Effective Date: January 01, 2025
This privacy notice for Towerlight Health and Wellness, LLC ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:
We may modify this Policy at any time. All changes will be effective immediately upon posting. Material changes will be conspicuously posted or otherwise communicated to you.
What personal information do we process?
When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Towerlight Health and Wellness, LLC and the Services, the choices you make, and the products and features you use. This may include:
Do we process any sensitive personal information?
No. We do not process sensitive personal information.
Do we receive any information from third parties?
No. We do not receive any information from third parties.
How do we process your information?
We process your information to: Provide and improve our Services. Communicate with you, such as responding to inquiries or scheduling appointments. Enhance website functionality and user experience. Ensure security and prevent fraud. Comply with applicable legal and regulatory obligations. We process your information only when we have a valid legal reason to do so, such as your consent or a legal obligation.
In what situations and with which parties do we share personal information?
We may share your information in specific situations, including: With Service Providers: Third-party vendors that assist with website hosting, email delivery, or appointment scheduling. For Legal Compliance: When required by law, court orders, or government requests. During Business Transfers: In the event of a merger, sale, or transfer of company assets, your information may be included in the transaction. We do not sell your personal information.
How do we keep your information safe?
We have organizational and technical processes in place to protect your personal information, including: Data encryption during transmission. Regular monitoring of our systems for vulnerabilities. However, no system can guarantee 100% security.
What are your rights?
Depending on where you are located, you may have certain rights regarding your personal information:
Vermont (VT):
Right to know the categories of personal information collected and shared. Opt out of sharing personal information for marketing purposes.
Florida (FL):
Right to access, correct, or delete your personal information.
Massachusetts (MA):
Right to request deletion of your information. Right to request a copy of your information in a portable format. To exercise your rights, contact us at privacy@towerlightcapecod.com.
How do you exercise your rights?
You can exercise your rights by contacting us directly at privacy@towerlightcapecod.com. We will respond to your request in accordance with applicable data protection laws.
Questions or concerns?
Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@towerlightcapecod.com.
The practice uses a cloud-based HIPAA compliant electronic medical record through Charm EHR, and is able to electronically prescribe certain medications also. According to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), a patient has the right to read and amend their own medical records. The doctor will generally accommodate most reasonable requests, except in certain cases where it may potentially worsen your condition, endanger the life or safety of your life or another person, or if there is a potential breach of confidentiality. If denied access to your medical records, you may submit your appeal in writing to Towerlight Health and Wellness, LLC. If you would like your medical records sent to another provider (such as another therapist, primary care physician, etc.), then the office will facilitate that request within a timely manner upon receipt of a written consent for a release of information to the other provider or agency.Confidentiality and Release of InformationAll records and treatment details are confidential and secured and will NOT be released without your authorization. If a breach has occurred, you will be notified in writing.
Limitations to confidentiality include:
1. Client authorizes release of information with a signature.
2. Client authorizes release of information for reimbursement purposes as defined by the insurance provider.
3. Client’s mental condition becomes an issue in a lawsuit.
4. Client presents as a danger to self.
5. Client presents a danger to others.
6. Child or elder abuse or neglect is suspectedWhat is Protected Health Information?Protected Health Information or PHI, is information that individually identifies a patient and information which a provider receives from the patient, another health care provider, health plan, employer, or a health care clearing house that relates to the patient’s
1) past,
present, or future physical or mental health conditions, 2) the provision of health care to the patient, or 3) the past, present, or future
payment for the patient’s health care.
Notice of Privacy Practices
This Notice of Privacy Practices (“Notice”) applies to: Towerlight Health and Wellness, LLC, 13 Steeple St., Ste 202-37, Mashpee, MA 02649.
SPECIAL PROTECTIONS FOR SUBSTANCE USE DISORDER (SUD) RECORDS (42 CFR PART 2):Consent for Use and Disclosure
We cannot use or share your SUD records without your written consent, except in very limited situations allowed by law. You may choose to sign a single consent form allowing us to use and share your records for treatment, payment, and healthcare operations (such as coordinating care, billing, and quality improvement).
