Easter Seals Disability Services

Easter Seals Online Network Privacy Policy

Notification of Change
The Information We Collect
Opting Out
Your California Privacy Rights
Correct/Update Your Profile
Aggregate Information
Cookies
Security of Your Information
Tell-A-Friend, Ecards and Personal Fundraising Pages
Links to Other Web Sites
Information from Children
Transmission of Health-Related Data

Welcome to the Easter Seals Online Network, the Web site of Easter Seals, Inc. (Easter Seals headquarters) and participating Easter Seals affiliates across the country.

Because Easter Seals values the privacy of constituents visiting the Easter Seals Online Network, users of the Easter Seals Online Network have the right to manage their own personal information.

You can contact Easter Seals for more information related to the privacy of the information you provide online:

Mail:  233 South Wacker Drive, Suite 2400, Chicago, IL 60606.
Phone:  312-726-6200
Online:  Click here to contact Easter Seals via email. Your request will be answered within 2-3 business days.

Notification of Change
Easter Seals reserves the right to change this policy at any time. Easter Seals privacy policy will be kept up-to-date and clearly posted on our Web site.

The Information We Collect
On many pages of the Easter Seals Online Network -- in particular when donating online, completing an action alert, registering for a special event, purchasing a product, or completing various feedback forms -- visitors are asked to list name, address, and other personal contact information. Information collected is specifically and knowingly provided by site visitors and may include name, email address, format preference (HTML vs. text), address, telephone number, interests and other similar information. Collecting this information helps Easter Seals to better provide site visitors with relevant and useful content.

Easter Seals has partnered with Convio, Inc. to power the Web content, email and transaction processing capabilities to serve our constituents and fulfill our mission on the Internet. Convio, Inc. is an Internet software and services company that provides online electronic Constituent Relationship Management (eCRM) solutions for nonprofit organizations and higher education institutions. Convio will not disclose your name or other personally identifiable information (such as your e-mail address or phone number) to any party other than Easter Seals.

Neither Easter Seals nor Convio store sensitive information such as credit card numbers. When an online transaction is completed through the Easter Seals Online Network, such as a charitable contribution, credit card information is used solely for the purpose of completing that specific transaction and is not retained in the Easter Seals or Convio database.

Easter Seals will not sell, share or exchange personal contact information collected from this Web site with other organizations. If a user has a previous relationship with Easter Seals through another channel (i.e., mail, phone), Easter Seals will occasionally rent or exchange those names and addresses with other organizations as a way of providing extra funds to help support services. If you do not want to participate in this program, please let us know.

Visitors to the Easter Seals Online Network are not required to share any personally identifiable information. Users who do not wish to share personal information when visiting the Easter Seals Online Network can still access the Network's Web pages and the valuable information provided.

Opting Out
Easter Seals provides site visitors with the opportunity to opt-out of receiving our online and offline communications.

If you would like to opt-out of receiving email communications please update your user profile. Email unsubscribe requests are processed immediately.

To discontinue the receipt of postal mail, please contact Easter Seals. Shortly, Easter Seals will be adding the capability to remove your name from our postal mailing list online. You'll need to register as user of the Easter Seals Online Network. Please note: there is a 8-12 week lapse period due to the fact that a subsequent mailing may already be in production. If you do receive another mailing, please disregard it.

Your California Privacy Rights
To review a special notice for California residents only per California Privacy Law (SB27): Exchanging, Renting, Reselling Personal Information, please visit the "Your California Privacy Rights" section. 

Correct/Update Your Profile
Easter Seals offers the option to change and modify personally identifiable information. Upon your request, Easter Seals will remove personally identifying information retained in organizational databases. If you are a registered user of this site, you can access your Easter Seals profile and update your contact information and user preferences by clicking here.

Easter Seals reserves the right to maintain information on users who have had their access to the Easter Seals Online Network blocked.

Aggregate Information
Demographic and profile data (i.e., age, gender, browser usage) is also collected via the Easter Seals Online Network. Easter Seals uses such data to improve marketing and promotional efforts, statistically analyze site usage, improve content and product offerings and to customize site content, layout, and services. Additionally, this data may be shared with third parties on an aggregated basis. Easter Seals does not share personally identifying information with third parties, except to a court or governmental agency if required by law and as stated above in the section titled "The Information We Collect."

