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PHS Notice of Privacy Practices (HIPAA)

This notice describes how medical information about a patient may be used and disclosed and how you can get access to this information. Please review this notice carefully.

What Are PHS Health Information Responsibilities? 

As we provide care and service, PHS collects information that becomes part of a patient’s medical and billing record. This information is called Protected Health Information (PHI). PHI includes information about the patient we receive from

  • The patient or the patient’s legal guardian or principal caregiver.
  • The medical people involved in the patient’s care, such as doctors, hospital or clinic staff, home care or school nurses, and mental health therapists.
  • The patient’s health insurance company.

Federal law and our concern about patient protection require us to keep a patient’s PHI private. We do this in many ways.

  • We have protections for paper and computer records to prevent accidental or intentional change, loss, or misuse of PHI.
  • We have written policies protecting PHI that govern how we do business.
  • We regularly train all of our employees on laws and PHS policies for protecting PHI.
  • We require all non-health care industry companies with which we work when we provide patient services to sign a legal agreement to follow PHI laws.

PHS notifies the patient or legal guardian if a loss of PHI occurs that is likely to cause patient harm. PHS sends this report no more than 60 days after we learn about the loss.

How Does PHS Use and Share Protected Health Information?

Federal law allows PHS to use and share PHI without a patient’s written permission for the following six purposes. For each purpose, we list one of many possible examples.

  1. Patient Care and Treatment We may share PHI with other health care providers as we give, manage or coordinate health care and related services for a PHS patient.
    Example: Speaking with referring health care providers to obtain medical history or determine the best equipment, supplies or medicine for a patient.
  2. Payment for PHS Services We may share PHI with the patient’s health insurance provider as we seek payment for PHS services.
    Example: Sharing PHI to determine whether the patient’s health insurance pays for equipment and supplies ordered by the doctor.
  3. On-Going Health Care Practices We may use PHI for business operations and to check that PHS follows all laws and guidelines for providing safe, high-quality patient care.
    Example: PHS review of medical records to assure we follow proper billing practices.
  4. Public Health We may share PHI with appropriate authorities to prevent a serious threat to individual or public health or safety.
    Example: Sharing a life-threatening patient event involving medical equipment with the federal Food and Drug Administration (FDA).
  5. Suspected Abuse or Neglect We may share PHI with appropriate authorities to address concerns about abuse, neglect, or domestic violence involving a child or Vulnerable Adult.
    Example: Sharing a nurse’s observations with a county Child Protection Service if there is concern about a child’s well-being.
  6. Legal Actions We may share PHI as required for court or law enforcement actions.
    Example: Sharing a patient’s location in response to a court order from the police.

Federal law requires PHS to seek and receive written permission from the patient or the patient’s legal guardian before using or sharing PHI in the following situations. PHS must explain to the patient or the patient’s legal
guardian why and with whom we want to share PHI.

  1. For requests to use or share PHI for purposes other than the six purposes listed on page one of this Notice of HIPAA Privacy Practices.
  2. For most requests to receive or share mental health treatment information contained within the medical record.

The patient or patient’s legal guardian can refuse permission to share PHI. Refusal does not affect the care or service PHS provides the patient. The patient or patient’s legal guardian can withdraw permission in writing at any time.

What Are the Patient’s Privacy Rights?

The patient or patient’s legal guardian has the following PHI rights. The person can

  • Ask that PHS not share PHI for the six purposes listed on page one of this Notice of HIPAA Privacy Practices. The request must be in writing and identify
    • The information PHS should not share,
    • The person or organization with whom PHS should not share the information,
    • Whether the request applies to written or spoken communication or to both.
      NOTE: In some cases, PHS may not be able to honor the request
  • Instruct PHS to not share information about service the patient or patient’s legal guardian paid for out of pocket and in full.
  • Identify how and where to receive PHI. Examples include telling us we should
    • Send PHI by email, surface mail or phone,
    • Mail PHI to an address different than the primary address in the medical record,
    • Not leave health information in voicemails or with family members at phone numbers in the medical record.
  • Receive a copy of the medical record, not including certain types of mental health treatment information. We send a copy of the record within 30 days of receiving a written request. We may charge a small fee for photocopying and mailing the medical record.
  • Ask that we change, add or remove information in the medical record. We respond in writing within 60 days of receiving the written request. If we agree, we forward the changed or new information to persons or organizations that use the medical record for treatment, payment or other health care services. If we do not agree, we explain our reasons in writing. The patient or patient’s legal guardian can follow the process described below to file a complaint about our decision.
  • Receive details about the health information PHS shared for purposes four, five or six listed on page one of this Notice of HIPAA Privacy Practices. The patient or patient’s legal guardian can also request details about any loss of PHI that PHS considered not likely to cause patient harm.
  • The person must send a signed hard copy letter with any of these requests to the Privacy Officer at PHS. See address below.

How Do I File a Complaint?

