HIPAA Notice of Privacy Practices

Table of Contents

1. Understanding Your Health Information
2. Your Rights Regarding Your Health Information
3. Our Responsibilities
4. How We May Use and Disclose Your Health Information
5. Treatment
6. Payment
7. Healthcare Operations
8. Other Permitted Uses and Disclosures
9. Your Written Authorization
10. Special Situations
11. Security Measures
12. Breach Notification
13. Changes to This Notice
14. Contact Information

1. Understanding Your Health Information

Each time you visit CLEAR or use our services, a record of your visit is made. Typically, this record contains your symptoms, examination and test results, diagnoses, treatment, and a plan for future care or treatment. This information, often referred to as your health or medical record, serves as a:

• Basis for planning your care and treatment.
• Means of communication among the many health professionals who contribute to your care.
• Legal document describing the care you received.
• Means by which you or a third-party payer can verify that services billed were actually provided.
• Tool in educating heath professionals.
• Source of data for medical research.
• Source of information for public health officials charged with improving the health of the nation.
• Source of data for facility planning and marketing.
• Tool with which we can assess and continually work to improve the care we render and the outcomes we achieve.

2. Your Rights Regarding Your Health Information

Although your health record is the physical property of CLEAR, the information belongs to you. You have the right to:

• Inspect and Copy: You have the right to inspect and copy health information that may be used to make decisions about your care. Usually, this includes medical and billing records.
• Amend: If you feel that health information we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept by or for CLEAR.
• Accounting of Disclosures: You have the right to request an "accounting of disclosures." This is a list of certain disclosures we made of your health information for purposes other than treatment, payment, or healthcare operations.
• Request Restrictions: You have the right to request a restriction or limitation on the health information we use or disclose about you for treatment, payment, or healthcare operations.
• Request Confidential Communications: You have the right to request that we communicate with you about medical matters in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail.
• Paper Copy of This Notice: You have the right to a paper copy of this notice. You may ask us to give you a copy of this notice at any time.

3. Our Responsibilities

CLEAR is required by law to:

• Maintain the privacy of your health information.
• Provide you with this notice as to our legal duties and privacy practices with respect to information we collect and maintain about you.
• Abide by the terms of this notice.
• Notify you if we are unable to agree to a requested restriction.
• Accommodate reasonable requests you may have to communicate health information by alternative means or at alternative locations.
• Notify you following a breach of unsecured protected health information.

4. How We May Use and Disclose Your Health Information

The following categories describe different ways that we use and disclose health information. For each category of uses or disclosures we will explain what we mean and try to give some examples. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will fall within one of the categories.

5. Treatment

We may use your health information to provide you with medical treatment or services. We may disclose health information about you to doctors, nurses, technicians, medical students, or other personnel who are involved in taking care of you. For example, a phlebotomist treating you may need to know if you have diabetes because diabetes may slow the healing process. In addition, the phlebotomist may need to tell the laboratory if you have diabetes so that we can arrange for appropriate testing.

6. Payment

We may use and disclose your health information so that the treatment and services you receive may be billed to and payment may be collected from you, an insurance company, or a third party. For example, we may need to give your health plan information about a test you received so your health plan will pay us or reimburse you for the test.

7. Healthcare Operations

We may use and disclose your health information for healthcare operations. These uses and disclosures are necessary to run CLEAR and make sure that all of our patients receive quality care. For example, we may use medical information to review our treatment and services and to evaluate the performance of our staff in caring for you. We may also combine medical information about many CLEAR patients to decide what additional services CLEAR should offer, what services are not needed, and whether certain new treatments are effective.

8. Other Permitted Uses and Disclosures

We may use or disclose your health information for the following purposes:

• Public Health Activities: We may disclose your health information for public health activities, such as preventing or controlling disease, injury, or disability.
• Health Oversight Activities: We may disclose health information to a health oversight agency for activities authorized by law. These activities include, for example, audits, investigations, inspections, and licensure.
• Lawsuits and Disputes: If you are involved in a lawsuit or a dispute, we may disclose health information about you in response to a court or administrative order.
• Law Enforcement: We may release health information if asked to do so by a law enforcement official in response to a court order, subpoena, warrant, summons, or similar process.
• Coroners, Medical Examiners and Funeral Directors: We may release health information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death.

9. Your Written Authorization

Other uses and disclosures of health information not covered by this notice or the laws that apply to us will be made only with your written permission. If you provide us permission to use or disclose health information about you, you may revoke that permission, in writing, at any time. If you revoke your permission, we will no longer use or disclose health information about you for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain our records of the care that we provided to you.

10. Special Situations

In certain situations, we may be required to disclose your health information without your authorization. These include:

• Organ and Tissue Donation: If you are an organ donor, we may release health information to organizations that handle organ procurement or organ, eye, or tissue transplantation or to an organ donation bank.
• Military and Veterans: If you are a member of the armed forces, we may release health information about you as required by military command authorities.
• Workers' Compensation: We may release health information about you for workers' compensation or similar programs. These programs provide benefits for work-related injuries or illness.
• Inmates: If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release health information about you to the correctional institution or law enforcement official.

11. Security Measures

We implement appropriate physical, technical, and administrative safeguards to protect your health information. This includes encryption, secure access controls, and regular security assessments. We limit access to your personal health information to those employees, agents, and contractors who need it to provide services to you or to perform their jobs.

12. Breach Notification

In the unlikely event of a breach of your unsecured protected health information, we will notify you in writing without unreasonable delay and in no case later than 60 days after discovering the breach. The notification will include a brief description of what happened, the types of unsecured protected health information that were involved, steps you should take to protect yourself from potential harm, and a brief description of what we are doing to investigate the breach, to mitigate harm to you, and to protect against any further breaches.

13. Changes to This Notice

We reserve the right to change this notice and our privacy practices. We reserve the right to make the revised or changed notice effective for health 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. The notice will contain on the first page, in the top right-hand corner, the effective date.

14. Contact Information

If you have questions about this notice or our privacy practices, please contact our Privacy Officer: