Last Updated: 9/8/2020
Michelle M Reynolds, PhD, LLC d/b/a LifeCatalyst is committed to protecting your privacy. To better help you understand how, we provide this notice explaining our online information practices.
Michelle M Reynolds, PhD, LLC d/b/a LifeCatalyst (hereinafter referred to as “we”, “us”, “our”, or “LifeCatalyst”), is a Connecticut Limited Liability Company with the registered doing-business-as name of LifeCatalyst.
INFORMATION COLLECTION AND USE
We collect information about visitors to our Site so that we can provide an experience that is responsive to our users’ and clients’ needs. We do not collect medical or credit card information on our Website, but do collect it on the Secure Patient Portal. Please do not provide any medical or payment information using the forms found on our Website. Medical and payment information can be provided using our Secure Patient Portal. You are not required to provide any personal information to access or use our Site, but registration is required to use our Secure Patient Portal.
Our Site provides forms which you can to request information from us. These forms include personal information (your name, address, telephone number, and Email address) that will be used to provide the information requested. Any information you provide, either using a form on our Site, or otherwise (by phone or Email) will be stored securely.
We will not sell, share, or trade any information you provide, and we will only use it for the purpose(s) indicated where you supplied it. We collect this information to provide you with information and updates, improve our service, and to help us determine your individual needs so we may serve you better individually, as well as collectively.
Information you provide using forms or the secure messaging tool on the Patient Portal is protected and used according to the MEDICAL PRIVACY NOTICE.
COOKIES AND TRACKING
We may also collect non-personally identifiable information about you, such as your use of our web sites, communication preferences, other aggregated data, and responses to promotional offers and surveys. We may use or disclose aggregate information only where no individual is identified for a number of purposes, including: (a) Compiling aggregate statistics of usage for improving the web site; (b) Developing, maintaining and administering the web site; and (c) Following up on comments and other messages that you submit to us through the web site.
LINKS TO EXTERNAL WEBSITES
This Site and may contain links to other websites for informational purposes. We are not responsible for the privacy practices or the content of such sites.
Our Site and Secure Patient Portal have security measures in place to protect against the loss, misuse or alteration of the information under our control. We encrypt the transmission of information using secure socket layer technology (SSL) and related methods.
When necessary, we securely supply information about you to third parties to provide various services on our behalf. These include credit card payment processing and insurance clearing house providers. We will only share information about you that is necessary for the third party to provide the requested service. These companies are prohibited from retaining, sharing, buying, selling, storing or using your personally identifiable information for any unrelated purposes.
We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method for transmitting information over the Internet, or for storing it electronically, is one hundred percent (100%) secure. Therefore, we cannot guarantee its absolute security.
GOOGLE ANALYTICS AND COOKIES
We may use a tool called “Google Analytics” to collect information about use of this Site, such as how often users visit the Site, what pages they visit when they do so, and what other sites they visited prior to coming to this Site. Google Analytics collects only the IP address assigned to you on the date you visit this Site, and not your name or other personally identifying information.
Google Analytics places a permanent cookie on your web browser to identify you as a unique user the next time you visit this Site. This cookie cannot be used by anyone but Google, Inc. The information generated by the cookie will be transmitted to and stored by Google on servers in the United States.
We only use the information received from Google Analytics to improve services on this Site. We do not combine the information collected by Google Analytics with your personally identifiable information.
COLLECTION AND USE OF PERSONAL INFORMATION OF CHILDREN UNDER AGE 13
We are committed to protecting the online privacy of children. In accordance with the Children’s Online Privacy Protection Act (”COPPA”), we will not knowingly collect any personally identifiable information from children under the age of thirteen (13) without first obtaining parental consent. Prior to providing any personally identifiable information (name, email address, address, phone number etc.), children under the age of thirteen (13) must have a parent or legal guardian provide parental consent to [email protected] The consent must state that the child’s “Parent” or “Legal Guardian”, by his or her signature, consents to the collection and transfer of the child’s personally identifiable information. Consent may be revoked by submitting a revocation of parental consent to the Email address above.
It is also our intention to adhere to the Children’s Advertising Review Unit (CARU) Guidelines on Internet advertising with its special sensitivities regarding solicitations to children under thirteen (13). We encourage parents/guardians to supervise and join their children in exploring cyberspace.