Contact the Privacy Officer at PHS with questions or concerns about patient privacy rights or PHS privacy policies. The patient or patient’s legal guardian can file a complaint with the PHS Privacy Officer if the person thinks there has been a violation of PHI privacy. Contact the PHS Privacy Officer at 651-642-1825 or send a written complaint to the following address:

PHS Privacy Officer
Pediatric Home Service
2800 Cleveland Avenue North
Roseville, MN 55113

The patient or patient’s legal guardian has the right to file a complaint with the United States Department of Health and Human Services – Office of Civil Rights. We cannot punish the patient in any way for filing such a complaint.

How Does PHS Notify Patients of Changes to Privacy Practices?

This Notice of HIPAA Privacy Practices goes into effect September 1, 2013. PHS has the right to change this Notice and the PHI policies it describes. If we change the Notice of HIPAA Privacy Practices, we put the new Notice on our
website (www.pediatrichomeservice.com) and in a public area of our office. The patient or patient’s legal guardian can request a written copy of the new Notice of HIPAA Privacy Practices.

Website Privacy Policy

Last Revised: April 29, 2024

Introduction

Pediatric Home Service, including its divisions, subsidiaries, and affiliates (“PHS,” “us”, “our” or “we”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the websites pediatrichomeservice.com, PHSUniversity.com, and phsonlineordering.com (collectively, the “Website”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

  • On or through the Website.
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

 

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website, application, or service operated by PHS or any third party, including our affiliates and subsidiaries; or
  • Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Website. By accessing or using the Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy below). Your continued use of the Website after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

 

Children

The Website is not intended for children, as defined under applicable law. Children may not provide any information to or on the Website. We do not knowingly collect personal information from children. If you believe we might have any information from or about a child, in the absence of verifiable parental consent, please contact us at: compliance@pediatrichomeservice.com.

 

Information We Collect About You and How We Collect It

We collect several types of information from and about users of the Website, including information:

  • by which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other information the Website collects that is defined as personal or personally identifiable information under an applicable law (“personal information”); and/or
  • about your internet connection, the equipment you use to access the Website and usage details.

 

We collect this information:

  • directly from you when you provide it to us;
  • automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and/or
  • from third parties, including legal guardians, principal caregivers, health insurance companies, individuals involved in patient care, such as doctors, hospital or clinic staff, home care or school nurses, and mental health therapists, and talent management software providers. This information may include, but not be limited to, information related to patient medical and billing records.

While you are not required to directly provide us with your personal information, please be advised that you may not be able to make use of certain features or functionalities on the Website, if you choose not to provide your personal information.

 

Information You Provide to Us.

The information we collect on or through the Website may include:

  • Information that you provide by filling in forms on the Website. This includes information you provide when you subscribe to our newsletter or sign up for updates, download guides, submit feedback, participate in virtual focus groups, find services, provide feedback, join the Naked Neck Club, or contact us. This information may include your name, email address, telephone number, address, patient names, dates of decannulation, anything you would like to say or share about your time with PHS, and information related to the contact methods you prefer and the services you are interested in, whether you have a computer with a camera, and the contents of any questions or comments you send to us.
  • Information that you provide when you comment on our blog. This information may include your name, email address, website, and any comments you provide.
  • Information that you provide when you register to make a payment or make a payment. This information may include your name, email address, username, password, code, account number, invoice number, invoice date, date of birth, last four digits of your social security number, photos of your bill, patient MRN, date of service provided, payment amount, name on card, card number, expiration date, and security code, zip code, patient account information, and information related to family members making payments for medical services they received.
  • Information that you provide when register for or use the MyPHS Portal, including for the purposes of ordering medical supplies. This information may include your name, email address, password, patient last name, patient zip code, patient date of birth, patient ID/MRN, relationship to patient, patient health information (including information related to demographics, allergies, insurance, and physician list), patient care information (including medication list, equipment maintenance record, treatment record, and a vital signs flow sheet), the contents of patient care and billing documents, and the contents of your messages with PHS clinicians.
  • Information that you provide when you apply for employment with us. This information may include your name, email address, telephone number, username, password, resume, cover letter, and information related to your biographical data, work history, names and numbers of contacts, and education background.
  • Information that you provide when you register for classes or engage with content through PHS University. This information may include your username, password, information related to your sessions and credits, account information (including name, username, email address, and telephone number), contact information (including country, state, FTE status, FLSA status, enrollment type, and whether you are an employee of PHS), billing and shipping address, and payment information (including credit card number, expiration date, and CSC).
  • Your search queries on the Website.
  • Records and copies of your correspondence (including email addresses), if you contact us.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

 

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with the Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to the Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Please see the Choices About How We Use and Disclose Your Information section below for additional details on how PHS responds to do-not-track signals.

The information we collect automatically may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve the Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize the Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to the Website.

 

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Website.
  • Web Beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit PHS, for example, to count users who have visited those pages or opened an e-mail and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

 

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and devices and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

 

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present the Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To facilitate advertising and marketing activities.
  • To collect and process applications for employment.
  • To understand and analyze how our visitors use the Website.
  • To improve and optimize the Website and your user experience.
  • To fulfill any other purpose for which you provide it.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
  • To notify you about changes to the Website or any products or services we offer or provide through it.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

We may also use your information to contact you about our products and services that may be of interest to you. If you do not want to receive solicitations regarding our products and services, you may unsubscribe from such communications by clicking the link in the applicable communication or by contacting us at compliance@pediatrichomeservice.com.

