This statement describes what you can expect from us regarding personal data on casadepalmas.org, and your associated rights and responsibilities. This statement is a part of the casadepalmas.org user agreement but trumps any conflicts with the agreement. This statement does not address anyone else's practices or our practices beyond the casedepalmas.org site.

Cookies, IP Addresses and URLs. Cookies are data snippets that websites store on your computer's hard drive. We use cookies to analyze site use, store your preferences/passwords (if you've registered) and personalize your experience. You can configure most web browsers to reject cookies or notify you when cookies are placed. If you're not registered, rejecting cookies won't noticeably affect your experience on casadepalmas.org. You must accept cookies to access casadepalmas.org as a registered user.

Your access provider assigns an IP address to your computer when you use the Internet. We log each IP address that accesses the site, along with referring/destination URLs. We use this data, as well as other data in our databases, to analyze site and user behavior, troubleshoot technical problems, resolve disputes, address complaints and prepare aggregated reports.

Email Tools. If you send emails through our site, your email will include your email address and any personal message you include. However, these emails are not private communications. You may not use these tools to send spam or content that violates the user agreement.
Feedback. We may ask for your feedback through a survey, which we treat like other business records.

Data Changes. If you terminate your account or delete/change your data or content, we usually update our live databases immediately. However, some data may update more slowly, and some old data may remain in our archives and records. If your account is being terminated or suspended, we may maintain some data to prevent re-registration.

Government Relations and Lawsuits. We may disclose data about you to the government if we are required to do so or if we think the disclosure is appropriate, and if you authorize these disclosures. We may also disclose data about you in connection with actual or potential lawsuits (a) if we are required to do so, (b) if such disclosures may potentially mitigate our liability, or (c) to enforce our rights.

Communicating with Other Users. You may not harvest personal data (including email addresses) from the site, and specifically you may not use email addresses displayed on the site to ask users to join or contribute to your services.

Security. We use up-to-the-minute industry-standard security protocols.

THIS NOTICE DESCRIBES HOW TREATMENT INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.
PLEASE READ IT CAREFULLY

We at Casa de Palmas understand that your treatment information and your health records are personal. We are committed to protecting your treatment information. We create a record about the care and services you receive during your stay here. We need this treatment information to provide you with quality care and to comply with certain legal requirements. This Notice of Privacy Practices applies to your treatment information generated and/or maintained by Casa de Palmas / The Haven.

This Notice will tell you about the ways in which we may use and disclose your treatment information. We also describe your rights and certain obligations we have regarding the use and disclosure of your treatment information.

Law requires us to:

• Make certain that treatment information that identifies you is kept private.
• Make certain that you are given notice of our legal duties and privacy practices with respect to your treatment information.
• Make certain that we follow the terms of the Notice of Privacy Practices that is currently in effect.

HOW WE MAY USE OR DISCLOSE TREATMENT INFORMATION ABOUT YOU

Substance Abuse Health Information. All treatment information regarding substance abuse is kept strictly confidential and released only in conformance with the requirements of federal law (42 U.S.C. 290dd-3 and 42 U.S.C. 290ee-3) and regulation (42 C.F.R. part 2). Disclosure of any treatment information referencing alcohol or substance abuse may only be made with your written authorization. A general authorization for the release of treatment or other information is not sufficient for this purpose.

The following describes different ways we use and disclose your treatment information. (Because you are receiving services for the evaluation and treatment of substance abuse, the specific rules above apply to the use and disclosure of information related to these services.)

For Treatment. We may use your treatment information to provide you with behavioral health treatment or services. We may disclose your treatment information to psychiatrists, your primary care practitioner, physicians, nurses, therapists, case managers or other behavioral health professionals who are involved in your care. For example, a practitioner treating you may need to know if you have allergies to certain medications. The practitioner may need to contact your primary care physician to obtain that information.

If necessary, we may share your treatment or medical information with your insurance company or a third party payor to confirm with them that you qualify for services, or to obtain approval for the services requested. However, note that insurance coverage for services is the responsibility of the client, and is not the responsibility of Casa de Palmas nor of its parent organization, The Haven.

Individuals Involved in Your Care. We may release your treatment information to a family member actively involved in your care and treatment as allowed under Arizona state law and in accordance with policies and procedures. This information is limited and will not be disclosed without first obtaining your written authorization.

HIV Information. All medical information regarding HIV is kept strictly confidential and released only in conformance with the requirements of state law (A.R.S. 36-664). Disclosure of any medical information referencing HIV status may only be made with your written authorization. A general authorization for the release of medical, treatment, or other information is not sufficient for this purpose.

Special Circumstances. Federal and state laws allow or require us to disclose your treatment or medical information in certain special circumstances that include, but are not limited to, the situations described below.

Public Health (Health and Safety for you and/or others). We may disclose your medical information for public health activities. We may use and disclose your medical information to a public health authority, when necessary, to prevent a serious threat to your health and safety or the health and safety of the public or another person. These generally include activities which:

• Prevent or control disease, injury or disability
• Report births or deaths
• Report child abuse or neglect
• Report reactions to medications
• Notify people of recalls regarding medications they may be using
• Notify a person who may have been exposed to a disease or may be at risk for contracting a disease
• Avert a serious threat to the health or safety of a person or the public
• Notify the appropriate government authority if we believe a client has been the victim of abuse, neglect or domestic violence. We will make this disclosure when required or authorized by law

Research. Under certain limited circumstances, and with your written permission, we may use and disclose your treatment information for research purposes. For example, a research project may involve the care and recovery of all members who receive one medication while other clients do not receive that medication, despite all the involved clients experiencing the same condition. All research projects are subject to a special approval process. We will obtain your written authorization if the researcher will use or disclose your treatment information.

