PHN Privacy Policies

HIPAA Privacy Policy

Please Review this Carefully

This Notice of Privacy Practices is NOT authorization. This Notice of Privacy Practices describes how we, Primary Health Network, our Business Associates and their subcontractors, may use and disclose your protected health information (PHI) to carry out treatment, payment or health care operations (TPO) and for other purposes permitted or required by law. It also describes your rights to access and control your protected health information. “Protected Health Information” is information about you, including demographic information that may identify you and that relates to your past, present or future physical or mental health conditions and related health care services.

Our Legal Duty

Primary Health Network is required by applicable federal and state law to maintain the privacy of your health information. We understand your medical information is personal and we are committed to protecting it. We create a record of care and services that you receive to ensure we are providing quality care and are complying with legal requirements. This Notice applies to all your health information that we maintain, whether created by our staff or others, and tells you about the ways in which we may use or disclose you protected health information.

We reserve the right to change our privacy practices and the terms of this Notice at any time, provided such changes are permitted by applicable law. We reserve the right to make the changes in our privacy practices and the new terms of our Notice effective for all health information we maintain, including health information we created or received before we made changes. Primary Health Network Notice of Privacy Practices are available upon request and on the Primary Health Network website.

How We May Use & Disclose Your Protected Health Information

Primary Health Network may use and disclose your health records for treatment, payment, and health care operations, and as required by law. Other disclosures will be made only with your authorization. Below are examples of how we use or disclose your protected health information.

• Treatment means providing, coordinating of managed care and related services by one or more health care providers. To promote quality care, Primary Health Network operates an electronic health record called the “EHR”. This is an electronic system that keeps medical information about you. If you see multiple Primary Health Network providers, your health information (including Medical, Behavioral Health, and Dental) will be shared between providers and authorized staff to achieve continuity of care. The privacy obligations of your health information rights set forth in this Notice also apply to information stored in the EHR and on paper. We participate in one or more Health Information Exchanges. Your healthcare providers can use this electronic network to securely provide access to your health records for a better picture of your health needs. We and other healthcare providers, may allow access to your health information through the Health Information Exchange for treatment, payment or other healthcare operations. This is a voluntary agreement. You may opt-out at any time by notifying the front office staff.
• Research We may use your PHI for research purposes or disclose your PHI to researchers when the research has been approved by an institutional review board that has reviewed the research proposal and established protocols to ensure the privacy of your health information.
• Payment means such activities as planning reimbursement for services, confirming coverage, billing or collection activities, and utilization review. An example of this would be sending a bill for your visit to your insurance company for payment.
• Health Care Operations include the business aspects of running our practice, such as conducting quality assessment and improvement activities, auditing functions, or management analysis, and customer service. An example would be internal quality assessment review.
• Public Health Activities The Privacy Rule permits Public Health Information (PHI) to be shared for specified public health purposes such as preventing or controlling disease, injury or disability and when required by law.
• Government Activities PHI may be released to government agencies for the purpose of enforcement of the Privacy Rule by the Department of Health and Human Services and the Office of Civil Rights to investigate a complaint and ensure compliance.
• Law Enforcement Purposes PHI may be released to the police or other law enforcement officials as required or permitted by law, or in compliance with a court order or subpoena.
• Fundraising We may use health information to contact you about fundraising efforts for the Primary Health Network; you may elect to opt out of receiving fundraising communications.

Uses & Disclosures that Require your Authorization

Other Permitted and Required Uses and Disclosures will be made only with your consent, authorization or opportunity to object unless required by law. Without your authorization, we are expressly prohibited to use or disclose your protected health information for marketing purposes. We may not sell your protected health information without your authorization. We may not use or disclose most psychotherapy notes contained in your protected health information. We will not use or disclose any of your protected health information that contains genetic information that will be used for underwriting purposes.

You may revoke the authorization, at any time, in writing, except to the extent that Primary Health Network has taken action in reliance on the use or disclosure indicated in the authorization.

Your Rights

The following are statements of rights with respect to your protected health information.

You have the right to inspect and copy your protected health information (reasonable fees may apply) Pursuant to your written request, you have the right to inspect or copy your protected health information whether in paper or electronic format, with limited exceptions. Primary Health Network may use readable electronic form or format to provide you access.

You have the right to request a restriction of your protected health information. This means you may ask Primary Health Network not to use or disclose any part of your protected health information for the purposes of treatment, payment or healthcare operations. You may also request that any part of your protected health information not be disclosed to family members or friends who may be involved in your care for notification purposes described in this Notice of Privacy Practices. Your written request must state specific restriction requested and to whom you want the restriction to apply. Primary Health Network is not required to agree to your requested restrictions except if you request that Primary Health Network not disclose protected health information to your health plan with respect to healthcare for which you have paid in full out of pocket.