 

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not constitute personal information under applicable law, without restriction.

We may disclose personal information that we collect or you provide as described in this Privacy Policy:

  • To our subsidiaries and affiliates.
  • To account holders, health insurance providers, payers, responsible parties, secondary caregivers, and members of the patient care team.
  • To contractors, service providers, and other third parties we use to support our business. We may share your information with the following categories of third-party business partners and service providers: advertising networks, banking institutions, data analytics providers, talent management software providers, billing software providers, learning management systems, social media platforms (including links to our Facebook, Instagram, LinkedIn, Pinterest, Twitter, and YouTube pages), tag management systems, payment platforms, technology service providers, and video hosting and sharing platforms (including Vimeo and YouTube- for more information about YouTube’s collection of information, see Google’s privacy policy at: https://www.google.com/policies/privacy).
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of PHS’, its affiliates’ or its subsidiaries’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by PHS about the Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our agreements with you.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of PHS, its affiliates, its subsidiaries, their respective customers, or others.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We do not respond to Do-Not-Track signals at this time; however, we have enabled the following mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising.

  • Google Analytics collects personal information through the Website, including through the use of cookies. For information about how Google Analytics collects and processes data, please visit: https://policies.google.com/technologies/partner-sites. To opt out of having your information used by Google Analytics, please visit: https://tools.google.com/dlpage/gaoptout/.For more information, please visit Google’s privacy policy at: https://policies.google.com/privacy?hl=en&fg=1.
  • Additionally, third parties, including Google, may place and read cookies on your browser, or use web beacons to collect information in connection with ad serving on or through the Website, including for the purposes of showing our ads on sites across the internet. Our partners will collect personal information for personalization of ads and may use first-party cookies or other first-party identifiers and third-party cookies and other third-party identifiers for personalized and non-personalized advertising and measurement. Ad serving may be based on users’ visits to our Website or other websites on the Internet, and your activity may be tracked over time and across websites. For information about how Google collects, shares, and uses data, please visit: https://policies.google.com/technologies/partner-sites. You can opt out of Google’s use of cookies or device identifiers by visiting the Google Ads Settings web page at: https://www.google.com/ads/preferences/. For more information, please visit Google’s privacy policy at: https://policies.google.com/privacy?hl=en&fg=1. You can opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page or control the use of device identifiers by using your device’s settings
  • We use the Meta Pixel to analyze user activity on our Website for remarketing and behavioral targeting. The Meta Pixel is triggered when you perform certain activities on the Website, and aids us in displaying Facebook ads to Facebook users who have visited our Website, or Facebook users who share certain characteristics with visitors to our Website. Meta and other third parties may use cookies, web beacons, and other storage technologies to collect information from the Website and from other internet websites, and use that information for the purposes of targeting ads and providing measurement services. Meta may track your activity over time and across websites. For more information about the data Meta collects, please visit Meta’s privacy policy at: https://www.facebook.com/privacy/policy/. For specific information about Meta Pixel, please visit: https://www.facebook.com/business/help/742478679120153?id=1205376682832142. For more information about ad targeting and exercising your choice to opt out of the collection and use of information for ad targeting, please visit: https://www.facebook.com/help/568137493302217, or https://optout.aboutads.info/?c=2&lang=EN.

Please note that we do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on NAI’s website, which can be found here: https://www.networkadvertising.org/understanding-online-advertising/what-are-my-options. You can also visit the Digital Advertising Alliance’s website, available at https://youradchoices.com/, to use its Consumer Choice Tools.

You can additionally set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly.

 

Promotional Offers from PHS

  • If you do not wish to have your e-mail address or contact information used by PHS to promote our products or services, you can opt-out by clicking the “unsubscribe” link in the applicable communication, or by sending us an e-mail stating your request to compliance@pediatrichomeservice.com. Please note that, even if you unsubscribe from certain email correspondences, we may still need to email you with information relating to important transactional or administrative information.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to: compliance@pediatrichomeservice.com. However, please note that we do not currently sell data triggering that statute’s opt-out requirements.

 

Accessing and Correcting Your Information

You may log into your account or send us an email at compliance@pediatrichomeservice.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

 

Data Security and Retention

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to or through the Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

We retain your information for as long as needed: (i) to conduct business with you; (ii) as needed for the purposes outlined in this Privacy Policy; and (iii) as necessary to comply with our legal obligations, resolve disputes, and enforce any agreements.

 

Changes To Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you by e-mail to the e-mail address provided by you, if you have provided one, or through a notice on the Website homepage. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting the Website and this Privacy Policy to check for any changes.

 

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

Pediatric Home Service

2800 Cleveland Avenue North
Roseville, MN 55113
Attn: Privacy Compliance Officer
Email: compliance@pediatrichomeservice.com

Additional Policies