TRANSFER OF DATA ABROAD
If you are visiting this Site from a country other than the country in which our servers are located, your communications with us may result in the transfer of information across international boundaries. By visiting this Site and communicating electronically with us, you consent to such transfers.
COMPLIANCE WITH LAWS AND LAW ENFORCEMENT
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law.
Except as outlined in the MEDICAL PRIVACY NOTICE, we will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including without limitation subpoenas), to protect our property and rights or the property and rights of a third party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be illegal or unethical. We will also share your information to the extent necessary to comply with ICANN’s rules, regulations and policies.
To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of legal process.
CORRECTING, UPDATING AND REMOVING PERSONAL INFORMATION
You may alter, update or deactivate your account information or opt out of receiving communications from us at any time. To alter or request removal of your contact information that we may have on file, or to opt-out of receiving communication from us, please send a written request via Email to [email protected]
We will respond to your request for access or to modify or deactivate your information within thirty (30) days.
MEDICAL PRIVACY NOTICE
THIS NOTICE DESCRIBES HOW HEALTH INFORMATION MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
OUR PLEDGE REGARDING HEALTH INFORMATION
We understand that health information about you and your health care is personal. We are committed to protecting health information about you. Your healthcare provider creates a record of the care and services you receive from them. This record is needed to provide you with quality care and to comply with certain legal requirements. This notice applies to all of the records of your care generated by this mental health care practice. This notice will tell you about the ways in which your health information may be used and disclosed. We also describe your rights to the health information kept about you, and describe certain obligations we have regarding the use and disclosure of your health information. We are required by law to:
- Make sure that protected health information (“PHI”) that identifies you is kept private.
- Give you this notice of our legal duties and privacy practices with respect to health information.
- Follow the terms of the notice that is currently in effect.
- Michelle M Reynolds, PhD, LLC d/b/a LifeCatalyst can change the terms of this Notice, and such changes will apply to all information we have about you. The new Notice will be available upon request and on our website.
HOW WE MAY USE AND DISCLOSE HEALTH INFORMATION ABOUT YOU
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.
For Treatment Payment, or Health Care Operations: Federal privacy rules (regulations) allow health care providers who have direct treatment relationship with the patient/client to use or disclose the patient/client’s personal health information without the patient’s written authorization, to carry out the health care provider’s own treatment, payment or health care operations. We may also disclose your protected health information for the treatment activities of any health care provider. This too can be done without your written authorization. For example, if a clinician were to consult with another licensed health care provider about your condition, we would be permitted to use and disclose your person health information, which is otherwise confidential, in order to assist the clinician in diagnosis and treatment of your mental health condition.
Disclosures for treatment purposes are not limited to the minimum necessary standard. Because therapists and other health care providers need access to the full record and/or full and complete information in order to provide quality care. The word “treatment” includes, among other things, the coordination and management of health care providers with a third party, consultations between health care providers and referrals of a patient for health care from one health care provider to another.
Lawsuits and Disputes: If you are involved in a lawsuit, we may disclose health information in response to a court or administrative order. We may also disclose health information about your child in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute, but only if efforts have been made to tell you about the request or to obtain an order protecting the information requested.
CERTAIN USES AND DISCLOSURES REQUIRE YOUR AUTHORIZATION:
- Psychotherapy Notes. Your Michelle M Reynolds, PhD, LLC d/b/a LifeCatalyst provider keeps “psychotherapy notes” as that term is defined in 45 CFR § 164.501, and any use or disclosure of such notes requires your Authorization unless the use or disclosure is: a. For their use in treating you. b. For their use in training or supervising mental health practitioners to help them improve their skills in group, joint, family, or individual counseling or therapy. c. For their use in defending themselves or Michelle M Reynolds, PhD, LLC d/b/a LifeCatalyst in legal proceedings instituted by you. d. For use by the Secretary of Health and Human Services to investigate our compliance with HIPAA. e. Required by law and the use or disclosure is limited to the requirements of such law. f. Required by law for certain health oversight activities pertaining to the originator of the psychotherapy notes. g. Required by a coroner who is performing duties authorized by law. h. Required to help avert a serious threat to the health and safety of others.
- Marketing Purposes. As a psychotherapy practice, Michelle M Reynolds, PhD, LLC d/b/a LifeCatalyst will not use or disclose your PHI for marketing purposes.