Cookies
A cookie is a small text file a Web site places on a site visitor’s computer hard drive. Its purpose is to let the site know when a user visits and to perform certain functions such as saving passwords and personal preferences.
 
Cookies help evaluate visitors' use of a Web site, such as what viewers want to see and what they never read. This information allows Easter Seals to better focus online information and to concentrate on information people are using.

Your browser is probably set to accept cookies. If you would like to turn this feature off, you will need to change the settings of your Internet browser.

Security of Your Information
All credit card and personal profile information provided to Easter Seals or our Internet software partner, Convio, Inc., is transmitted using SSL (Secure Socket Layer) encryption using Verisign as a payment gateway. SSL is a proven coding system that allows a browser to automatically encrypt, or scramble, data before it is sent.

Easter Seals also protects account information by placing it on a secure portion of the Easter Seals Online Network that is only accessible by certain qualified employees of Easter Seals. Unfortunately, no data transmission over the Internet is 100% secure. Easter Seals strives to protect your information, however cannot ensure or warrant the security of such information.

Tell-A-Friend, Ecards and Personal Fundraising Pages
If you elect to use the referral service to inform a friend about a page on the Easter Seals Online Network, send an ecard, or raise funds for Easter Seals by soliciting friends and family, you will be asked for the friend's name and email address. Easter Seals will automatically send the friend a one-time email inviting them to visit the site. Easter Seals stores this information to send this one-time email only. In addition, the contact information will be maintained solely for the future convenience of the individual who provided the information -- to send subsequent ecards or fundraising reminders/updates.

Links to Other Web Sites
Easter Seals has links to other Web sites outside of the Easter Seals Online Network. Easter Seals is not responsible for the content of any linked Web site, or any link contained in a linked Web site, or any changes or updates to such Web sites. The inclusion of any link does not imply endorsement by Easter Seals of that Web site.

In addition, please be aware that Easter Seals is not responsible for the privacy practices of such other Web sites. Easter Seals encourages you to read the privacy statements of each and every Web site that requests personal information from you.

Information from Children
Easter Seals does not seek to collect personal information about children through the Easter Seals Online Network. If a child submits information through any part of the Network, and Easter Seals is aware that the user submitting the information is a child, the information is not used for any purpose, nor is it disclosed to third parties. Easter Seals will comply with all regulations set forward by the Children’s Online Privacy Protection Act (COPPA). To learn more about COPPA, visit the Federal Trade Commission.

Transmission of Health-Related Data
Easter Seals understands the sensitivity of collecting and using health-related data. Personally identifiable health-related data collected on the Easter Seals Online Network will not be shared with entities other than Easter Seals, Inc., and Easter Seals affiliates. Any transfer of personally identifiable health-related data between Easter Seals organizations will take place in a secure environment with access allowed only to certain qualified employees of Easter Seals. Easter Seals will comply with all regulations set forward by the Health Insurance Portability and Accountability Act (HIPAA). To learn more about HIPAA, visit the U.S. Department of Health and Human Services Office for Civil Rights.

NOTICE OF PRIVACY PRACTICES
OF
Easter Seals North Carolina

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.

Effective: April 14, 2003

If you have any questions or requests, please contact:

Hope Ethington, Privacy Officer
Easter Seals North Carolina
2315 Myron Drive
Raleigh, NC 27607
Phone: (919) 783-8898 Fax: (919) 782-5486
Email: HIPAA@.nc.easterseals.com

Table of Contents
(Please refer to full document for details)

A. We have a legal duty to protect health information about you.

B. We may use and disclose Protected Health Information (PHI) about you without your authorization in the following circumstances.

1. We may use and disclose PHI about you to provide health care treatment to you.
2. We may use and disclose PHI about you to obtain payment for services.
3. We may use and disclose PHI about you for health care operations.
4. We may use and disclose PHI under other circumstances without your authorization or an opportunity
    to agree or object.
5. You can object to certain uses and disclosures.
6. We may contact you to provide appointment reminders.
7. We may contact you with information about treatment, services, products or health care providers.
8. We may contact you for fundraising activities.

C. You have several rights regarding PHI about you.

1. You have the right to request restrictions on uses and disclosures of PHI about you.
2. You have the right to request different ways to communicate with you.
3. You have the right to see and copy PHI about you.
4. You have the right to request amendment of PHI about you.
5. You have the right to a listing of disclosures we have made.
6. You have a right to a copy of this Notice.

D. You may file a complaint about our privacy practices.

E. Effective date of this Notice.

A. Your Health Information is Protected by Law

We are required by law to protect the privacy of health information about you and that can be identified with you, which we call "protected health information," or "PHI" for short.  We must give you notice of our legal duties and privacy practices concerning PHI:

• We must protect PHI that we have created or received about:  your past, present, or future health condition; health care we provide to you; or payment for your health care.
• We must notify you about how we protect PHI about you.  
• We must explain how, when and why we use and/or disclose PHI about you.  
• We may only use and/or disclose PHI as we have described in this Notice. 

This Notice describes the types of uses and disclosures that we may make and gives you some examples.  In addition, we may make other uses and disclosures which occur as a byproduct of the permitted uses and disclosures described in this Notice.   If we participate in an "organized health care arrangement" (defined in subsection B.3 below), the providers participating in the "organized health care arrangement" will share PHI with each other, as necessary to carry out treatment, payment or health care operations (defined below) relating to the "organized health care arrangement".We are required to follow the procedures in this Notice. We reserve the right to change the terms of this Notice and to make new notice provisions effective for all PHI that we maintain by first:

• Posting the revised notice in our offices;
• Making copies of the revised notice available upon request (either at our offices or through the contact person listed in this Notice); and
• Posting the revised notice on our website.

B. Your PHI can be released without authorization under prescribed guidelines.

1. We may use and disclose PHI about you to provide health care/services treatment to you.
We may use and disclose PHI about you to provide, coordinate or manage your health care and related services.  This may include communicating with other health care providers regarding your treatment and coordinating and managing your health care with others. 

EXAMPLE:  We may use and disclose PHI about you when you need other health care services such as durable medical equipment or qualify for other services.  In addition, we may use and disclose PHI about you when referring you to another health care provider.EXAMPLE Any time we open a Medicaid/insurance case the following takes place.  Easter Seals receives a request for assessment from the attending physician.  (PHI received)  We arrange a home visit with family to complete DMA 3000 assessment form, and follow up by completing this visit.  This is then returned to the attending physician for approval.  (PHI sent) Approval note is returned from attending physician.  (PHI received). 

2. We may use and disclose PHI about you to obtain payment for services.
Generally, we may use and give your medical information to others to bill and collect payment for the treatment and services provided to you by us or by another provider.  Before you receive scheduled services, we may share information about these services with your health plan(s).  Sharing information allows us to ask for coverage under your plan or policy and for approval of payment before we provide the services.  We may also share portions of medical information about you with the following:

• Billing departments;
• Collection departments/agencies/attorneys assisting with collections; 
• Insurance companies, health plans and their agents which provide you coverage; q Consumer reporting agencies (e.g., credit bureaus).

EXAMPLE:   We may need to give your health plan(s) information about your condition and services. The information is given to our billing department and your health plan so we can be paid or you can be reimbursed.

3. We may use and disclose PHI about you for health care operations.
We may use and disclose PHI in performing business activities, which we call "health care operations".  These "health care operations" allow us to improve the quality of care we provide and reduce health care costs.  We may also disclose PHI for the "health care operations" of any "organized health care arrangement" in which we participate.  An example of an "organized health care arrangement" is the care provided by a Easter Seals North Carolina and the Area Program Case Managers who oversee the services provided.  In addition, we may disclose PHI about you for the "health care operations" of other providers involved in your care to improve the quality, efficiency and costs of their care or to evaluate and improve the performance of their providers.  Examples of the way we may use or disclose PHI about you for "health care operations" include the following:

• Reviewing and improving the quality, efficiency and cost of care that we provide to you and our other patients.  For example, we may use PHI about you to develop ways to assist our health care providers and staff in deciding what medical treatment should be provided to others.  
• Improving health care and lowering costs for groups of people who have similar health problems and to help manage and coordinate the care for these groups of people.  We may use PHI to identify groups of people with similar health problems to give them information, for instance, about treatment alternatives, classes, or new procedures.  
• Reviewing and evaluating the skills, qualifications, and performance of health care providers taking care of you. 
• Providing training programs for students, trainees, health care providers or non-health care professionals (for example, billing clerks or assistants, etc.) to help them practice or improve their skills.
• Cooperating with outside organizations that assess the quality of the care we and others provide.  These organizations might include government agencies or accrediting bodies such as the Council on Accreditation of Rehabilitation Facilities.
• Cooperating with outside organizations that evaluate, certify or license health care providers, staff or facilities in a particular field or specialty.  For example, we may use or disclose PHI so that one of our nurses may become certified as having expertise in a specific field of nursing, such as pediatric nursing. 
• Assisting various people who review our activities.  For example, PHI may be seen by doctors reviewing the services provided to you, and by accountants, lawyers, and others who assist us in complying with applicable laws. 
• Planning for our organization's future operations, and fundraising for the benefit of our organization. 
• Conducting business management and general administrative activities related to our organization and the services it provides.
• Resolving grievances within our organization.
• Reviewing activities and using or disclosing PHI in the event that we sell our business, property or give control of our business or property to someone else.
• Complying with this Notice and with applicable laws.

