1. WHAT HEALTH INFORMATION IS PROTECTED. We are committed to protecting the privacy of information we gather about you while providing health-related services. Some examples of protected health information include information indicating that you are a medical marijuana patient, information about your health condition, each when combined with identifying information, such as your name, address, social security number, patient ID number, government issued ID number, phone number, or other identifying information which may connect your patient status, health condition and personal identity.

  1. REQUIRED DISCLOSURES OF YOUR PROTECTED HEALTH INFORMATION. In certain circumstances, we are required to disclose your protected health information.
    1. Disclosures to You. We are required to disclose your protected health information to you, or your personal representative upon your request. A personal representative is an individual who has been designated by you and who has qualified for such designation in accordance with relevant law (and provides adequate documentation).
    2. Disclosures for HIPAA compliance. We may be required to disclose your protected health information to determine our compliance with the Health Insurance Portability and Accountability Act (HIPAA), a federal privacy law.

  1. HOW WE MAY USE AND DISCLOSE YOUR HEALTH INFORMATION WITHOUT YOUR WRITTEN AUTHORIZATION. There are some situations when we do not need your written authorization before using your health information or disclosing it to others, including:
    1. We may use your health information or disclose it to others in order to conduct our business operations. For example, we may use your health information to evaluate the performance of our staff in servicing you, or to educate our staff on how to improve the services they provide for you.
    2. We may disclose your health information to contractors, agents and other “business associates” who need the information in order to assist us with carrying out our business operations. For example, we may disclose your health information to an accounting firm or law firm that provides professional advice to us. If we do disclose your health information to a business associate, we will have a written contract to ensure that our business associate also protects the privacy of your health information. If our business associate discloses your health information to a subcontractor or vendor, the business associate is required to have a written contract to ensure that the subcontractor or vendor also protects the privacy of the information.
    3. We may use or disclose your health information if we are required by law to do so, and we will notify you of these uses and disclosures if notice is required by law. We may release your health information to government agencies authorized to conduct audits, investigations, and inspections. These disclosures shall be in compliance with government regulatory programs and civil rights laws.
    4. We may disclose your health information if we are ordered to do so by a court or administrative tribunal that is handling a lawsuit or other dispute. We may also disclose your information in response to a subpoena, discovery request, or other lawful request by someone else involved in the dispute, but only if required judicial or other approval or necessary authorization is obtained.
    5. We may use your health information or disclose it to others when necessary to prevent a serious and imminent threat to your health or safety, or the health or safety of another person or the public. In such cases, we will disclose your information only to someone able to help prevent the threat. We may also disclose your health information to law enforcement officers if you tell us that you participated in a violent crime that may have caused serious physical harm to another person (unless you admitted that fact while in counseling), or if we determine that you escaped from lawful custody (such as a prison or mental health institution).
    6. We may use and disclose your health information if we have removed any information that has the potential to identify you so that the health information is “de-identified.” We may also use and disclose health information about you that is constitutes a “limited data set” if the person who will receive the information signs an agreement to protect the privacy of the information as required by federal and state law. A limited data set will not contain any information that would directly identify you (such as your name, street address, social security number, phone number, fax number, electronic mail address, website address, or license number).
    7. While we will take reasonable steps to safeguard the privacy of your health information, certain disclosures of your health information may occur during or as an unavoidable result of our otherwise permissible uses or disclosures of your health information. For example, during the course of an appointment, other patients or clients in the area may see, or overhear discussion of, your health information.

  1. CHANGES TO THIS NOTICE. We reserve the right to change this notice at any time and to make the revised or changed notice effective in the future. We will make the revised notice available on our website and notify you of any material changes to the notice.

  1. REQUIREMENT FOR WRITTEN AUTHORIZATION. For purposes other than those described above, generally, we will obtain your written authorization before using your health information or disclosing it to others outside of Aura of Rhode Island, Inc., Inc.

