Privacy Policy

The following privacy policy has been compiled to inform our patients how we collect, use and protect your personally identifiable information (PII) and personal health information (PHI) in accordance with the Health Insurance Portability & Accountability Act of 1996 (HIPPA) and California Online Privacy Protection Act (CalOPPA).

SPINE & JOINT
(212) 810-9525

Website

When registering on our site or sending an inquiry to our team, as appropriate, you may be asked to enter your name, email address, mailing address, phone number or other details to help you with your experience.  We will use your information to follow-up with you regarding your request.

We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when its release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property or safety.  We do not include or offer third-party products or services on our website.

We have implemented the following:

  • Google Display Network Impression Reporting
  • Demographics and Interests Reporting
  • We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.

Opting out:

  • Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network.
  • Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’ors reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA, we agree to the following:

  • Users can visit our site anonymously.
  • Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website.
  • Our Privacy Policy link includes the word privacy and can be easily be found on the page specified above.

You will be notified of any Privacy Policy changes:

  • On our Privacy Policy Page

You can change your personal information:

  • By emailing us or by calling us

How does our site handle Do Not Track signals?

We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third-party behavioral tracking?

It’s also important to note that we do not allow third-party behavioral tracking

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

We do not specifically market to children under the age of 13 years old.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

We will notify the users via in-site notification within 7 business days.

We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

  • Send information, respond to inquiries, and/or other requests or questions

To be in accordance with CANSPAM, we agree to the following:

  • Not use false or misleading subjects or email addresses.
  • Identify the message as an advertisement in some reasonable way.
  • Include the physical address of our business or site headquarters.
  • Monitor third-party email marketing services for compliance, if one is used.
  • Honor opt-out/unsubscribe requests quickly.
  • Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can contact us directly.

MEDICAL PRACTICE:

Minimum Necessary Use and Disclosure of Protected Health Information

Spine & Joint will ensure that for all routine and recurring uses and disclosures of PHI (except for uses or disclosures made for treatment purposes; to or as authorized by the patient; or as required by law for HIPAA compliance) such uses and disclosures of PHI must be limited to the minimum amount of information needed to accomplish the purpose of disclosure.

Verification of Identity

Spine & Joint will ensure that the identity of all persons who request access to protected health information be verified before such access is granted.

Safeguards

Appropriate safeguards will be in place at Spine & Joint to reasonably protect health information from any intentional or unintentional use or disclosure that is in violation of the HIPAA Privacy Rule. These safeguards include physical protection of premises and PHI, technical protection of PHI maintained electronically and administrative protection of PHI.

Training and Awareness

Spine & Joint will ensure that all employees are trained on the policies and procedures governing protected health information and how Spine & Joint complies with the HIPAA Privacy.  New employees will receive training within a reasonable time of employment. 

Complaints

Spine & Joint will investigate and resolve all complaints relating to the protection of health in a timely fashion. All complaints will be directed to Practice Manager, who is duly authorized to investigate complaints and implement resolutions.

Prohibited Activities-No Retaliation or Intimidation

No employee or contractor of Spine & Joint will engage in any intimidating or retaliatory acts against persons who file complaints or otherwise exercise their rights under HIPAA regulations. No employee or contractor may condition treatment or payment on the provision of an authorization to disclose protected health information.

Cooperation with Privacy Oversight Authorities

Spine & Joint will ensure that oversight agencies such as the Office for Civil Rights of the Department of Health and Human Services will receive cooperation in any investigation relative to protection of health information within Spine & Joint.

Investigation and Enforcement

In addition to cooperation with Privacy Oversight Authorities, Spine & Joint will enact procedures to ensure that investigations are supported internally and staff of Spine & Joint will not be retaliated against for cooperation with any authority. It is our policy to attempt to resolve all investigations and avoid any penalty phase if at all possible.

COMMUNICATION BY E-MAIL or TEXT

Security Risks

Most standard email providers such as Gmail, Yahoo, Hotmail, etc. and most cellular providers do not provide a secured or encrypted means of communication. As a result, there is risk that any protected health information contained in an email or text message may be disclosed to, or intercepted by, unauthorized third parties. Additionally, email and text messages accessible through personal computers, laptops, or phones have inherent privacy risks especially when the email or cellular account is provided by an employer, when the account is not password protected, or the account is shared. Use of more secure communications, such as phone, fax or mail is preferred and always an available alternative.

Responsibility

When consenting to the use of email or text through such unsecured or unencrypted systems, you are accepting responsibility for any unauthorized access or disclosure to protected health information contained within the message. The Practice will not be responsible for unauthorized access of protected health information while in transmission and will not be responsible for safeguarding information once it is delivered. The Practice will take steps to ensure that any email or text message with protected health information is protected prior to being sent to the requested address and will use the minimum necessary amount of protected health information when communicating with you.

Additional Information

It is important to understand that emails and text messages will not be used to replace or facilitate communications between you and your physician and will not be considered private communications. There is no guarantee that the Practice will be actively monitoring emails and text messages, so responses and replies sent to or received by you or the Practice may be hours or days apart. Email and text messages may be inadvertently missed or errors in transmissions may occur. The Practice will not be responsible for any issues caused by delays in communications. If you have an immediate need or an emergency situation, you must contact the Practice by telephone or dial 9-1-1 if applicable. Practice staff will be utilized to monitor the inbox in order to properly direct or respond to communications received. Therefore, any information considered sensitive should not be included in your communications. At the Practice’s discretion, any email or text message received or sent may become part of your medical record. By completing and signing this form, or by initiating contact with the Practice via email, text, or web form, I am accepting that Vein Treatment Clinic​ may communicate with me via email or text message via the provided contact information and acknowledge the inherent limitations therein.