4. We may use and disclose PHI under other circumstances without your authorization or an opportunity to agree or object.
We may use and/or disclose PHI about you for a number of circumstances in which you do not have to consent, give authorization or otherwise have an opportunity to agree or object.  Those circumstances include:

• When the use and/or disclosure is required by law.  For example, when a disclosure is required by federal, state or local law or other judicial or administrative proceeding.  For example, when a court orders disclosure, when we suspect abuse or neglect of a child or disabled adult,
• When the use and/or disclosure is necessary for public health activities.  For example, we may disclose PHI about you if you have been exposed to a communicable disease or may otherwise be at risk of contracting or spreading a disease or condition.
• When the disclosure relates to victims of abuse, neglect or domestic violence.q When the use and/or disclosure is for health oversight activities.  For example, we may disclose PHI about you to a state or federal health oversight agency which is authorized by law to oversee our operations.
• When the disclosure is for judicial and administrative proceedings.  For example, we may disclose PHI about you in response to an order of a court or administrative tribunal.
• When the disclosure is for law enforcement purposes.  For example, we may disclose PHI about you in order to comply with laws that require the reporting of certain types of wounds or other physical injuries.
• When the use and/or disclosure is to avert a serious threat to health or safety.  For example, we may disclose PHI about you to prevent or lessen a serious and imminent threat to the health or safety of a person or the public.
• When the use and/or disclosure relates to specialized government functions.  For example, we may disclose PHI about you if it relates to military and veterans' activities, national security and intelligence activities, protective services for the President, and medical suitability or determinations of the Department of State.

5. You can object to certain uses and disclosures.
Unless you object, we may use or disclose PHI about you in the following circumstances:

• We may share with a family member, relative, friend or other person identified by you, PHI directly related to that person's involvement in your care or payment for your care.  We may share with a family member, personal representative or other person responsible for your care PHI necessary to notify such individuals of your location, general condition or death. 
• We may share with a public or private agency (for example, American Red Cross) PHI about you for disaster relief purposes.  Even if you object, we may still share the PHI about you, if necessary for the emergency circumstances.

If you would like to object to our use or disclosure of PHI about you in the above circumstances, please call or write to our contact person listed on the cover page of this Notice.

6. We may contact you to provide appointment reminders.
We may use and/or disclose PHI to contact you to provide a reminder to you about an appointment you have for treatment or medical care.

7. We may contact you with information about treatment, services, products or health care providers.
We may use and/or disclose PHI to manage or coordinate your healthcare.  This may include telling you about treatments, services, products and/or other healthcare providers.  We may also use and/or disclose PHI to give you gifts of a small value. 

EXAMPLE:  If you are diagnosed with diabetes, we may tell you about nutritional and other counseling services that may be of interest to you.  

8. We may contact you for fundraising activities.
We may use and/or disclose PHI about you, including disclosure to a foundation, to contact you to raise money for our facility and its operations.  We would only release contact information and the dates you received treatment or services at our facility.   If you do not want to be contacted in this way, you must notify in writing our contact person listed on the cover page of this Notice.

** ANY OTHER USE OR DISCLOSURE OF PHI ABOUT YOU REQUIRES YOUR WRITTEN AUTHORIZATION **

Under any circumstances other than those listed above, we will ask for your written authorization before we use or disclose PHI about you.  If you sign a written authorization allowing us to disclose PHI about you in a specific situation, you can later cancel your authorization in writing by contacting Hope Ethington or your local representative.   If you cancel your authorization in writing, we will not disclose PHI about you after we receive your cancellation, except for disclosures which were being processed before we received your cancellation.