Health Oversight Activities. We may disclose your treatment information to a health oversight agency for activities authorized by law. These oversight activities may include audits, investigations, inspections, and licensure. These activities are necessary for the government to monitor the behavioral health care system, government programs, and compliance with civil rights laws.

Lawsuits and Disputes. If you are involved in a lawsuit or legal action, we may disclose your treatment information in response to a valid court or administrative order, a valid subpoena, a discovery request, or other lawful process that complies with state law and our policies and procedures.

Law Enforcement. We may release your treatment information if asked to do so by a law enforcement official:

In response to a valid court order, subpoena, warrant, summons, or similar lawful process that complies with state law and our polices and procedures

To identify or locate a suspect, fugitive, material witness, or missing person

About the victim of a crime if, under certain limited circumstances, we are unable to obtain the person’s authorization

About a death we believe may have been the result of criminal conduct

About criminal conduct that occurs at Casa de Palmas

In emergency circumstances to report a crime, the location of the crime or victims, or the identity, description or location of the person who committed the crime

Coroners, Medical Examiners and Funeral Directors. We may release your treatment or medical information to a coroner or medical examiner. This may be necessary for identification or to determine a cause of death. We may also release your medical information to funeral directors as necessary to carry out their duties.

National Security and Intelligence Activities. We may release your treatment information to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.

Protective Services for the President and Others. We may disclose your treatment information to authorized federal officials so they may provide protection to the President or other authorized persons.

As Required By Law. We may disclose your treatment information when required to do so by federal, state, or local law.

YOUR RIGHTS REGARDING TREATMENT INFORMATION ABOUT YOU

Right to Access. You have the right to inspect and receive a copy of treatment information that may be used to make decisions about your care. To inspect and copy your treatment information, contact the Privacy Officer, who may be located at The Haven, the parent organization of Casa de Palmas. If you request a copy of the information, you may receive one copy each year at no cost. For any additional copies during the same year, you may be charged a fee for the costs of copying, mailing, or other supplies associated with your request. Your request to inspect and copy your treatment information may be denied in certain limited circumstances. If you are denied access to all, or any part, of your treatment information, you may request that the denial be reviewed. Information regarding how to initiate the review process will be provided in writing at the time of any denial of access to your treatment information.

Right to Amend. If you feel that your treatment information is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment, for as long as your treatment information is kept by Casa de Palmas. To request an amendment, your request must be made in writing and submitted to our Privacy Officer. You must provide a reason that supports your request. We may deny your request if you ask us to amend information that:

• Was not created by us, unless the person or entity that created the information is no longer available to make the amendment.
• Is not part of the treatment information kept by or for Casa de Palmas.
• Is not part of the treatment information which you would be permitted to inspect or copy.
• Is accurate and complete.

Right to an Accounting of Disclosures. You have the right to request an accounting of disclosures of your treatment information. This is a list of disclosures we made of your treatment information to others outside of Casa de Palmas or The Haven. The accounting does not include information disclosed as a part of payment or to other health care operations for your treatment or health. To request this accounting, you must submit your request in writing to the Casa de Palmas/The Haven’s Privacy Officer. Your request must state a period of time for the accounting that may not be longer than six years and may not include dates before April 14, 2003.

Right to Request Restrictions. You have the right to request a restriction on the treatment information we use or disclose about you. We are not required to agree to your request. If we do agree, we will comply with your request, unless the information is needed to provide you emergency treatment. To request a restriction, you must make your request in writing to the Casa de Palmas/The Haven’s Privacy Officer. In your request, you must tell us what information you want to restrict, and to whom you want the restriction to apply.

Right to Request Confidential Communications. You have the right to request that we communicate with you about treatment matters in a certain way or at a certain location if you believe that you will be otherwise endangered. For example, you can ask that we only contact you at a certain telephone number or address. To request confidential communications, you must make your request in writing to Casa de Palmas/The Haven’s Privacy Officer. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.

Right to Paper Copy of this Notice. All women are given a copy of this notice when they enter Casa de Palmas. It is in their Resident Manual.

Casa de Palmas reserves the right to change this notice. Casa de Palmas reserves the right to make the revised notice effective for your treatment information that Casa de Palmas already has about you, as well as any information we will receive following the revision. Copies of the current notice will be posted at the main office. The notice will contain the effective date at the bottom of each page. Casa de Palmas will make you aware of any revisions.

COMPLAINTS

If you believe your privacy rights have been violated, you may submit your complaint in writing to Casa de Palmas / The Haven’s Privacy Officer, 1107 E. Adelaide, Tucson, Arizona 85719. For questions, you may contact the Privacy Officer at (520) 623-4590. If we cannot resolve your concern, you also have the right to file a written complaint with the relevant authorities. The quality of your care will not be jeopardized, and nor will you be penalized for filing a complaint.

OTHER USES AND DISCLOSURES

Other uses and disclosures of your treatment information not covered by this notice will be made only with your written authorization. If you provide us with written authorization to use or disclose your treatment information, you may revoke that authorization, in writing, at any time. If you revoke your authorization, Casa de Palmas will no longer use or disclose your treatment information for the reasons covered by the authorization. Casa de Palmas is unable to take back any disclosures already made, based on your authorization.

Revised May 2008