NOTICE OF PRIVACY PRACTICES

If you have any questions about this Notice, please contact our Privacy Contact who is the Chief Information and Security Officer, and who may be reached c/o PinnacleCare, 250 West Pratt Street, Suite 1100, Baltimore, Maryland, 21201 USA. WE ARE COMMITTED TO PROTECTING YOUR HEALTH INFORMATION.

You are a Consultee of PinnacleCare. As a Consultee, you may give, or authorize others to give, medical or health information to us about you or others in your family. “Confidential Health Information” means any written health information related to care provided to you or other members of your family receiving consultation services from PinnacleCare that is or has been created or received by any of your health care providers, that relates to your past, present or future physical or mental health or condition, and that is in our possession. This Notice of Privacy Practices describes how we may use and disclose that Confidential Health Information. It also describes what you may do to control your Confidential Health Information.

We are strongly committed to protecting the confidentiality of your medical information. We may maintain a medical record about your care because one of the benefits of being a Consultee is to have access to a platform that will enable people (whom you have selected or authorized) to have access to some or all of your Confidential Health Information. We may use certain Confidential Health Information in our day to day operations. This Notice will let you know about the various ways we use and disclose your Confidential Health Information and describe your privileges and our obligations with respect to the use or disclosure of your Confidential Health Information.

 

OUR USES AND DISCLOSURES OF YOUR CONFIDENTIAL HEALTH INFORMATION

Your Confidential Health Information may be disclosed to others outside of PinnacleCare who are involved in your care and treatment (“Providers”) for the purpose of enabling them to better know and understand your medical history and assist them in providing health care services to you. For example, if you have sent us, or authorized someone else to send us, some or all of your medical history, we may send part or all of the information we have received to a physician, hospital or similar institution to permit them to conduct an initial review of your history to make a preliminary assessment of your suitability for treatment by them or at their facility. In so doing, we are acting strictly as an intermediary, following your direction, and are not in any manner providing medical care of any sort or making any medical assessment or decision. Your Confidential Health Information may also be used and disclosed to assist you in securing payment for your health care bills. However, except for Providers, only individuals whom you have identified to us, or to whom you have chosen to give the unique identifier we will supply you, will have the authority to receive or access your Confidential Health Information from us. It is up to you whether you want anyone to have the authority to access your Confidential Health Information, but once you have authorized an individual to have access (including by giving someone your unique identifier), we will permit such person(s) access to your Confidential Health Information in our possession until you revoke the authorization. That access may be provided through the use of various media, and in the future may include providing electronic access through our web site. You may limit access to your Confidential Health Information to specific time frames as well as to specific persons, but unless you instruct us not to send your Confidential Health Information to specific physicians or institutions, we will send your Confidential Health Information that is in our possession to Providers that are involved in your medical care until you revoke the authorization.

Other possible uses of your Confidential Health Information include:

Health Related Benefits and Services. A key feature of our approach to service is to proactively look for techniques and new ideas designed to improve your health and wellbeing. We will not disclose your Confidential Health Information to third parties in connection with these activities, but PinnacleCare may consider your Confidential Health Information in the process of our careful screening of these ideas to select only those that we feel are appropriate to pass along to you. You may contact our Privacy Contact to request that these materials not be sent to you.

Sale. If we decide to sell PinnacleCare or merge or combine with another company, we may share your Confidential Health Information with the successor entity.

With Your Authorization. Other uses and disclosures of your Confidential Health Information will be made only with your Authorization, unless otherwise required by law. We cannot obtain any of your Confidential Health Information unless you sign an Authorization permitting your health care Providers to send it to us or give it to us yourself. You may revoke your Authorization, at any time, in writing. You understand that we cannot take back any use or disclosure we may have made under the Authorization before we received your written revocation. The Authorization is a separate document, and you will have the opportunity to review any Authorization before you sign it. We will not condition your Service Option on whether or not you sign any Authorization, but you will not be able to use our medical record data base unless you sign and keep in effect an Authorization.

To Others Involved in Your Healthcare. At PinnacleCare, we believe that you should determine who has access to your own Confidential Health Information. Of course, physicians, hospitals and other institutions that are directly providing care to you must have access to your information in the normal course of treating you. With respect to others involved in your care, we will follow your instructions about disclosing any of your Confidential Health Information. We may disclose Confidential Health Information to a consultee of your family, a relative, a close friend, an associate or any other person you identify, orally or in writing, when that confidential health information directly relates to that person’s involvement in your health care, unless you have instructed us in writing not to do so. We may use or disclose your Confidential Health Information to notify or assist in notifying a family consultee, personal representative or any other person that is responsible for your care, of your location or general condition, unless you have instructed us in writing not to do so.

If Required By Law. We may use or disclose your Confidential Health Information to the extent that the use or disclosure is required by federal, state or local law. You will be notified, as required by law, of any such uses or disclosures.

Legal Proceedings. We may disclose your Confidential 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), in certain conditions in response to a subpoena, discovery request or other lawful process.