Redisclosure
If you give consent, HIPAA-covered providers, health plans, and business associates who receive your records may redisclose them as permitted by HIPAA. However, records cannot be used to take legal action against you in civil, criminal, administrative, or legislative proceedings unless you also give written consent or a court specifically orders it.
Breach Notification
If a breach involves your SUD records, you will be notified under the same rules that apply to HIPAA breaches.
Your Rights
You have the same privacy rights described in this Notice for all health records, and you may also file a complaint with the U.S. Department of Health and Human Services if you believe your SUD confidentiality rights have been violated.OUR PLEDGE REGARDING PROTECTED HEALTH INFORMATION (PHI):
We understand that your health information is personal. We are committed to keeping your PHI safe. This notice will tell you about the ways we may use and disclose your PHI, your privacy rights, and our duties regarding PHI.
We are required by law to make sure that your PHI is kept private, give you this Notice of our legal duties and privacy practices, notify you of a breach of unsecured PHI, and follow the terms of the Notice that is currently in effect.
Privacy practices refer to the ways Towerlight Health and Wellness, LLC and your provider may use and disclose your PHI. This Notice explains your rights and the legal obligations of Towerlight Health and Wellness, LLC and your provider regarding the privacy of your PHI. Towerlight Health and Wellness, LLC and your provider is required by law to notify you following a breach of privacy of your PHI.
YOUR PRIVACY RIGHTS WITH RESPECT TO PHI:
The following is a list of your rights and how you may exercise these rights.
• Right to Request Restrictions - You have the right to request a restriction or limitation on the PHI we use or disclose about you for treatment, payment, or health care operations. We are required to honor the request to restrict disclosures of PHI to a health plan where you have paid out-of-pocket in full for the healthcare item or service you have received. Otherwise, although we will consider your request, we are not required to agree to or abide by your request. You must make your request for any restrictions or limitations in writing to Towerlight Health and Wellness, LLC, 13 Steeple St., Ste 202-37, Mashpee, MA 02649. In your request, you must tell us what PHI you want to limit, whether you want to limit our use, disclosure, or both, and to whom you want delimits to apply (for example, disclosures to your spouse).
• Right to Request Confidential Communications - You have the right to request that we communicate with you in a confidential manner. You have the right to request that we communicate with you about your PHI in a certain way or at a certain location. For example, you may ask that we only contact you at work or by mail. You must make your request for confidential communications in writing to Towerlight Health and Wellness, LLC, 13 Steeple St., Ste 202-37, Mashpee, MA 02649. We will accommodate reasonable requests. Your request must specify how or where you wish to be contacted. For example, if you wish to be contacted by telephone, and be sure to provide an appropriate telephone number.
• Right to Review and Copy - You have the right to review and obtain a copy of PHI that may be used to make decisions about your care. You must submit your request for your PHI in writing to Towerlight Health and Wellness, LLC, 13 Steeple St., Ste 202-37, Mashpee, MA 02649. If you request a copy of the PHI we may charge a reasonable fee for the costs of copying, mailing, or other supplies associated with your request. Under very limited situations, you may not be allowed to review or obtain a copy of parts of your health information.
(For example, our healthcare provider may decide for clear treatment reasons that sharing your PHI with you will likely have an adverse effect on you. If your request is denied, you will be notified of this decision in writing and you may appeal this decision in writing to the owner.)
• Right to Amend - If you feel that PHI we have asked about you is incorrect or incomplete, and then you may ask us to change the PHI. You have the right to request a change for as long as the PHI is maintained by us.
Submit your request to Towerlight Health and Wellness, LLC, 13 Steeple St., Ste 202-37, Mashpee, MA 02649. Your request must be made in writing and include a reason that supports your request. We may deny your request if you ask us to change PHI that was not created by us, is not part of our records, is not part of the PHI which you would be permitted to see and get a copy of, or we believe the information is accurate and
complete.
