Notice of Privacy Practices

dafne.care/npp

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

This Notice does not apply to personal information collected through the Dafne platform unless it is Protected Health Information as defined under HIPAA. This Notice of Privacy Practices does not apply to non-PHI; the Dafne Privacy Policy applies to that information.

This Notice describes how Ordonez Counseling, A Licensed Clinical Social Worker Corporation and its associated provider groups (each, a "Dafne Provider Entity" and collectively, the "Dafne Provider Group," "we," "us," or "our") collect, use, and disclose your protected health information ("PHI"). Together with its contracted clinicians, each Dafne Provider Entity is part of an organized health care arrangement that jointly uses and discloses PHI to carry out treatment, payment, or health care operations and for other purposes that are permitted or required by law. As an organized health care arrangement, the Dafne Provider Group agrees to abide by the terms of this Notice. This Notice applies to therapy services provided by independent licensed clinicians on the Dafne platform (the "Services").

The Dafne Provider Group is associated with the operator of the Dafne platform, which provides certain management and administrative services to the Dafne Provider Group and functions as its Business Associate under HIPAA.

Effective Date

This Notice is effective as of the date listed above and will remain in effect until we replace it. We must abide by the terms of this Notice while it is in effect.

PHI is information about you that may be used to identify you and that relates to your past, present, or future physical or mental health condition; the provision of health care to you; or your past, present, or future payment for the provision of health care.

Information We Collect About You

We collect PHI to provide you with the Services, from the following sources: directly from you, such as information you submit when signing up for and receiving the Services, including your intake responses; indirectly from you, such as through your use of the platform in connection with your care; and from third parties involved in your care or payment for care.

When We Use and Disclose Your Information

To provide you with the Services, we use and disclose your PHI for the following purposes:

Treatment. To provide you with the Services. For example, we will disclose your PHI to your therapist for treatment purposes, including coordinating a referral.

Payment. To collect payment and for other payment-related purposes, including through our payment processors.

Health Care Operations. To operate our practice, including quality review, clinical supervision, training, credentialing, and audits.

We may also use PHI to: engage third parties to assist with our payment and health care operations—if any such third party needs access to PHI to perform services on our behalf, we require a written agreement that protects the PHI, and we provide only the minimum PHI necessary; communicate with family and friends who are involved in your care or payment for your care to the extent legally authorized; and create de-identified and aggregate information to be used for any lawful purpose.

When We May or Must Disclose Your Information Without Your Authorization

In certain limited circumstances, we may be permitted or required by law to use or disclose your PHI without your authorization, including: for public health activities; to report suspected abuse or neglect of a child, elder, or dependent adult; for judicial and administrative proceedings, such as responding to court orders and lawful process; to prevent or lessen a serious and imminent threat of harm to a person or the public, including by contacting your emergency contact, local crisis services, or emergency responders at your location; when required by law or for law enforcement purposes; for state and federal health oversight activities, such as licensing and disciplinary action; to coroners, medical examiners, and funeral directors in limited circumstances; for research approved by an institutional review board; for specialized government functions; and for workers' compensation claims.

When We Need Your Authorization to Use or Disclose PHI

Your written authorization is required prior to: any use or disclosure of psychotherapy notes, except as permitted by law; use or disclosure of PHI for marketing purposes; and any sale of PHI. We will not use or disclose PHI for these purposes, or for any other purpose not described in this Notice, without your written authorization. You have the right to revoke any authorization you previously provided, except to the extent we have already relied on it. With regard to deceased individuals, we comply with the HIPAA Privacy Rule's requirements for uses and disclosures of PHI for a period of 50 years following death.

Special Protections

Certain information—including psychotherapy notes and, where applicable, substance use disorder treatment records—has additional protections under federal and state law. Where state law is more protective of your information than HIPAA, we follow state law.

Your Rights Regarding Your Information

Right to Access PHI. With certain exceptions, you have the right to review and obtain a copy of your PHI, including an electronic copy, by emailing hipaa@dafne.care. We may charge a reasonable, cost-based fee. In limited circumstances we may deny your request; if so, we will inform you of the reason and whether you have the right to have the denial reviewed by a licensed health care professional who did not participate in the original decision.

Right to Request Amendment. You have the right to request that we amend your PHI if you believe it is inaccurate or incomplete, by emailing hipaa@dafne.care. If we deny your request, you may submit a statement of disagreement for inclusion in your record.

Right to Request Confidential Communications. You may request that we communicate with you about PHI by alternative means or at an alternative location, by emailing hipaa@dafne.care. We will accommodate reasonable requests.

Right to Request Restrictions. You may request restrictions on certain uses and disclosures of your PHI by emailing hipaa@dafne.care. We are not required to agree to all restrictions, but we must agree not to disclose PHI to your health plan for services you have paid for in full out of pocket, upon your request.

Right to an Accounting of Disclosures. You have the right to receive an accounting of our disclosures of your PHI, except disclosures for treatment, payment, health care operations, and certain other purposes, by emailing hipaa@dafne.care. Your first accounting in any 12-month period is free; we may charge a reasonable fee for additional requests within that period.

Right to a Paper Copy. You have the right to request a paper copy of this Notice at any time, even if you agreed to receive it electronically.

Right to File a Complaint. If you believe your privacy rights have been violated, you may file a complaint by emailing our Privacy Officer at hipaa@dafne.care. You also have the right to file a complaint with the U.S. Department of Health and Human Services, Office for Civil Rights, by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints. You will not be retaliated against for filing a complaint.

Our Duties Regarding Your PHI

We are required by law to maintain the privacy and security of PHI, to provide notice of our legal duties and privacy practices with respect to PHI, to notify affected individuals following any breach of unsecured PHI, and to abide by the terms of this Notice currently in effect.

Changes to This Notice

We reserve the right to change this Notice at any time. If we change this Notice, we will post the new version at dafne.care/notice-of-privacy-practices and make it available upon request. New terms will apply to all PHI we maintain.

Contact

For additional information about our privacy practices, contact our Privacy Officer: hipaa@dafne.care.