  1. YOUR RIGHTS TO ACCESS AND CONTROL YOUR HEALTH INFORMATION. You have the following rights to access and control your health information:
    1. Right To Inspect And Copy Records. You have the right to inspect and obtain a copy of any of your health information that may be used to make decisions about you and your treatment for as long as we maintain this information in our records, including medical and billing records. To inspect or obtain a copy of your health information, please submit your request in writing to the Privacy Officer at the address given above. If you request a copy of the information, we may charge a reasonable fee for the costs of copying, mailing or other supplies we use to fulfill your request. If your protected health information is maintained in an electronic health record, then you may receive a copy of this information in electronic format.
    2. Right To Amend Records. If you believe that the health information we have about you is incorrect or incomplete, you may ask us to amend the information for as long as the information is kept in our records by writing to the Privacy Officer at the address given above. Your request should include the reasons why you think we should make the amendment. If we deny part or your entire request, we will provide a written notice that explains our reasons for doing so. You will have the right to have certain information related to your requested amendment included in your records.
    3. Right To An Accounting Of Disclosures. You have a right to request an “accounting of disclosures,” which is a list with information about how we have disclosed your health information to others within the past 6 years. We are not required to provide you with accounting of disclosures (1) for purposes of treatment, payment, or health care operations, (2) made to you or your personal representative, (3) made pursuant to your authorization, (4) made to family involved in your care in the presence of an emergency, (5) for national security or intelligence purposes, and (6) as part of a limited data set. To obtain a request form for an accounting of disclosures, please write to the Privacy Officer at the address given above. You have a right to receive one list every 12-month period for free. However, we may charge you for the cost of providing any additional lists in that same 12-month period.
    4. Right To Receive Notification Of A Breach. You have the right to be notified if there is a compromise of your unsecured protected health information within sixty (60) days of the discovery of the breach. The notice will include a description of what happened, including the date, the type of information involved in the breach, steps you should take to protect yourself from potential harm, a brief description of the investigation into the breach, mitigation of harm to you and protection against further breaches and contact procedures to answer your questions.
    5. Right To Request Restrictions. You have the right to request that we further restrict the way we use and disclose your health information to treat your condition, collect payment for that treatment, run our normal business operations or disclose information about you to family or friends involved in your care. The request for restriction will only be applicable to that particular service. You will have to request a restriction for each service thereafter. To request restrictions, please write to the Privacy Officer at the address given above. We are not required to agree to your request for a restriction, and in some cases the restriction you request may not be permitted under law. However, if we do agree, we will be bound by our agreement unless the information is needed to provide you with emergency treatment or comply with the law. Once we have agreed to a restriction, you have the right to revoke the restriction at any time. Under some circumstances, we will also have the right to revoke the restriction as long as we notify you before doing so.
    6. Right To Request Confidential Communications. You have the right to request that communications of your protected health information be sent to you at another location or by alternative means if you indicate that disclosure by the regular means could pose a danger to you and specify a reasonable alternative address or method of contact. For example, you may request we call you at work instead of sending information to your home. We will accommodate all reasonable requests.
    7. Right To Have Someone Act On Your Behalf. You have the right to name a personal representative who may act on your behalf to control the privacy of your health information. Parents and guardians will generally have the right to control the privacy of health information about minors unless the minors are permitted by law to act on their own behalf. We may elect not to treat the person as your personal representative if there is a reasonable belief that you have been, or may be; subjected to abuse, violence, or neglect by such person or that treating such person as your personal representative could endanger you. Furthermore, we may determine, in the exercise of professional judgment, that it is not in your best interest to treat the person as your personal representative.
    8. Right To Obtain A Copy Of Notices. If you are receiving this notice electronically, you have the right to a paper copy of this notice.
    9. Right To File A Complaint. If you believe your privacy rights have been violated, you may file a complaint with us by calling the Privacy Officer at Pinnacle. We will not withhold services or take action against you for filing a complaint.

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