This notice describes:
Summit Behavioral Healthcare (“SHBC”,” “us”, “we”, or “our”) operates the englishmountain.com (“Website”), and provides various services to clients in order to manage and care for individuals who suffer from behavioral illnesses, chemical dependencies or addition disorders. Among other services, we offer hospitalization, inpatient treatment, detoxification programs, partial hospitalization programs, and intensive outpatient programs (hereinafter collectively referred to as the “Services”).
SBHC cares about your personal integrity. Therefore, this Privacy Policy is provided to equip you with information on how SBHC processes the personal data that you share with us when using contact forms on our website.
As noted above, our Privacy Policy is designed to advise you about how we collect, use, protect, and disclose the information that we collect and/or receive about you. It also explains your privacy rights, and how you can manage the privacy of your Personal Information. Please note that this Privacy Policy does not govern the practices of third parties, including our partners, third party service providers, and/or advertisers, even when those services are branded as, or provided on behalf of, SBHC. Information collected from you by others, such as third party websites that you access through links on the Website, are governed by those entities’ privacy policies.
We use your information to provide the Services that you request, and to improve the Services we offer to you. By using our Services, you agree to the collection and use of information in accordance with this Privacy Policy.
Included below is a list of several different types of information for various purposes to provide and improve our Service to you.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Services.
Examples of Cookies and other technologies we may use include, but are not limited to:
Your Cookie Choices
You may set your browser to block or otherwise control what cookies your browser or mobile device accepts via your browser or mobile device settings. Additionally, you can choose to modify your settings and delete those cookies that are otherwise stored on your device. Please consult the instructions provided by your browser or your mobile device’s manufacturer to determine how you can limit the placement of and/or remove cookies or other technologies. Please note, however, that limiting or disabling the use of cookies and other technologies may impact or adversely affect your ability to perform certain transactions on, use certain functionalities of, and access certain content on our Website.
SBHC collects and obtains your information in a few ways: there is information that you choose to give to us, information we obtain through your use of our Services – including our Website – and information we obtain from third parties.
a. Information You Give Us
We collect information that you decide to share with us. At times, we may require you to provide certain information – including Personal Information – in order to use certain parts of our Website, fulfill your requests with us, or provide you with certain Services. For instance, we may require you to provide your name, email address or other contact information when you contact us with a question or comment. Additionally, we may need you to provide certain Personal Information to use other portions of our Services.
b. Information We Obtain When You Use Our Services
As noted above, we collect certain information from you through your use of our Services, such as Usage Data. For instance, in using our Website, we may collect information about the device you use to log into, access, and use the Website. We may collect other Generic Information in relation to how you use our Website or other Services (for example, aggregate metrics on how often certain pages on our Website are accessed and viewed).
We also may collect information through the use of cookie, pixel tags, or other technologies, as described above.
c. Information We Obtain from Third Parties
We may also obtain information about you from our third party service providers who help us provide our Services to you.
SBHC collects, processes (or asks our service providers to process on our behalf), and uses your information to provide the Services we make available to you. We therefore will collect and use your information for a variety of reasons, including:
As noted elsewhere in this Privacy Policy, SBHC uses your information to provide our Services to you.
Such general uses include, but are not limited to:
SBHC does not and will not sell your personal information Please note that SBHC may disclose your information in a number of ways in furtherance of our Services to you. For instance, we may share you information with other healthcare providers to ensure that all necessary information is transferred to facilitate necessary treatment and care.
We may also disclose or share your information for the following purposes:
SBHC takes reasonable, technical, organization, and other measures to protect the personal information we collect from being subject to accidental or unlawful destruction, accidental loss or alteration, disclosure without authorization, and any other unlawful actions taken against otherwise protected information. Moreover, SBHC takes all judicious legal, technical, and organizational measures reasonably necessary to ensure that all personal information is handled with a sufficient level of security. Furthermore, SBHC takes all reasonable measures to protect personal information when it is shared with third parties.
Despite the security measures taken, SBHC cannot guarantee the protection of the data you provide to us.