 

YOUR PRIVILEGES REGARDING YOUR HEALTH INFORMATION HELD BY US

As a Consultee of PinnacleCare, you have the following privileges with respect to your Confidential Health Information. You may have other rights under state and federal law, or when your information is in the possession of other persons or entities. We are not a health care provider, or an insurer or health maintenance organization, or any other organization defined as a Covered Entity as that term is defined under the Privacy Rule enacted by the Department of Health and Human Services (originally found at 45 CFR Subpart E, as amended from time to time). Therefore, we are not subject to the provisions of the Privacy Rule with respect to Confidential Health Information in our possession. Although the Privacy Rule does not apply to the health information maintained by us, we do provide you with the option to control the distribution of any of your health information in our possession based upon your personal preferences and within the limitations of law and regulation.

You may inspect and copy your Confidential Health Information. We are only holding your information because you have specifically authorized us to do so. You may inspect and obtain a copy of your Confidential Health Information contained in our records for as long as we maintain it. We will maintain it as long as you are a Consultee in good standing.

If you request a copy of your Confidential Health Information, we may charge you a fee for the costs of copying, mailing or other costs incurred by us in complying with your request. There will be no charge to access any of your medical information that may be on our website, as long as you are a Consultee in good standing.

You may request a restriction of your Confidential Health Information. You may ask us not to use or disclose any part of your Confidential Health Information. You may also request that any part of your Confidential Health Information not be disclosed to specified family consultees or friends or others 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. We will attempt to honor any such written restriction received by us from you. All such requests must be in writing.

You may make reasonable requests to receive confidential communications from us by alternative means or at an alternative location. We will attempt to accommodate any reasonable requests to receive confidential communications from us by alternative means or at an alternative location, subject to our capability. We may also condition that accommodation by asking you for additional information or require an alternative address or other method of contact and may seek payment for the additional costs incurred by us. Please make any such request in writing to our Privacy Contact.

We have no obligation to edit, translate, review for accuracy, keep current or otherwise amend your Confidential Health Information. We offer certain services to you and other Consultees as described in the Terms and Conditions to your agreement with us. We agree to accept information about you that you either give to us or authorize others to give to us. We accept that information as is and have no obligation to do anything with that information other than as described in the Terms and Conditions. Specifically, we do not assume any obligation to translate any medical record, to edit or review any record, to review any record for accuracy or quality assurance purposes, or otherwise to amend or monitor the information in such records. Our obligations to you as a Consultee are described in your application and this document (collectively the “Agreement”). No person is authorized to amend the terms of the Agreement other than through a written document signed by an authorized officer of PinnacleCare.

 

WHAT HAPPENS WHEN I AM NO LONGER A CONSULTEE

Within 120 days of the date when you cease being a Consultee, you may request, in writing, that we send your Confidential Health Information to a person you designate. If you make this request, we may charge you a fee for the costs of copying, mailing or other costs incurred by us in complying with your request.

If you do not make such a request within 120 days, we will be automatically authorized by you, at our election, to destroy any paper and/or electronic copies of your confidential medical information in our possession. We may elect to continue to hold such records, unless we receive written instruction from you to destroy your records. We reserve the right to retain a description of the use you have made of PinnacleCare’s services while you were a Consultee for our records.

You may request in writing that we destroy your Confidential Health Information in our possession. If you do, we will use our commercially reasonable efforts to destroy both any paper records and to remove any electronically stored records in our possession. We cannot guarantee that we will be able to destroy all electronically stored records. In addition, others that you have authorized may have obtained all or a part of your Confidential Health Information, and we have no responsibility to attempt to track and destroy any such information obtained by others.

WE MAY CHANGE THIS NOTICE

We reserve the right to change the privacy practices that are described in this Notice. When possible, we will provide you with at least thirty (30) days’ notice prior to the effective date of those changes. We reserve the right to apply those changes retroactively to Confidential Health Information that we have received before the change in privacy practices. However, you may object to any such changes in privacy practices within fifteen (15) days by writing to our Privacy Contact. If your concerns cannot be addressed to your satisfaction, you will be permitted to terminate your contract for PinnacleCare’s services.

  

NOTICES, QUESTIONS, AND COMPLAINTS

You may address any notices, questions, instructions or complaints to us, which will be deemed to have been received by us 1) when delivered by hand or confirmed facsimile transmission; 2) one business day after delivery by receipted overnight delivery; or 3) four days after having been mailed by certified or registered United States mail, return receipt requested and postage prepaid. All notices, communications, complaints and inquiries must be made in writing and addressed to us at PinnacleCare, 250 West Pratt Street, Suite 1100, Baltimore, Maryland, 21201, United States of America, to the attention of the Privacy Contact. If you believe your rights under this Notice have been violated by us, you may file a complaint with us by notifying our Privacy Contact at www.pinnaclecare.com.

You may contact our Privacy Contact for further information about the inquiry process.

This Notice was published and becomes effective on June 2, 2020.