You have the right to receive an accounting of certain disclosures. You have the right to receive an accounting of disclosures, paper or electronic, except for disclosures: pursuant to an authorization, for purposes of treatment, payment, healthcare operations; required by law that occurred prior to April 14, 2003, or six years prior to the date of your request.

You have the right to request an amendment to your protected health information. Your request must be in writing and it must explain why the information should be amended. Primary Health Network may deny your request for amendment, you have the right to file a statement of disagreement with us and we may prepare a rebuttal to your statement and will provide you with a copy of any such rebuttal.

You have the right to receive a notice of a breach. Primary Health Network will notify you of your unsecured protected health information has been breached.

You have the right to obtain a paper or electronic copy of this notice. Primary Health Network reserves the right to change the terms of this notice. We will also make available copies of our new notice if you wish to obtain one.

Complaints

You may complain to Primary Health Network or the US Department of Health and Human Services, Office of Civil Rights if you believe your privacy rights have been violated by us. You may file a complaint with Primary Health Network by notifying Customer Service of your complaint. We will not retaliate against you for filing a complaint.

Primary Health Network Customer Service 1-866-276-7018

Department of Health and Human Services 1-877-696-6775

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Website Privacy Policy

Last updated: January 24, 2024

This Privacy Policy applies to information collected by Primary Health Network and PHN Charitable Foundation (collectively, “we,” “our,” or “us”) in connection with your access or use of our website (primary-health.net) and our mobile application (collectively, our “online services”).  Our online services are designed to provide the community with information about our services, locations, and hours, as well as details about our organization and our partners.  Our online services are part of our outreach strategy and are designed to serve as resource tools.

This Privacy Policy describes the information we collect, how we use it, and how we protect it. When used in this policy, the term “personal information” means information about an individual that identifies or describes a natural person.  Any personal information that meets the definition of protected health information (“PHI”) under the Health Insurance Portability and Accountability Act (“HIPAA”) is governed by and will be used and disclosed solely as described in Primary Health Network’s Notice of Privacy Practices, not by this Privacy Policy.

By accessing or using our online services, you consent to the use of cookies and tracking technologies as described in this Privacy Policy.  Please read this policy carefully.

What Information Do We Collect About You?

You may access and use our online services without providing your personal information.  There are several ways we may collect information about you:

A. Information You Provide to Us

You may access and use our online services without providing your personal information.  Our online services do not request, require or collect your personal information or your protected health information.

Our online services, specifically our website, contain links and integrations to third-party sites and services.  The third-party sites and services may request, require, or collect your personal information or your protected health information.  Any information collected by the third-party sites and services will be subject to their privacy policies which are available when you click on their links on our website.  We have also included their privacy policies below:

Name of Third Party	Type of Service Provided	Third-Party Privacy Policy
Intelichart	Appointment Scheduling	Intelichart Privacy Policy
Irecruit	Recruitment Portal	Irecuit Privacy Policy
Phreesia	Appointment Scheduling	Phreesia Privacy Policy

B. Information We Collect Automatically

We automatically collect certain device and use information when you access or use our online services, including:

• Device information: Our online services collect information about the devices used to access or use our website, including the hardware model, operating system and version, unique device identifiers such as Internet Protocol (“IP”) addresses, mobile network information, browser type and language and referring URLs.  With your device settings permitting, our online services may also collect information about the precise location of your device.
• Use information: We collect information about your use of our online services, including the date and time you visit the website; use or click through to any of the links; the information, content, or advertisements you view, hover over, or click on; the amount of time you spend viewing or using the website and mobile application; the number of times you return; other click-stream or site usage data; and emails or social media posts that you open, forward or click-through to our website and mobile application.

To collect such information, our online services use tracking technologies, including:

• Cookies (or browser cookies): A cookie is a small file or piece of data sent from a website and is stored on the hard drive of your computer or mobile device.  You may refuse to accept browser cookies by activating the appropriate setting on your browser, and similar capabilities may be available on your mobile device in the preferences for your operating system or browser.  Please note, however, that if you select this setting, you may be unable to access or use certain parts of our website.  Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website or use our app.

• Web beacons or tracking pixels: A tiny graphic image placed on a webpage that allows the website owner or a third party to collect information regarding the use of the webpage that contains the web beacon or pixel.