California Residents. SBHC takes reasonable steps to allow you to exercise your rights pursuant to CCPA. As such, where applicable under relevant law, you are entitled to the following[Moran, Th1] :
Please contact us using the information in the “Contact Information” section at the very bottom of this document, in relation to exercising these rights.
a. Access to Specific Information
California residents have the right to request information from us regarding the manner in which we share certain categories of personal information with this parties for their direct marketing purposes, in addition to the rights set forth above. Under California law, you have the right to send us a request at the designated address at the conclusion of this policy. You may request the following information:
1. The categories of personal information we collected about you.
2. The categories of sources for the personal information we collected about you.
3. Our business or commercial purpose for collecting that personal information.
4. The categories of third parties with whom we share that personal information.
5. The specific pieces of personal information we collected about you (also called a data portability request).
6. If we disclose or sell your information for a business purpose, you have the right to identify the personal information categories that each category of recipient obtained.
b. Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to limited exceptions. Once we receive a verifiable request, and determine that it is not subject to an exceptions, we will delete your personal information from our records. Please note, personal information involved in the ongoing treatment of our patients, with SBHC or elsewhere, will not be subject to deletion.
Moreover, we may deny your deletion request if retaining the information is necessary for us or any applicable third party to:
1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
3. Debug products to identify and repair errors that impair existing intended functionality;
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
8. Comply with a legal obligation;
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
c. Making a Request
To exercise the access or deletion rights listed above, please submit a verifiable consumer request to us by either:
Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests not submitted through one of the above-listed methods of communication.
Your request will only be processed if you are a California resident, and your identity can be verified. Furthermore, the CCPA does not apply to healthcare or employee information.
We are a covered entity under the Health Insurance Portability and Accountability Act (“HIPAA”) and are also subject to other federal and state laws governing the privacy and confidentiality of certain types of health information. When more than one law applies, we comply with the law that provides greater protection to your information. Some health information we may receive about you is protected by additional federal laws which provide greater privacy protections than HIPAA. This includes records related to substance use disorder (“SUD”) treatment that are protected under federal law, 42 CFR Part 2. The standards that apply to records covered under 42 CFR Part 2 identifying an individual as having a substance use disorder (“Part 2 Covered Information”) often vary from the standards that apply to other health information. This notice describes your rights relating to both Part 2 Covered Information and other health information. Except as otherwise outlined below in the section entitled, “Special Terms for Confidentiality of Part 2 Covered Information,” the rights, uses and disclosures, and duties provided below apply both to Part 2 Covered Information and other health information about you.
Your Rights
When it comes to your health information, you have certain rights. This section explains your rights with respect to your health information.
Obtain an electronic or paper copy of your medical record
Ask us to correct your medical record
Request confidential communications
Ask us to limit what we use or share
Get a list of those with whom we have shared your health information
Get a copy of this Notice
Choose someone to act for you
File a complaint if you feel your rights are violated
Your Choices
For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, let us know.
In the following cases, you have both the right and choice to tell us to:
If you are not able to tell us your preference, for example if you are unconscious, we may go ahead and share your information if we believe it is in your best interest. We may also share your information when needed to lessen a serious and imminent threat to health or safety.
Requirements of Other Laws
Some state and federal laws provide even greater rights, including more favorable access and amendment rights, as well as protection for particularly sensitive information. Such information includes HIV/AIDS-related information, alcohol and substance abuse treatment information, mental health information (including psychotherapy notes), and genetic information. Uses and disclosures of this information will be made only in accordance with applicable law, including by obtaining your written authorization for use and disclosure when legally required.
Our Uses and Disclosures
We typically use or share your health information in the following ways:
Provide treatment
Run our facility
Obtain payment for our services
We are allowed or required to share your information in other ways—usually in ways that contribute to the public good, such as public health and research. We have to meet many conditions in the law before we can share your information for these purposes. For more information, you can go to this online link: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html for information on privacy protections under the Health Information Portability and Accountability Act (“HIPAA”) and/or https://www.samhsa.gov/about/faqs/confidentiality-regulations for information on 42 CFR Part 2 protections specifically related to Part 2 Covered Information.
