NOTICE OF PRIVACY PRACTICES

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 is effective: April 15, 2015. If you have any questions about this Notice please contact our Privacy Officer, Patti Gosser, at (360) 433-0428.

This Notice of Privacy Practices (“Notice”) describes how Corporate Translation Services, Inc. (“CTS Language Link”) may use and disclose your Protected Health Information under the Health Insurance Portability and Accountability Act (HIPAA) to assist in your treatment, to facilitate payment for treatment you have received, for CTS Language Link’s operations, and for other purposes that are permitted or required by law.

This Notice also describes your rights to access and control your Protected Health Information. “Protected Health Information” is information that may identify you and that relates to your past, present or future physical or mental health or condition and related health care services. We are required by law to abide by the terms of this Notice. Your health care providers, health insurance company or other representatives may have different policies or notices regarding the use and disclosure of your Protected Health Information.

HOW WE MAY USE AND DISCLOSE YOUR PROTECTED HEALTH INFORMATION

Your Protected Health Information may be used and disclosed by CTS Language Link’s interpreters or translators, your physician, and other who are involved in your care and treatment for the purpose of providing health care services to you. Your Protected Health Information may also be used and disclosed to pay your health care bills.

The following categories describe different types of uses and disclosures of your Protected Health Information that CTS Language Link is allowed to make. Not every type of use or disclosure within in a category will be listed. However, all of the ways in which we are permitted to use or disclose your Protected Health Information will fall into one of the categories listed.

Treatment:
CTS Language Link will use and disclose your Protected Health Information to assist your health care providers in providing your treatment, or to coordinate or manage your health care and any related services. For example, we would disclose your Protected Health Information, as necessary, to a health care provider that provides care to you to assist in diagnosis and treatment.

Payment:
Your Protected Health Information will be used and disclosed, as needed, to assist appropriate parties in obtaining payment for your health care services provided by your health care provider. This may include providing services in connection with certain activities that your health insurance plan may undertake before it approves or pays for the health care services recommended for you such as: determining eligibility or coverage for insurance benefits, reviewing services provided to you for medical necessity, and undertaking utilization review activities.

Health Care Operations:
We may use or disclose, as needed, your Protected Health Information in order to support the business activities of CTS Language Link. These activities include, but are not limited to, quality assessment activities, employee review activities, training of interpreters and translators, licensing, and conducting or arranging for other business activities.

We will share your Protected Health Information with third party “business associates” or “subcontractors” that perform various activities (for example, interpretation or translation services) for CTS Language Link. Whenever an arrangement between our company and a business associate or subcontractor involves the use or disclosure of your Protected Health Information, we will have a written contract that contains terms that will protect the privacy of your Protected Health Information.

We may use or disclose your Protected Health Information, as necessary, to provide you with appointment reminders and information about benefits and services that may be of interest to you. You may contact our Privacy Officer to request that these materials not be sent to you.

Other Permitted and Required Uses and Disclosures That We May Make Without Your Authorization or Opportunity to Agree or Object:

We may use or disclose your Protected Health Information in the following situations without your authorization or providing you the opportunity to agree or object. These situations include:

Required By Law:
We may use or disclose your Protected Health Information to the extent that the use or disclosure is required by law. For example, we may disclose your Protected Health Information when required by a court order in a litigation proceeding such as a malpractice action. The use or disclosure will be made in compliance with the law and will be limited to the relevant requirements of the law. You will be notified, if required by law, of any such uses or disclosures.

Public Health:
We may disclose your Protected Health Information for public health activities and purposes to a public health authority that is permitted by law to collect or receive such information. For example, a disclosure may be made for the purpose of preventing or controlling disease, injury or disability.

Communicable Diseases:
We may disclose your Protected Health Information, if authorized by law, to a person who may have been exposed to a communicable disease or may otherwise be at risk of contracting or spreading the disease or condition.

Health Oversight:
We may disclose Protected Health Information to a health oversight agency for activities authorized by law, such as audits, investigations, and inspections. Oversight agencies seeking this information include government agencies that oversee the health care system, government benefit programs, other government regulatory programs and civil rights laws.

Abuse or Neglect:
We may disclose your Protected Health Information to a public health authority that is authorized by law to receive reports of child abuse or neglect. In addition, we may disclose your Protected Health Information if we believe that you have been a victim of abuse, neglect or domestic violence to the governmental entity or agency authorized to receive such information. In this case, the disclosure will be made consistent with the requirements of applicable federal and state laws.

Food and Drug Administration:
We may disclose your Protected Health Information to a person or company required by the Food and Drug Administration for the purpose of quality, safety, or effectiveness of FDA-regulated products or activities including, to report adverse events, product defects or problems, biologic product deviations, to track products; to enable product recalls; to make repairs or replacements, or to conduct post marketing surveillance, as required.

Legal Proceedings:
We may disclose Protected Health Information in the course of any judicial or administrative proceeding, in response to an order of a court or administrative tribunal (to the extent such disclosure is expressly authorized), or in certain conditions in response to a subpoena, discovery request or other lawful process.

Law Enforcement:
We may also disclose Protected Health Information, so long as applicable legal requirements are met, for law enforcement purposes. These law enforcement purposes include (1) legal processes and otherwise required by law, (2) limited information requests for identification and location purposes, (3) information pertaining to victims of a crime, and (4) suspicion that death or injury has occurred as a result of criminal conduct.

Coroners, Funeral Directors, and Organ Donation:
We may disclose Protected Health Information to a coroner or medical examiner. For example, such disclosure may be necessary for identification purposes or to determine the cause of death. Protected health information may also be used and disclosed for cadaveric organ, eye or tissue donation purposes.