We use tracking technology vendors to help collect and analyze the information collected.  The companies may also combine information they collect from your interaction with our website with information they collect from other sources.  We may not have access to information these companies collect using cookies or other tracking technologies.  We use tracking technology vendors, including:

• Google Analytics: We use Google Analytics, a web analytics service provided by Alphabet Inc. (“Google”), to collect and analyze certain information relating to your use of our online services.  You can find out more about how Google uses data by visiting “How Google uses data when you use our partners’ sites or apps” (located at www.google.com/policies/privacy/partners/).  For more information regarding Google Analytics, please visit Google’s website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.
• LinkedIn: We use LinkedIn advertising services provided by LinkedIn to advertise open positions within our organization and track what users do after they see or click on our advertisement. This is to better provide relevant content and advertisements to our target audiences.  For more information regarding LinkedIn’s use of cookies, please visit their Cookie Policy and LinkedIn Cookie Table.
• Facebook Pixel: We use Facebook Pixel, a web analytics and advertising service provided by Meta Inc. (“Facebook”), to track what users do after they see or click on a Facebook advertisement for Primary Health Network and PHN Charitable Foundation, to track users who access our website or advertisements from different devices, and to better provide advertisements to our target audiences.  The data from Facebook Pixel is also saved and processed by Facebook.  Under Facebook’s Data Policy, it can connect this data with your Facebook or Instagram account and use it for its own and others’ advertising purposes.  If you would like to withdraw your consent for the use of your data with Facebook Pixel, please visit: https://www.facebook.com/settings/?tab=ads.

How Do We Use Information About You?

We may use the information collected to:

• Improve Our Online Services: We may use your information to improve our website and mobile application, to help diagnose problems with our online services and servers; analyze trends; track users’ web page, and mobile application movements/activities.
• Personalize or Contextualize Our Services: We may use your information to help personalize and contextualize our website and provide relevant content based on how you interact with our website.
• Business Operations: We may use your information to understand your use of our online services in order to consider improving them, including to provide, change, market, or optimize our services to perform analytics and to create new services and products.  We also may use your information to determine whether applicable policies and terms are being violated.
• Security and Auditing: We may use your information to detect security incidents, protect against fraud or other malicious activity, and identify and repair errors that may arise.
• Complying with Laws: We may use your information to comply with applicable laws, including as required by judicial or administrative proceedings.

We may also use your information for other purposes as disclosed at the time you provide your information or otherwise with your authorization.

How Do We Share Your Information with Others?

We may share your information with companies that we work with or provide services to us in the ways described below.

A. Affiliates and Subsidiaries

We may share information with our subsidiaries and affiliated companies for business and operational purposes.

B. Service Providers and Third Parties

We may share your information with service providers and third parties to perform services on our behalf, including:

• Data analytic, data connectivity and customer data providers and platforms
• Customer engagement or relationship management platforms
• Cloud computing providers
• Software development tools
• Data providers and analytics software
• Text delivery and analytics platform

C. For Corporate Transactions

We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control.  If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity.  In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties.  Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use information provided through the Services in a manner that is consistent with this Privacy Policy.

D. For Legal Obligations/Safety

We may be required by law to comply with a valid legal process, such as a subpoena, court order, or search warrant, or where there is a lawful request, to disclose your information without your consent or notice.  We may also be required to disclose your information to a third party or governmental entity in response to a court order.  We may disclose your information to protect the security of our website, servers, network systems, and databases.

E. To Enforce Legal Rights

We may also share your information to protect our patients, employees, or property; in emergency situations; to investigate, prevent, or take other action regarding suspected illegal activity, fraud, or other wrongdoing; and to enforce our rights under our terms of service and policies, in court or elsewhere.

What Choices Do You Have?

A. Cookies and Do Not Track

To control what cookies are collected when you are on our website, please click on the “Cookie Preferences” link at the bottom of the applicable webpage.

You may adjust your device or Internet browser settings to limit certain tracking or to decline cookies, but by doing so, the performance of your device or browser may prevent you from being automatically recognized upon revisiting and you may not be able to use certain features of the website.  Please refer to your device’s settings or your Internet browser’s “Help” section for more information on how to delete and/or disable your device or browser from receiving cookies or controlling your tracking preferences.

B. Your Privacy Rights

• We do not sell your personal information.

• We do not conduct profiling in the furtherance of decisions that produce legal or similarly significant effects, however, Primary Health Network and PHN Charitable Foundation does not conduct such profiling.

European Union Visitors

Please do not use our website if you are not a resident of the United States.  Our website is intended for use only by residents of the United States.  Use by visitors from the European Economic Area (or EEA) or the United Kingdom is prohibited.