To avert serious threats and public health and safety issues
Health Oversight Activities
Conduct research
Comply with the law
Respond to organ and tissue donation requests
Work with a medical examiner or funeral director
Address workers’ compensation, law enforcement, and other government requests/activities
Respond to lawsuits and legal actions
Our Responsibilities
We are required by law to maintain the privacy and security of your health information, to provide you with notice of our legal duties and privacy practices with respect to records, to follow the duties and privacy practices described in the notice currently in effect, and give you a copy of this notice. Further, we will let you know if a breach compromises your unsecured protected health information (“PHI”) as defined by HIPAA. We will not use or share your PHI other than as described in this notice unless you tell us we can in writing. Your written authorization will typically be required for uses and disclosures of psychotherapy notes, for marketing, or involving the sale of PHI. If you provide us with authorization to use or disclose health information about you, you may revoke that authority, in writing, at any time. If you revoke your authorization, we will no longer use or disclose health information about you for the reasons covered by your written authorization except to the extent we have already relied upon your authorization. You understand that we are unable to take back any disclosures we have already made in reliance upon your prior authorization, and that we are required to retain our records of the care that we have provided to you.
Availability of Language Assistance Services
We provide language assistance services and appropriate auxiliary aids and services free of charge, when necessary for compliance with applicable law.
Changes to the Terms of this Notice
We reserve the right to change the terms of this Notice and such changes will apply to all health information we maintain. Revised Notices will be available online, at the facility, and upon request.
Special Terms for Confidentiality of Part 2 Covered Information (Substance Use Disorder Patient Records under 42 CFR Part 2)
The terms below outline special protections that apply to Part 2 Covered Information. The confidentiality of Part 2 Covered Information maintained by a program providing substance use disorder treatment or otherwise characterized as a Part 2 Program under 42 CFR Part 2 (the “Program”) is protected by federal law and regulations. Records of Part 2 Covered Information, or testimony relaying the content of such records, will not be used or disclosed in civil, criminal, administrative or legislative proceedings against you, absent your specific written consent or a court order accompanied by a subpoena or other similar legal mandate compelling disclosure and, where required by 42 CFR Part 2, after notice and an opportunity to be heard is provided.
Additional circumstances allowing use and/or disclosure of Part 2 Covered Information without consent include the following:
With the written consent of the patient and/or the patient’s authorized representative, we may use and disclose Part 2 Covered Information as follows:
A patient may provide a single consent for all future uses or disclosures for treatment, payment, and health care operations purposes. The Program will make uses and disclosures of Part 2 Covered Information not described in this notice only with the written consent of the patient or the patient’s authorized representative. A patient may revoke consent in writing, except to the extent that the Program or other lawful holder of patient identifying information that is permitted to make the disclosure has already acted in reliance on it. If you wish to revoke consent, you must notify the Privacy Officer in writing.
Program records that are disclosed to another substance use disorder Program, covered entity, or business associate pursuant to the patient’s written consent for treatment, payment, and health care operations may be further disclosed by that Part 2 Program, covered entity, or business associate, without the patient’s written consent, to the extent the HIPAA regulations permit the disclosure.
You have a right to request restrictions of disclosures of Part 2 Covered Information made with prior consent for purposes of treatment, payment, and health care operations. You have a right to request and obtain restrictions of disclosures of Program records with Part 2 Covered Information to your health plan for those services for which you have paid in full. You have a right to request an accounting of disclosures of your electronic records with Part 2 Covered Information for the past 3 years, an accounting of disclosures of your records with Part 2 Covered Information by an intermediary for the past 3 years (for example, a health information exchange if you have consented to the Program disclosing Part 2 Covered Information to the health information exchange), and an accounting of disclosures of your records with consent as provided under HIPAA. You have a right to discuss this notice with our Privacy Officer. Contact information for the Privacy Officer is provided below.
Our Privacy Policy is designed to advise you about how we collect, use, protect, and disclose the information that we collect and/or receive about you. However, our website may also contain links that lead to websites neither owned nor operated by us. As such, this Privacy Policy does not govern the practices of third parties, including partners, third-party service providers, and/or advertisers, even when those services are provided on our behalf or in partnership with us. Information gathered about you by others are governed by those distinct entities’ privacy policies. Therefore, we strongly recommend that you review the privacy policy of every website you visit.
We exercise no control over and assume no responsibility for the content, privacy policies or practices of any third party site or services.
We reserve the right to amend this privacy notice at our discretion and at any time.
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by mailing: Privacy Officer, Summit BHC, 501 Corporate Centre Dr #600, Franklin, TN 37067. You can also contact the Privacy Officer through the confidential website at summitbhc.ethicspoint.com or phone number (844) 920-1197.