• Right to an Accounting of Disclosures - you have the right to request an accounting of disclosures of PHI. This is a list of certain disclosures of PHI we made in special situations listed above. These disclosures are not related to treatment, payment, or health care operations. When we make these disclosures, we are not required to obtain your authorization before we disclose your PHI to others. You must submit your request for an accounting of disclosures in writing to Towerlight Health and Wellness, LLC, 13 Steeple St., Ste 202-37, Mashpee, MA 02649. Your request must tell us the calendar dates you want to see (the time period may include up to six years of information prior to the date of the request and parentheses. There will be no charge for the first list you request within a 12-month period. We may charge you for the costs of providing any additional lists. We will tell you about any cost involved. You may choose to withdraw or modify your request before any costs are incurred.
• Right to a Paper Copy of This Notice - You have a right to receive a paper copy of this Notice at any time, even if you have received this Notice previously. To obtain a paper copy, please contact Towerlight Health and Wellness, LLC, 13 Steeple St., Ste 202-37, Mashpee, MA 02649.
THE WAYS WE MAY USE AND DISCLOSE YOUR PHI:
Federal law allows us to use or disclose your PHI without your permission for the following purposes:
For Treatment - For example, treatment may include:
• Disclosing your PHI to doctors, nurses, technicians, student trainees, and other people who help with your care
• Coordinating services you need, such as prescriptions, lab work, and x-rays
• Contacting you for appointment reminders
• Contacting you about health-related benefits and services
• Disclosing to a doctor outside of the health system for your treatment. For example, a doctor treating you for a broken leg may need to know if you have diabetes because diabetes may slowly healing process. In addition, the doctor may need to tell the dietitian if you have diabetes so that we can arrange for appropriate meals
• Updating your healthcare providers about care you received
For Payment - For example, payment may include:
• Determining eligibility for healthcare services and pre-certifying benefits
• Coordinating benefits with insurance payers
• Billing and collecting for healthcare services provided
• Facilitating payment to another provider who has participated in your care
For Health Care Operations - For example, healthcare operations may include:
• Improving quality of care
• Accrediting certifying licensing or credentialing healthcare providers
• Reviewing competence or qualifications of healthcare professionals
• Developing maintaining and supporting computer Group
• Managing budgeting and planning activities and reports
• Improving healthcare processes, reducing healthcare costs, and accessing organizational performance for us and other healthcare providers and health plans that care for you.
ADDITIONAL USES AND DISCLOSURES FOR WHICH AUTHORIZATION OR OPPORTUNITY TO AGREE OR OBJECT IS NOT REQUIRED BY HIPAA
• Research - We may contact you about research studies you may qualify for so that you can decide if you want to participate. If you qualify to participate in a research study, then you will be asked to sign a separate consent form to participate in the project that includes an authorization for use in possible disclosure of your
information outside the health system.
• As Required by Law - We will disclose PHI about you when required to do so by federal, state, or local law.
• Public Health Risks - As required by law, we may disclose your PHI with public health authorities to prevent
or control disease, injury, or disability; report communicable diseases or infection exposure such as HIV, hepatitis, or tuberculosis; report medical device safety issues and adverse events to the federal FDA; and report vital events such as births and deaths.
• Victims of Abuse, Neglect, or Domestic Violence - We may disclose your PHI to government agencies authorized by law to receive reports of suspected child or elder abuse, neglect, or domestic violence if we believe that you have been a victim.
• Health Oversight Activities - We may disclose your PHI to a health oversight agency for activities permitted by law. For example, these activities may include audits, investigations, inspections, or licensure. Healthcare oversight agencies include government agencies that oversee the healthcare system, government benefits, programs, and agencies that enforce civil rights laws.
• Judicial and Administrative Proceedings - We may disclose your PHI in the course of an administrative or judicial proceeding, such as in response to a court order or subpoena as permitted by federal and state law.
• Law Enforcement - We may disclose your PHI to a law enforcement official if required or permitted by law for reasons such as reporting crimes occurring at an office site or providing routine reporting to law enforcement agencies, such as for gunshot wounds.
• Deceased Persons PHI - We may disclose PHI to a funeral director as necessary so that they may carry out their duties. We may also disclose PHI to a corner or medical examiner for identification purposes, determining cause of death, or performing other duties authorized by law.