Children’s Privacy

We are committed to protecting the privacy of children.  Our website is intended for adults and minors age 13 and over.  It is not intended for or designed to attract persons under the age of 13. We do not permit registration by, nor do we knowingly collect personal information from individuals under the age of 13.  

Third-Party Services and Websites

When you access or engage with a third-party service, application, or website, even when doing so through our website, equipment or applications, you are entering that service, application, or website and governed by its policies.  Many third parties have their own privacy policies that differ from ours.  This Privacy Policy only covers our website and does not cover any other third parties.  We may collect usage information related to those third-party products, services, applications, or websites if they are accessed through our websites or applications.

How Do We Protect Your Information?

We take information security seriously.  We use commercially reasonable efforts to prevent unauthorized third-party access to your personal information.  However, we cannot guarantee that these practices will prevent every unauthorized attempt to access, use, or disclosure of your personal information.  Please note that we cannot ensure or warrant the security of any information you transmit to us over the internet or other electronic means (such as text messages).  You use our website at your own risk, and we accept no liability for unintentional disclosure.

What About Changes to This Notice?

We may modify this Privacy Policy at any time.  When we do so, we will post the revised Privacy Policy on our website.  Please check the revision date at the top of this page to determine if the policy has been modified since you last reviewed it.  By continuing to use our website after any changes to this policy, you acknowledge and agree to the revised policy.

Who Can You Contact with Questions or Concerns?

Please address comments or questions to us about this Privacy Policy via phone by calling
1-866-276-7018.  We are available Monday-Friday (excluding holidays), from 8:30 AM to 5:00 PM (EST).  You may also contact in writing at:

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Social Media Policy

BY ENGAGING WITH PRIMARY HEALTH NETWORK (PHN) ON SOCIAL MEDIA PLATFORMS, YOU AGREE TO THE FOLLOWING TERMS. Primary Health Network (“PHN”) maintains publicly accessible pages on various social media platforms for the purpose of disseminating information, facilitating discussions, and receiving feedback. These social media platforms may include but are not limited to Meta (Facebook and Instagram), X (Formally known as Twitter), LinkedIn, and other user-generated content sites (“Social Media Platforms”). By accessing, viewing, or posting any content related directly or indirectly to PHN on any Social Media Platform, you accept, without limitation or qualification, the following terms of use. If you do not agree to these terms, you may not view or post any content on any Social Media Platform associated with PHN. PHN also respects, observes, and adheres to the posting and terms of use policies governed by each Social Media Platform. Your engagement with Social Media Platforms governed by this policy constitutes acceptance of these terms.

Employee Compliance

If you are a PHN employee, you must adhere to the PHN Social Media Policy posted on the PHN internal network.

Privacy and Health Information

You are prohibited from posting any personal health information, including patient images, on any Social Media Platform associated with PHN. Furthermore, you may not provide medical advice or commentary. Referrals to physicians who are not employed by PHN are also prohibited.

Code of Conduct

By engaging with any Social Media Platform associated with PHN, you agree not to:

• Violate any local, state, federal, or international laws and regulations.
• Transmit any material that is unlawful, disruptive, threatening, abusive, harassing, defamatory, obscene, libelous, or otherwise objectionable.
• Impersonate any person or entity or falsely state or misrepresent your affiliation.
• Infringe upon any patent, trademark, trade secret, copyright, or other proprietary rights.
• Transmit unsolicited or unauthorized advertising, promotional materials, spam, or any other form of solicitation.
• Transmit any material containing software viruses, worms, or other harmful computer code.
• Harass others or collect personal data about third parties without their consent.
• Share confidential information, including pricing information, of any party.

PHN’s Rights

PHN reserves the right to monitor, prohibit, restrict, block, suspend, terminate, delete, or discontinue access to any Social Media Platform associated with PHN, at any time and for any reason, without notice and in its sole discretion. PHN may also remove, delete, block, filter, or restrict any materials at its discretion. Users understand and agree that PHN may disclose communications and activities in response to lawful requests by governmental authorities or for the protection of PHN’s rights.

Security and Privacy

Users acknowledge and assume responsibility for the security, privacy, and confidentiality risks inherent in posting content online. PHN does not warrant any safeguard against interceptions or compromises to user information. Users should exercise caution when sharing detailed or private information.

Commercial Endorsements and Political Activity

Users may not provide content containing product endorsements or engage in political lobbying, solicitations, or contributions on any Social Media Platform associated with PHN.

Policy Updates

This policy may be updated at any time without notice, and each user’s continued engagement with Social Media Platforms associated with PHN constitutes acceptance of the updated policy.