Privacy Policy

CLINICA LAS AMERICAS DE GUAYNABO (SALUS)

Summary of Privacy Practices

Our pledge is to limit to the minimum necessary the information we collect in order to provide health care services. As part of our administrative functions, we may collect your personal, financial or health information from sources such as:

• applications and other documents you have provided to obtain a product or medical service;
• transactions you make with us;
• consumer credit reporting agencies;
• other healthcare providers;
• Government health programs

Uses and Disclosures of Information

We may use and disclose your personal information to our business associates, who provide services on our behalf and contribute in the administration or coordination of your services. We only share the minimum necessary information and require from each of our business associates to sign a written agreement in which they provide satisfactory assurances of compliance with the security and privacy of your health information. If the business associate goes out of business, we will maintain your information secure to provide the services you need.

As part of our administrative functions, with your consent we may use or disclose your information for treatment, payment and healthcare operations, and when authorized or permitted by law. For example:

Treatment: To a physician or other health care provider who provides medical services to you.

Payment: To pay your medical claims, to determine your eligibility for benefits, to coordinate your benefits with other payers, or to collect premiums, and the like.

Health Care Operations: For audits, legal services, including fraud and abuse, business planning, general administration, and patient safety activities, credentialing, disease management, training of medical or pharmacy students.

We may disclose your health information to another health plan or to a health care provider subject to federal or local privacy protection laws, as long as the plan or provider has or had a relationship with you.

Affiliated Covered Entities. These companies are subject to the same statutes that require protection for your protected health information.

Disaster relief or emergency situations

Government Sponsored Benefits Programs

Public Health and Safety Activities: We may use and disclose your medical information when required or permitted by law for the following activities:

• public health, including to report disease and vital statistics;
• to report child and/or adult abuse or domestic violence;
• healthcare oversight, fraud prevention and compliance;
• in response to court and administrative orders;
• to law enforcement officials or matters of national security;
• scientific research
• as authorized by state worker’s compensation laws; and
• as otherwise required by applicable laws and regulations

Health-Related Products and Services: We may use your medical information to inform you about health-related products, benefits and services we provide or treatment alternatives that may be of interest to you. We will call or send you reminders of your medical appointments or the preventive services that you need according to your age or health condition.

With Your Authorization: You may give us a written authorization to disclose your medical information to anyone for any purpose. Activities such as marketing of non-health related products or services or the sale of health information must be authorized by you. In these cases your health care won’t be affected if you denied the authorization.

The authorization must be signed and dated, mention the entity authorized to provide/receive the information, a brief description of the data to be disclosed and the expiration date, which will not exceed 2 years from the date of signage.

The disclosed information pursuant to your authorization may be redisclosed by the recipient of the information and may not be protected by applicable privacy laws.

You may revoke the authorization in writing at any time. Your revocation will not affect any use or disclosure permitted by your authorization while it was in effect. We will keep copies of the authorizations and revocations executed by you.

Family and Friends Involved in Your Care or Payment for Care: To a family member or friend you involve in your health care or payment for your health care, unless you request a restriction. We will disclose only the medical information that is relevant to the person’s involvement.

Before we make such a disclosure, we will provide you with an opportunity to object. If you are not present or disabled or in case of emergency we will use our professional judgment to determine whether disclosing your medical information is in your best interest.

Terminated accounts: We will not share the data of persons who are no longer our customers or who do not maintain a service relationship with us, except as required or permitted by law.

Security safeguards: We have implemented physical, technical and administrative safeguards to limit access to your personal information. Our employees and business associates are trained and know their duty to protect and maintain the privacy of your medical information, and are committed to comply with the highest security and privacy standards to handle your information in a responsible manner.