Criminal Activity:
We may disclose your Protected Health Information if we believe that the use or disclosure is necessary to prevent or lessen a serious and imminent threat to the health or safety of a person or the public. We may also disclose Protected Health Information if it is necessary for law enforcement authorities to identify or apprehend an individual.

Military Activity and National Security:
When the appropriate conditions apply, we may use or disclose Protected Health Information of individuals who are Armed Forces personnel (1) for activities deemed necessary by appropriate military command authorities; (2) for the purpose of a determination by the Department of Veterans Affairs of your eligibility for benefits, or (3) to foreign military authority if you are a member of that foreign military services. We may also disclose your Protected Health Information to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.

Workers’ Compensation:
We may disclose your Protected Health Information as authorized to comply with workers’ compensation laws and other similar legally-established programs.

Inmates:
We may use or disclose your Protected Health Information about you to a correctional facility law enforcement official if you are an inmate of the correctional facility or under the custody of the law enforcement official. This disclosure would be necessary: (a) for the correctional institution to provide you with health care, (b) to protect your health and safety or the health and safety of others, or (c) for the safety and security of the correctional institution.

Uses and Disclosures of Protected Health Information Based upon Your Written Authorization:

CTS Language Link will make other uses and disclosures of your Protected Health Information only with your written authorization, unless otherwise permitted or required by law as described below. For example, we will not use your Protected Health Information for marketing purposes or sell your Protected Health Information without your prior authorization. Additionally, if your Protected Health Information includes psychotherapy notes, we will not use or disclose this information without your prior authorization. You may revoke any such authorizations in writing at any time. If you revoke your authorization, we will no longer use or disclose your Protected Health Information for the reasons covered by your written authorization. Please understand that we cannot take back any disclosures already made with your authorization.

Other Permitted and Required Uses and Disclosures That Require Providing You the Opportunity to Agree or Object:

Unless you object, we may disclose to a member of your family, a relative, a close friend or any other person you identify, your Protected Health Information 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 health care provider determines that it is in your best interest. We may use or disclose Protected Health Information to notify or assist in notifying a family member, personal representative or any other person that is responsible for your care of your location, general condition or death. Finally, we may use or disclose your Protected Health Information to an authorized public or private entity to assist in disaster relief efforts and to assist disclosures to family or other individuals involved in your health care.

YOUR RIGHTS

You have the following rights regarding Protected Health Information we maintain about you:

Right to inspect and copy.
You have the right to inspect and obtain a copy of Protected Health Information about you for so long as we maintain the Protected Health Information. As permitted by federal or state law, we may charge you a reasonable copy fee for a copy of your records. We may deny your request to inspect and copy in certain limited circumstances. If you are denied access to your Protected Health Information, you may request that the denial be reviewed. Please contact our Privacy Officer if you have questions about access to your records.

Right to request a restriction.
You have the right to request a restriction or limitation on the Protected Health Information we disclose for the purposes of treatment, payment or health care operations. You also have the right to request a restriction or limitation on the Protected Health Information we disclose to family members or friends who may be involved in your care or for notification purposes as described in this Notice. You also have the right to request a restriction on the disclosure of your Protected Health Information to a health plan for payment purposes if you are paying out of pocket. Your request must state the specific restriction requested and to whom you want the restriction to apply. You may request a restriction by submitting a written request to the Privacy Officer listed above.

CTS Language Link is not required to agree to a restriction that you may request. If we do not agree to the requested restriction, we may not use or disclose your Protected Health Information in violation of that restriction unless it is needed to assist your health care provider in providing emergency treatment. With this in mind, please discuss any restriction you wish to request with your health care provider.

Right to Request Confidential Communications.
You have the right to request to receive confidential communications from CTS Language Link by alternative means or at an alternative location. We will accommodate reasonable requests. We will not request an explanation from you as to the basis for your request. Please make this request in writing to the Privacy Officer listed above.

Right to Amend.
You may have the right to have CTS Language Link amend your Protected Health Information. You may request an amendment of your Protected Health Information that is contained in a designated record set for so long as we maintain this information. We may deny your request for an amendment in certain cases. If we deny your request for amendment, you have the right to file a statement of disagreement with us. We may prepare a rebuttal to your statement and will provide you with a copy of any such rebuttal. Please contact our Privacy Officer if you have questions about amending your Protected Health Information.

Right to Accounting.
You have the right to receive an accounting of disclosures we have made, if any, for purposes other than treatment, payment or health care operations. You must submit a request for accounting to the Privacy Officer listed above. This right excludes disclosures we may have made to you if you authorized us to make the disclosure to family members or friends involved in your care, or for notification purposes, for national security or intelligence, to law enforcement or correctional facilities, as part of a limited data set disclosure. You have the right to receive specific information regarding these disclosures, subject to applicable exceptions, restrictions and limitations.

Right to Paper Copy of Notice.
You have the right to obtain a paper copy of this Notice from us, upon request, even if you have agreed to accept this Notice electronically. You may obtain a paper copy by visiting our website, or by contacting the Privacy Officer listed above.

Right to Notice of Breach.
We will let you know promptly if a breach occurs that may have compromised the privacy or security of your Protected Health Information.

CHANGES TO THIS NOTICE

CTS Language Link may change the terms of this Notice, at any time. The new Notice will be effective for all Protected Health Information that we maintain at that time. Upon your request, we will provide you with a copy of any revised Notice. You may request a revised Notice by visiting our website, or by contacting the Privacy Officer listed above.

COMPLAINTS

You may submit a complaint to us or to the Secretary of Health and Human Services if you believe your privacy rights have been violated by CTS Language Link. You may file a complaint with us by notifying our Privacy Officer. We will not retaliate against you for filing a complaint. You may contact the Privacy Officer listed above for further information about the complaint process.