Social Thinking Privacy Policy

September 2003

In light of new laws requesting businesses to clarify privacy policies, the Center for Social Thinking (CST) has drafted the below policy.

This notice describes how information about our patients/clients may be used and disclosed and how they can obtain access to this information.

Terms:

Any medical information, which could in any way identify an individual client, is considered Protected Health Information (PHI) . PHI will be used and disclosed only as needed for the CST to perform Treatment * , Acquire Payment and Health Care Operations (TPO). Any other disclosure will require the written authorization of the client. In general, use or disclosure of PHI for purposes other than treatment, or a disclosure requested by the client, is limited to the Minimum Necessary to accomplish the intended purpose.

*Treatment: CST philosophy includes a ten minute “group” parent meeting as a part of each group session to discuss what happened during the session. During this time it is understood that the therapist will speak openly to all the parents about all the students in the group with regard to their participation and things they need to work on at home. The therapist should make every attempt to have these discussions in a private setting.

Access:

The following people will have access to PHI:

• The client when 18 years old or older.

• Parents or legal guardians of a minor.

• Parents of an adult client with written permission of client.

• Any person to whom the adult client has authorized, in writing, the release of

Information.

• CST staff and contractors who are involved in providing care

or administrative assistance.

• The client's health insurance company, for payment purposes.

• Public Health Services and regulatory officials, when required by law.

• An appropriate authority when a determination is made that the client may pose

physical threat to themselves or others.

• Courts, when the request is accompanied by a duly executed subpoena.

Minimum Necessary:

The CST Privacy Contact will review requests for disclosure of PHI for all purposes to assure that they meet the minimum necessary requirement.

Patient/Client Rights:

• Parent/Guardian of clients or adult clients have a right to see and obtain a copy of their PHI.

• Clients have a right to request limitations to the routine use of PHI for

TPO.

• Clients have a right to request changes in their PHI.

• Clients have the right to see a list of all people to whom PHI has been disclosed. In order to meet this requirement, the must keep a disclosure log. The log must record all disclosures, both written and verbal.

Security:

Privacy measures are designed to protect the confidentiality of all PHI:

• All staff will receive instruction about and be familiar with the CST

• All Staff will exert due diligence to avoid being overheard when discussing PHI.

• All records will be maintained in a secure environment.

Information with regard to grievances:

Clients who have complaints or concerns with regard to therapeutic management, please first contact your child's personal therapist to discuss your concern. If you feel that she has not been able to adequately address your needs, then please contact Stephanie Madrigal, Clinical Services Manager. If you still have unanswered concerns, please contact Michelle Winner, Director of the CST. For all other questions, concerns or complaints please address them to the CST Administrative Assistant, Cathy Hart. If Cathy cannot handle them directly, she will bring them to the attention of the relevant employee at the CST. If you still feel that your complaint has not been resolved to your satisfaction, you can address complaints to the Secretary of the United States Department of Health and Human Services. The Center for Social Thinking will not retaliate against any individual for filing a complaint.

Administration:

• The CST Administrative Assistant serves as the Privacy Contact.

• A designee of the CST serves as the Center Security Officer.

Non-Medical Information:

We request non-medical information from you (including name, address, telephone number, email address and fax number) when you:

• Place an order for a book, video or rubber chicken

• Register for a conference

• Subscribe to our Email Newsletter

We maintain the data that you provide us, along with a record of your purchases, in a secure database. We do not share this information with any other companies. We do not make our mailing list available to any other companies or organizations. On rare occasions, we may disclose specific information upon governmental request, in response to a court order, or when required to do so by law.

How We Use Email

When you provide us your email address, we may send you emails announcing our conferences in your area. It is our intent to send you our Email Newsletter only if you have agreed to receive it. If you do not wish to receive these emails, kindly email us at information@socialthinking.com and let us know.

Additional Resources on Health Information Privacy

Health Privacy Project

Georgetown University

www.healthprivacy.org

Office for Civil Rights

U.S. Department of Health & Human Services