 

Correctional Institutions.  If you are an inmate, PCCI may disclose health information to your correctional institution for treatment purposes or to ensure the safety of yourself or others. 

Students and Trainees.  We may disclose health information to doctors, nurses, technicians, house-staff (including residents and interns), medical students, other health care students and other PCCI personnel to conduct training and education programs. 

Marketing.  PCCI does not sell protected health information for marketing purposes.  We do not use or disclose protected health information for marketing purposes without your authorization.  However, we may communicate with you about health-related products or services that may interest you or we may provide a promotional gift of nominal value. 

Others Involved in Your Care.  PCCI may disclose health information to persons/organizations involved in your care or who we believe reasonably may be involved in your care (e.g., because you have received a referral to them for follow up care) or organizations involved in the payment for your care (but only to the extent of their involvement).   

Fundraising.  PCCI may disclose limited information about you to the Parkland Foundation for fundraising.  You may opt out of these communications.  Be assured that your ability to receive treatment or services is not dependent on your willingness to participate in fundraising activities. 

Authorizations.  PCCI must obtain your authorization to use or disclose your health information for purposes other than those described in this Notice.  Your authorization is also required to disclose psychotherapy notes.  If you provide authorization, you have the right to revoke your authorization by notifying PCCI in writing.  Any revocation will not affect uses or disclosures made prior to your revocation.  

Non-Medical Information 

PCCI may from time to time gather, use and disclose non-medical information which may constitute Personally Identifiable Information or confidential information about individuals and businesses.   We will treat this non-medical information in accord with all applicable laws; government contracts or grants; and/or our agreements with the individuals or businesses who own or hold the non-medical information described above. 

Web Site Notice 

Web site notice.    Please do not submit health information via our “Contact Us” link on the PCCI web site.  Transmissions over the internet are never 100% secure or error free, and we will only accept health information if it comes from the government your health care provider or insurance plan or a Business Associate of theirs.  PCCI’s web site does not publish content targeted to children.  The web site is not intended to or directed at children 13 years old or under. 

Cookies 

Like most websites, the PCCInnovation.org website uses browser cookiesCookies are data files that a website sends to your browser/computer to be stored for the purpose of allowing the site to remember/recognize you. The PCCInnovation.org website utilizes browser cookies to monitor web traffic for our analytics, ensure security of the website, and validate the information you provide on our “Contact Us form. Most browsers are enabled to accept cookies. You have the option of resetting your browser settings to refuse cookies or monitor when cookies are being used. Please be aware that some features of the PCCInnovation.org website require the use of cookies. 

Email Addresses and Mailing Lists 

PCCI collects contact information through its “Contact Us” link for purposes of: (1) providing an electronic newsletter about PCCI’s organization, services and products to interested parties; (2) coordinating potential collaboration; (3) facilitating communication directly with PCCI; and (4) responding to requests regarding career opportunities. You may opt-out of the electronic newsletter at any time by replying to the email that sends the newsletter to you. We do not share any of the contact information collected through our “Contact Us” link with anyone outside PCCI.  

Contact Us 

Contact us.  If you have questions about our Notice of Privacy Practices and Security Policy Summary, please contact us at security@pccinnovation.org. 

Future Changes 

PCCI reserves the right to change our privacy practices, security policies and this Notice at any time without advance notice.  If we make a material change to our privacy practices, we will make a new, updated Notice available to you.  The new Notice will apply to all health information in our possession, including any information created or received before the revised Notice became effective. 

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