• Organ and Tissue Donation - We may disclose your PHI to organizations that handle organ, tissue, and procurement to facilitate organ, tissue, and donation and transplantation.
• To Avert a Serious Threat to Health or Safety - We may use and disclose your PHI when necessary to prevent a serious threat to your health and safety, the public’s health and safety, or another person’s health and safety.
• Specialized Government Functions - We may disclose your PHI to authorized federal officials for national security and intelligence, military, or veteran’s activities required by the law.
• Workers Compensation - We may disclose your PHI to workers compensation as required by workers compensation laws or other similar programs. These programs provide benefits for work-related injuries or illnesses.
• Disaster Relief Efforts - We may use or disclose your PHI to a public or private entity authorized by law or by
its charter to assist in disaster relief efforts, for the purpose of coordinating with such entity in the notification of
your family member, personal representative, or another person responsible for your care.
• Individuals Involved in Your Care or Payment for Your Care - We may communicate with your family,
friends, or others involved in your care or payment for your care. For example, an emergency room doctor may discuss a patient’s treatment in front of your friend if you ask that your friend come into the room.
• Other Uses and Disclosures Made Only with your Written Permission - All other uses and disclosures not described in the Notice will be made only with your written authorization. For example, we would not release your PHI to your supervisor for employment purposes without your permission, as described in this Notice. You may revoke your permission, in writing, at any time. If you revoke your permission, then we will no longer use or disclose PHI about you, for the reasons covered by your written permission, except to the extent that we have already used or disclosed your PHI. Most uses and disclosures of psychotherapy notes, uses and disclosure of PHI for marketing purposes, and disclosures that constitute the sale of PHI require your authorization. Other uses and disclosures not described in the Notice will be made only with your authorization.
OUR DUTIES
• Notice Changes - We reserve the right to change this Notice. We reserve the right to make the revised or changed Notice effective for PHI we already have about you and any PHI we receive in the future. Current copies of this notice will be available at registration locations. The current notice will also be posted at our website. The effective date of the notice will be posted on the first page.
• Cell Phone/Email Mail - We ask you not to use your cell phone or email in contacting our healthcare providers, personally. Cell Phone and Emails sent to and from you are not secure and could be read by a third-party.
• Complaints - If you believe your privacy rights have been violated, then you have the right to submit a complaint to us. Any complaints shall be made in writing or by telephone to Towerlight Health and Wellness, LLC, 13 Steeple St., Ste 202-37, Mashpee, MA 02649. We encourage you to express any concerns you may have regarding the privacy of your information. You will not be retaliated against or penalized in any way for filing a complaint. You may also file a written complaint with the secretary of the US Department of Health and Human Services, 200 Independence Ave. S W, Washington DC, 20201, or call toll-free 877-696-6775, by email to OCRComplaint@hhs.gov or to Region V, Office for Civil Rights, US Department of Health and Human Services, 233 North Michigan Ave, Suite 240, Chicago, IL 60601, voice phone 312-886-2359, fax
312-886-1807, or TDD 312-353-5693.
OPTING OUT
The following are areas which require your provider to give you the opportunity to object and opt out:
• Individuals involved in your care or payment for your care - Unless you object, We may, with your consent, disclose
to a member of your family, a relative, a close friend, or any other persons you identify, your PHI that directly relates
to that person’s involvement in your health care. If you are unable to agree or object to such a disclosure, We may
disclose such information as necessary if your provider determines that it is in your best interest based on their
professional judgement.
• Disaster Relief – We may disclose your PHI to disaster relief organizations that seek your PHI to coordinate your
care, or notify family and friends of your location or condition in a disaster. We will provide you with an opportunity
to agree or object to such a disclosure whenever we practicably can do so.
• Fundraising Activities – We may use or disclose your PHI, as necessary, in order to contact you for fundraising
activities. You have the right to opt out of receiving fundraising communications.
• Marketing Communications - We may use or disclose your PHI as permitted to inform you about services, products,
or programs that may be beneficial to you. However, you have the right to opt out of receiving such marketing
communications.