Individual Rights

Access: You have the right to examine and receive a copy of your protected health information on enrollment and claims within the limits and exceptions provided by law. You must make a written request. Upon receipt of your request, we will have five (5) business days to do any of the following activities:

• provide the requested information or allow you to examine your information during working hours
• inform you that we do not have the requested information, in which case, we will orient you where to find it if we know the source
• deny the request, partially or in its entirety, because the information originates from a confidential source or was compiled in anticipation of a legal proceeding, investigations by law enforcement agencies or the anti-fraud unit or quality assurance programs which disclosures are prohibited by law. We will notify you in writing the reasons for the denial, except in the event there’s an ongoing investigation or in anticipation of a legal proceeding.

The first report will be free of charge, but we may charge you reasonable, cost-based fees for subsequent reports. If you request the report in a special format, you may have to pay an additional charge.

Disclosure Accounting: You have the right to a list of instances after April 14, 2003, in which we disclose your protected health information for purposes other than treatment, payment, health care operations, as authorized by you, and for certain other activities.

The report will provide the name of the entity to which we disclosed your information, the date and purpose of the disclosure and a brief description of the data disclosed. If you request this accounting more than once in a 12-month period, we may charge you a reasonable, cost-based fee for responding to your additional requests. The report only covers the last six (6) years.

Amendment. You have the right to request that we amend your health information. Your request must be in writing, and it must explain and justify the amendment requested. Within 60 days we will execute the amendment. If we need additional time, we will request you in writing an additional period of 30 days prior to the termination of the original period.

If we deny your request, we will provide you a written explanation. You have the right to request that we include your statement of disagreement with the determination taken by us in future disclosures of the disputed information. If we accept your request, we will make your amendment part of your record and use reasonable efforts to inform our business associates and others who we know may have and rely on the unamended information.

Restriction: You have the right to request that we restrict our use or disclosure of your health information, if such disclosure may put your life at risk, as in a case of domestic violence. We are not required to agree to your request. If we do agree, we will abide by our agreement, except in a medical emergency or as required or authorized by law. Any agreement we may make to a request for restriction must be in writing signed by an authorized officer.

Confidential Communication: You have the right to request that we communicate with you about your medical information in confidence by alternative means or to alternative locations if your life may be at risk. You must make your request in writing, and your request must represent that the information could endanger you if it is not communicated in confidence as you request.

We will accommodate your request if it is reasonable, specifies the alternative means or location for confidential communication, and continues to permit us to collect premiums and pay claims under your health plan, including issuance of explanations of benefits to the subscriber.

Business closure. In the event of business closure, we will communicate with you to let you know how to obtain your claims history and any other information.

Notice of security breaches in which your health information may be at risk: You are entitled to be notified by any means if the security breach is the result of not having your information secured by technologies or methodologies approved by the Department of Health and Human Services.

Electronic Notice: If you receive this notice on our web site (www.saluspr.com) or by e-mail, you are entitled to receive this notice in written form.

Questions and Complaints

If you want more information about our privacy practices or have questions or concerns, please contact us. All the forms to exercise your rights are available at: www.ssspr.com.

If you are concerned that we or any of our business associates may have violated your privacy rights, or you disagree with a decision we made about access to your health information, in response to a request you made to amend, restrict the use or disclosure of, or communicate in confidence about your health information, you may complain to us using the contact information at the end of this notice.

You also may submit a written complaint to the Office for Civil Rights of the United States Department of Health and Human Services (DHHS) at: 200 Independence Avenue, S.W. Room 509F HHH Bldg. Washington, D.C. 20201.; telephone (800) 368-1019 Fax: (202) 619-3818 TDD: (800) 537- 7697. Email: OCRComplaint@hhs.gov

We support your right to the privacy of your health information. We will not retaliate in any way if you choose to file a complaint with us or with the DHHS.

Contact Office: COMPLIANCE AND PRIVACY OFFICE SALUS

Office: Departamento de Cumplimiento
Attention: Privacy Officer
Telephone: (787) 789-1996
Fax: (787) 993-3260
E-mail: lpadilla@ssspr.com
Address: P. O. Box 11320 San Juan, PR 00922