- Sale of PHI. As a psychotherapy practice, Michelle M Reynolds, PhD, LLC d/b/a LifeCatalyst will not sell your PHI in the regular course of business.
CERTAIN USES AND DISCLOSURES DO NOT REQUIRE YOUR AUTHORIZATION.
Subject to certain limitations in the law, we can use and disclose your PHI without your Authorization for the following reasons:
- When disclosure is required by state or federal law, and the use or disclosure complies with and is limited to the relevant requirements of such law.
- For public health activities, including reporting suspected child, elder, or dependent adult abuse, or preventing or reducing a serious threat to anyone’s health or safety.
- For health oversight activities, including audits and investigations.
- For judicial and administrative proceedings, including responding to a court or administrative order, although our preference is to obtain an Authorization from you before doing so.
- For law enforcement purposes, including reporting crimes.
- To coroners or medical examiners, when such individuals are performing duties authorized by law.
- For workers’ compensation purposes. Although our preference is to obtain an Authorization from you, we may provide your PHI in order to comply with workers’ compensation laws.
- Appointment reminders and health related benefits or services. We may use and disclose your PHI to contact you to remind you that you have an appointment with your Michelle M Reynolds, PhD, LLC d/b/a LifeCatalyst healthcare provider. We may also use and disclose your PHI to tell you about treatment alternatives, or other health care services or benefits that we offer.
CERTAIN USES AND DISCLOSURES REQUIRE YOU TO HAVE THE OPPORTUNITY TO OBJECT.
Disclosures to family, friends, or others. We may provide your PHI to a family member, friend, or other person that you indicate is involved in your care or the payment for your health care, unless you object in whole or in part. The opportunity to consent may be obtained retroactively in emergency situations.
YOU HAVE THE FOLLOWING RIGHTS WITH RESPECT TO YOUR PHI:
- The Right to Request Limits on Uses and Disclosures of Your PHI. You have the right to ask Michelle M Reynolds, PhD, LLC d/b/a LifeCatalyst not to use or disclose certain PHI for treatment, payment, or health care operations purposes. We are not required to agree to your request, and your healthcare provider may say “no” if they believe it would adversely affect your health care.
- The Right to Request Restrictions for Out-of-Pocket Expenses Paid for In Full. You have the right to request restrictions on disclosures of your PHI to health plans for payment or health care operations purposes if the PHI pertains solely to a health care item or a health care service that you have paid for out-of-pocket in full.
- The Right to Choose How PHI is Sent to You. You have the right to ask Michelle M Reynolds, PhD, LLC d/b/a LifeCatalyst to contact you in a specific way (for example, home or office phone) or to send mail to a different address, and we will agree to all reasonable requests.
- The Right to See and Get Copies of Your PHI. Other than “psychotherapy notes,” you have the right to get an electronic or paper copy of your medical record and other information that Michelle M Reynolds, PhD, LLC d/b/a LifeCatalyst has about you. We will provide you with a copy of your record, or a summary of it, if you agree to receive a summary, within 30 days of receiving your written request, and I may charge a reasonable, cost-based fee for doing so.
- The Right to Get a List of the Disclosures Made About You. You have the right to request a list of instances in which we have disclosed your PHI for purposes other than treatment, payment, or health care operations, or for which you provided an Authorization. We will respond to your written request for an accounting of disclosures within 60 days of receiving it. The list we will give you will include disclosures made in the last six years unless you request a shorter time. We will provide the list to you at no charge, but if you make more than one request in the same year, we will charge you a reasonable cost based fee for each additional request.
- The Right to Correct or Update Your PHI. If you believe that there is a mistake in your PHI, or that a piece of important information is missing from your PHI, you have the right to request that we correct the existing information or add the missing information. We may say “no” to your request, but will tell you why in writing within 60 days of receiving your written request.
- The Right to Get a Paper or Electronic Copy of this Notice. You have the right get a paper copy of this Notice, and you have the right to get a copy of this notice by e-mail. And, even if you have agreed to receive this Notice via e-mail, you also have the right to request a paper copy of it.
EFFECTIVE DATE OF THE MEDICAL PRIVACY NOTICE
This notice went into effect on August 17, 2020
CHANGES IN OUR PRACTICES