Discrimination is Against the Law
Towerlight Health and Wellness, LLC complies with applicable Federal civil rights laws and does not discriminate on the basis of race, color, national origin, age, disability, or sex. Towerlight Health and Wellness, LLC does not exclude people or treat them differently because of race, color, national origin, age, disability, or sex (including pregnancy, sex stereotyping, gender identity, gender expression and being transgendered).
Towerlight Health and Wellness, LLC:
Provides free aids and services to people with disabilities to communicate effectively with us, such as:
Qualified sign language interpreters
Written information in other formats (large print, audio, accessible electronic formats, other formats)
If you need these services, contact the main office at patients@towerlightcapecod.com or by phone (508) 375-7936.If you believe that Towerlight Health and Wellness, LLC has failed to provide these services or discriminated in another way on the basis of race, color, national origin, age, disability, or sex, you can file a grievance by mail with: Towerlight Health and Wellness, Patient Relations, 13 Steeple St., ste 202-37, Mashpee, MA 02649-3278.
You can also file a civil rights complaint with the U.S. Department of Health and Human Services, Office for Civil Rights, electronically through the Office for Civil Rights Complaint Portal, available at https://ocrportal.hhs.gov/ocr/portal/lobby.jsf, or by mail or phone at: U.S. Department of Health and Human Services 200 Independence Avenue, SW Room 509F, HHH Building Washington, D.C. 20201
1-800-368-1019, 800-537-7697 (TDD) Complaint forms are available at http://www.hhs.gov/ocr/office/file/index.htmlEach party acknowledges that it has had time to review this agreement and, as desired, consult with counsel. In the interpretation of this agreement, no adverse presumption shall be made against any party on the basis that it has prepared, or participated in the preparation of, this agreement.
The Parties agree that a signed copy of this Agreement which is electronically signed or transmitted by facsimile transmission shall be binding upon the sending Party to the same extent as if it or they delivered an original signature upon this Agreement. All consents are subject to annual review by the Parties.
Appointment Management:
Schedule and attend all appointments on time.
Notify the office at least 24 hours in advance if you need to cancel or reschedule an appointment.
Understand that repeated missed appointments may result in termination of care.
Accurate Information:
Provide accurate and complete information about your medical history, current medications, and any other relevant health information.
Update the office promptly about any changes in your contact information, insurance details, or health status.
Compliance with Treatment:
Follow the treatment plan prescribed by your healthcare provider, including taking medications as directed.
Actively participate in your treatment, including attending therapy sessions and following through with recommended activities or lifestyle changes.
Communicate any side effects, concerns, or difficulties you experience with your treatment plan.
Financial Responsibilities:
Understand your insurance coverage and ensure that necessary referrals or authorizations are obtained.
Pay any co-pays, deductibles, or fees at the time of your appointment.
Address any billing issues promptly with the office.
Behavior and Conduct:
Treat all staff and other patients with respect and courtesy.
Abide by the office's policies and procedures, including those related to privacy and confidentiality.
Refrain from any disruptive or harmful behavior while on the premises.
Confidentiality and Privacy:
Respect the privacy and confidentiality of other patients.
Understand and comply with the office's policies regarding the use and disclosure of your health information.
Communication:
Maintain open and honest communication with your healthcare provider.
Ask questions if you do not understand your diagnosis, treatment plan, or any other aspect of your care.
Inform your provider of any other treatments or medications you are receiving from other healthcare professionals.
Emergency Protocols:
Know what to do in case of a psychiatric emergency, including who to contact and where to go.
Follow the office's guidelines for handling urgent situations or crises outside of normal business hours.
Substance Use:
Disclose any use of substances, including alcohol, drugs, and over-the-counter medications, that could affect your treatment.
Follow the office's policies regarding substance use and refrain from being under the influence of substances during appointments.
Feedback and Improvement:
Provide constructive feedback about your care and the services provided.
Participate in surveys or other quality improvement activities if requested.
These responsibilities help ensure a productive and supportive environment for both patients and healthcare providers, facilitating effective and efficient care.