C. Your Rights Related to PHI.

1. You have the right to request restrictions on uses and disclosures of PHI about you.
You have the right to request that we restrict the use and disclosure of PHI about you.  We are not required to agree to your requested restrictions.  However, even if we agree to your request, in certain situations your restrictions may not be followed.  These situations include emergency treatment, disclosures to the Secretary of the Department of Health and Human Services, and uses and disclosures described in subsection B.4 of the previous section of this Notice.  You may request a restriction by contacting Hope Ethington or your local representative. 

2. You have the right to request different ways to communicate with you.
You have the right to request how and where we contact you about PHI.  For example, you may request that we contact you at your work address or phone number or by email.  Your request must be in writing.  We must accommodate reasonable requests, but, when appropriate, may condition that accommodation on your providing us with information regarding how payment, if any, will be handled and your specification of an alternative address or other method of contact.  You may request alternative communications by contacting Hope Ethington or your local representative.

3. You have the right to see and copy PHI about you.
You have the right to request to see and receive a copy of PHI contained in clinical, billing and other records used to make decisions about you.  Your request must be in writing.  We may charge you related fees. Instead of providing you with a full copy of the PHI, we may give you a summary or explanation of the PHI about you, if you agree in advance to the form and cost of the summary or explanation. There are certain situations in which we are not required to comply with your request. However, we may deny access to information that would be injurious to the client's physical or mental well being as determined by the facility director. Under these circumstances, we will respond to you in writing, stating why we will not grant your request and describing any rights you may have to request a review of our denial.  You may request to see and receive a copy of PHI by contacting Hope Ethington or your local representative.

4. You have the right to request amendment of PHI about you.
You have the right to request that we make amendments to clinical, billing and other records used to make decisions about you.  Your request must be in writing and must explain your reason(s) for the amendment.  We may deny your request if: 1) the information was not created by us (unless you prove the creator of the information is no longer available to amend the record); 2) the information is not part of the records used to make decisions about you; 3) we believe the information is correct and complete; or 4) you would not have the right to see and copy the record as described in paragraph 3 above. We will tell you in writing the reasons for the denial and describe your rights to give us a written statement disagreeing with the denial. If we accept your request to amend the information, we will make reasonable efforts to inform others of the amendment, including persons you name who have received PHI about you and who need the amendment.  You may request an amendment of PHI about you by contacting Hope Ethington or your local representative.

5. You have the right to a listing of disclosures we have made.
If you ask our contact person in writing, you have the right to receive a written list of certain of our disclosures of PHI about you.  You may ask for disclosures made up to six (6) years before your request (not including disclosures made prior to April 14, 2003).  We are required to provide a listing of all disclosures except the following:

• For your treatment
• For billing and collection of payment for your treatment
• For health care operations 
• Made to or requested by you, or that you authorized
• Occurring as a byproduct of permitted uses and disclosures
• Made to individuals involved in your care, for directory or notification purposes, or for other purposes described in subsection B.5 above 
• Allowed by law when the use and/or disclosure relates to certain specialized government functions or relates to correctional institutions and in other law enforcement custodial situations (please see subsection B.4 above) and
• As part of a limited set of information which does not contain certain information which would identify you

The list will include the date of the disclosure, the name (and address, if available) of the person or organization receiving the information, a brief description of the information disclosed, and the purpose of the disclosure.  If, under permitted circumstances, PHI about you has been disclosed for certain types of research projects, the list may include different types of information.

If you request a list of disclosures more than once in 12 months, we can charge you a reasonable fee.  You may request a listing of disclosures by contacting Hope Ethington or your local representative.

You have the right to request a paper copy of this Notice at any time by contacting Hope Ethington or your local representative.   We will provide a copy of this Notice no later than the date you first receive service from us (except for emergency services, and then we will provide the Notice to you as soon as possible).

D. How to File a Complaint.

If you think we have violated your privacy rights, or you want to complain to us about our privacy practices, you can contact the person listed below:

Hope Ethington, Privacy Officer
Easter Seals North Carolina
2315 Myron Drive, Raleigh, NC 27607
Phone: 800-662-7119     Fax: 919-783-9551
Email: HIPAA@nc.easter-seals.org.

You may also send a written complaint to the United States Secretary of the Department of Health and Human Services.

If you file a complaint, we will not take any action against you or change our treatment of you in any way.

E. Effective Date of this Notice

This Notice of Privacy Practices is effective on April 14, 2003.