Privacy & Legal Information
THIS NOTICE DESCRIBES HOW INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU MAY ACCESS THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
If you have any questions about this notice, please contact the QuitNet Privacy Officer by sending email to: firstname.lastname@example.org or by writing to:
Healthways QuitNet, LLC
c/o Healthways, Inc.
701 Cool Springs Blvd.
Franklin, Tennessee 37067
Regulations under the federal law commonly referred to as "HIPAA" - The Health Insurance Portability and Accountability Act - require health care providers to tell patients how their personal health information is used. These regulations protect your right to prevent personal medical information from being used or disclosed without your knowledge and consent, and require that health care providers:
QuitNet is not a health care provider and does not maintain medical records in the same manner as a doctor's office. However, we have implemented internal procedures to ensure that if the information we do collect were considered Personal Health Information, our practices and standards would meet or exceed the federal regulations. We have drafted this privacy notice to help you understand how we do that.
What is a QuitNet "health record"?
Some examples of information we record about you include information you provide when you:
a) register and create your membership account,
b) fill out surveys or self-assessment questionnaires,
c) use the quit date wizard to report a quit date and medication plan,
d) answer medical history questions in the medication wizard,
e) enter credit card and shipping information to purchase a product.
We record information about how you use QuitNet that allows us to tailor your experience to be more helpful. For example, the "My Next Steps" area on the "My Quit" page will change as the site remembers that you have used different features.
How we use these records:
For Treatment (Support). One form of support provided by QuitNet is online counseling. If you contact an expert counselor, that counselor may view information including your quit date, your indicated medication plan, and your responses to questionnaires. The counselor will also be able to view information regarding whether or not you have been subscribed to QuitTips, how often you have logged in, and your history of setting and changing your quit date and medication plan. All counselors have agreed to strictly honor our privacy practices and internal policies to ensure confidentiality of your information.
For Payment. If you purchase a product from us, we will submit your credit card information to our bank for processing. If you subscribe to a monthly membership, we encrypt and store your credit card information in order to process monthly billings.
For Health Care(Web Site)Operations. Web site operations are activities necessary to keep the online service running. This includes troubleshooting technical support issues. If you report a problem with the site, we may access your user information to identify the web browser you are using or to reproduce a problem you have reported. We will also periodically run reports to determine how many people are online, what features they are using, and what the general characteristics of our users are. For example, we will run a report to show us how many users have set quit dates or how many users have registered in a given time period from a given state. Development of an effective online smoking cessation program is a never-ending task we have been engaged in for nearly a decade. Throughout the process of improving the site, we will perform a variety of analyses to answer questions about how users like you use our site. We use this information internally and will never release personal information to outside marketers. We deploy banner advertising and other content targeted to you based on information in your user profile. For example, if you receive QuitTips emails, the content of these emails will be customized based on your quit date and medication plan, among other variables. These kinds of targeting and customization of content are fundamental to how QuitNet works and what distinguishes it from an information-only, brochure-ware website.
When we might allow others to see those records:
QuitNet will not allow anyone other than QuitNet employees or contractors to view the information associated with your QuitNet membership. Federal regulations require us to provide you with a history of any disclosures to third parties on demand. Our policy is not to make any such disclosures.
We sometimes share aggregate information with our agents or contractors for billing and research-related matters. This information does not include anything that could be used to identify you. For example, if your membership in QuitNet was sponsored by a state agency, we generate a report to tell the sponsoring agency how many people registered with QuitNet. We also give them summary reports showing the number of users of different ages, genders, and education levels. We will report how many users have set a quit date or selected a medication plan. In some cases we generate reports showing the number of registrants per county or zip code.
We may provide more detailed individual user records to medical researchers so they can analyze how activity on the site correlates with success quitting. However, this information will still be de-identified for purposes of HIPAA, because we remove all personal identifiers, including your username, first/last name, and email address and strip the last two digits from the zip code. This means that as a researcher analyzes the data, he or she would see information such as your quit date and medication plan, along with how many times you had logged in to the site, but would have no way to associate this back to you personally.
Some of our partners who sponsor your membership may request we provide verification of your enrollment for management of their benefits programs. If this is the case, you will be informed of this fact prior to disclosure of the information.
Our policies to protect health care records.
Our policy is to treat any information related to your efforts to quit smoking as confidential. This means that every QuitNet employee and contractor has been trained to respect the information they may access in the course of working with the company. For example, when you ask a question of an expert counselor, that counselor will not reveal your name or email address to anyone else in the company if he or she needs to discuss details about a particular question to better help you. If you report a technical problem, while the technical person solving the problem may see information such as your quit date, he or she would never pass that information along to anyone else unless it is necessary to solve the problem.
You have the following rights regarding medical information we maintain about you. We have provided examples to illustrate how these rights apply to QuitNet.
Right to Request Restrictions. You have the right to request a restriction or limitation on the medical information we use or disclose about you for treatment, payment, or health care operations. We are not required to agree to your request. You may exercise this right by choosing to make certain data such as your quit date public or private, through the checkboxes on the My Quit / Profile page. This will prevent the information from being disclosed to other members of the community who view your profile. If you feel this option does not give you sufficient control, you may use our problem reporting system to request more specific action.
Right to Receive Confidential Communications. You have the right to request that we communicate with you about medical matters in a certain way. For example, if you have access to the "Ask an Expert" forum and "Email a Counselor" features, you can use our expert forum or qmail a counselor directly. You may change your email address to a work address or whatever address you prefer. Because QuitNet is an online community, we will not, as a rule, communicate with members directly over the phone or in person. However, users can telephone us directly at our main phone number in Boston. Given the small size of our staff, we prefer electronic communications and that users submit questions through our problem report system online which allows us to track problems to resolution.
Right to Inspect, Copy, and Amend Protected Health Information. Because QuitNet does not maintain physical patient files, you would exercise this right though direct review and modification of data you had previously entered on the website. For example, you might re-take a questionnaire or update your quit date and medication plan. Many of the fields on your profile page are editable to update things like email address, first and last name. If you believe information about you is inaccurate and you are unable to determine how to verify or update it, submit a problem report on the web site for assistance.
Right to Request an Accounting of Disclosures.You have the right to request an "accounting of disclosures." This is a list of the disclosures we made of your medical information for which an authorization was not obtained, or which was not made for purposes of treatment, payment, or health care operations. QuitNet, as a matter of policy, will not disclose your Personal Health Information to third parties. If you feel a disclosure has occurred, submit a problem report on the site and/or follow the procedures for filing a complaint below.
Right to obtain a paper copy of this notice. You may submit a request in writing to Healthways QuitNet, LLC, 1 Appleton St., 4th Floor, Boston, MA 02116, for us to print and mail you a copy of this notice.
Changes to this Notice
We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for medical information we already have about you as well as any information we receive in the future. We will post a copy of the current notice on our website with its effective date. We will notify you of such changes via qmail.
If you believe your privacy rights have been violated, you may file a complaint with Healthways QuitNet, LLC, or with the Secretary of the Department of Health and Human Services. To file a complaint with Healthways QuitNet, LLC, send your written complaint to Healthways QuitNet, LLC, 1 Appleton St., Boston, MA 02116. All complaints must be submitted in writing.
You will not be penalized for filing a complaint. QuitNet is committed to protecting the privacy of our members and will act to swiftly address any concerns.
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