Privacy Policy

Privacy Notice

Hazard Perry County Community Ministries cares about our clients’ privacy and strives to protect the confidentiality of clients’ Protected Personal Information (PPI). It shall be the policy of Hazard Perry County Community Ministries (HPCCM) to comply with federal, state and local laws regarding the use and disclosure of Protected Person Information (PPI).

Allowable HPCCM Uses and Disclosures of Protected Personal Information (PPI):

PPI may be used and disclosed under the following circumstances:

· To provide or coordinate services to an individual;

· For functions related to payment or reimbursement for services;

· To carry out administrative functions, including but not limited to legal, audit, personnel, oversight and management functions;

· For creating de-identified PPI

Use and disclosures required by law:

PPI may be used or disclosed when required by law to the extent that the use or disclosure complies with and is limited to the requirements of the law.

Uses and disclosures to avert a serious threat to health or safety:

PPI may be used or disclosed if, consistent with applicable law and standards of ethical conduct:

· It is believed, in good faith, that the use or disclosure is necessary to prevent or lessen a serious and imminent threat to the health or safety of an individual or the public;

· The use or disclosure is made to a person reasonably able to prevent or lessen the threat, including the target of the threat.

Uses and disclosures about victims of abuse, neglect or domestic violence:

PPI may be used and disclosed about an individual if s/he is reasonably believed to be a victim of abuse, neglect or domestic violence to a government authority (including a social service or protective services agency) authorized by law to receive reports of abuse, neglect or domestic violence under any of the following circumstances:

· Where the disclosure is required by law and the disclosure complies with and is limited to the requirements of the law;

· If the individual agrees to the disclosure; or

· To the extent that the disclosure is expressly authorized by statute or regulation; and HPCCM believes the disclosure is necessary to prevent serious harm to the individual or other potential victims; or if the individual is unable to agree because of incapacity, a law enforcement or other public official authorized to receive the report represents that the PPI for which disclosure is sought is not intended to be used against the individual and that an immediate enforcement activity that depends upon the disclosure would be materially and adversely affected by waiting until the individual is able to agree to the disclosure.

When a permitted disclosure about a victim of abuse, neglect or domestic violence is made, HPCCM must promptly inform the individual that a disclosure has been or will be made, except if:

· The HPCCM staff, in the exercise of professional judgment, believes informing the individual would place the individual at risk of serious harm; or

· The HPCCM staff would be informing a personal representative (such as a family member or friend) and the staff reasonably believes the personal representative is responsible for the abuse, neglect or other injury, and that informing the personal representative would not be in the best interests of the individual as determined by the staff in the exercise of professional judgment.

Use and disclosures for academic research purposes:

PPI may be used or disclosed for academic research conducted by an individual or institution that has a formal relationship with HPCCM if the research is conducted either:

· By an individual employed by or affiliated with HPCCM for use in a research project conducted under a written research agreement approved in writing by the Executive Director or, in the case when this person is conducting the research, the Board of Directors; or

· By an institution for use in a research project conducted under a written research agreement approved in writing by the Executive Director.

A written research agreement must:

· Establish rules and limitations for the processing and security of PPI in the course of the research;

· Provide for the return or proper disposal of all PPI at the conclusion of the research;

· Restrict additional use or disclosure of PPI, except where required by law; and

· Require that the recipient of data formally agrees to comply with all terms and conditions of the agreement. A written research agreement is not a substitute for approval of a research project by an Institutional Review Board, Privacy Board or other applicable human subjects protection institution.

Disclosures for law enforcement purposes:

PPI may be disclosed, consistent with applicable law and standards of ethical conduct, for a law enforcement purpose to a law enforcement official under any of the following circumstances:

· In response to a lawful court order, court-ordered warrant, subpoena or summons issued by a judicial officer, or a grand jury subpoena;

· If the law enforcement official makes a written request for protected personal information that: (a) is signed by a supervisory official of the law enforcement agency seeking the PPI; (b) states that the information is relevant and material to legitimate law enforcement investigation; (c) identifies the PPI sought: (d) is specific and limited in scope to the extent reasonably practicable in light of the purpose for which the information is sought; and (e) states that de-identified information could not be used to accomplish the purpose of the disclosure.

· If it is believed, in good faith, that the PPI constitutes evidence of criminal conduct that occurred on HPCCM premises;

· In response to an oral request for the purpose of identifying or locating a suspect, fugitive, material witness or missing person and the PPI disclosed consists only of name, address, date of birth, place of birth, Social Security Number, and distinguishing physical characteristics; or

· If the official is an authorized federal official seeking PPI for the provision of protective services to the President or other persons authorized by 19 U.S.C 3056, or to foreign heads of state or other persons authorized by 22 U.S.C. 2709 (a)(3), or for the conduct of investigations authorized by 18 U.S.C. 871 and 879 (threats against the President and others); and the information requested is specific and limited in scope to the extent reasonably practicable in light of the purpose for which the information is sought.

Collection limitation:

HPCCM staff may collect PPI only when appropriate to the purposes for which the information is obtained or when required by law. HPCCM staff must collect PPI by lawful and fair means and, where appropriate, with the knowledge or consent of the individual.

Purpose specification and use limitation:

· PPI may be used or disclosed only if the use or disclosure is allowed by the standards described in this privacy notice. Consent may be inferred for all uses and disclosures specified in this notice and for uses and disclosures determined by HPCCM to be compatible with those specified in the notice.

· Except for first party access to information and any required disclosures for oversight of program compliance, all uses and disclosures are permissive and not mandatory. Uses and disclosures not specified in the privacy notice can be made only with the consent of the individual or when required by law.

· HPCCM must obtain written consent from the individual to use or disclose personal information with a third party.

· HPCCM will agree to additional restrictions on use or disclosure of an individual’s PPI at the request of the individual if the request is reasonable and noted on the consent. HPCCM is bound by the agreement, except if inconsistent with legal requirements.

· Aggregate data may be released as long as all identifiers are removed.

Openness:

· HPCCM staff must provide a copy of this privacy notice to any individual upon request. A current version of the privacy notice is published on the web at www.hpccm.org.

· This privacy notice may be amended. All amendments to the privacy notice must be consistent with the requirements of these privacy standards.

Access and correction:

· In general, HPCCM staff must allow an individual to inspect and to have a copy of any PPI about the individual. The staff must offer to explain any information that the individual may not understand.

· Any request by an individual for correction of inaccurate or incomplete PPI pertaining to the individual must be considered. Although HPCCM is not required to remove any information but may, in the alternative, mark information as inaccurate or incomplete and may supplement it with additional information.

· HPCCM reserves the ability to rely on the following reasons for denying an individual inspection or copying of the individual’s PPI:

a. Information about another individual (other than a health care or homeless provider);

b. Information, the disclosure of which would be reasonably likely to endanger the life or physical safety of any individual.

· HPCCM can reject repeated or harassing requests for access or correction. If an individual’s request for access or correction is denied, s/he must receive a written explanation for the denial to the individual. Documentation of the request and the reason for the denial will be included as part of the protected personal information about the individual.

Accountability:

Questions or complaints about this privacy notice should be sent in writing to HPCCM’s Administrative Office:

151 Miss Edna Lane

Hazard, KY 41701

If you feel your privacy rights have been violated, you should contact:

Adrienne Bush

HPCCM

151 Miss Edna Lane

Hazard, KY 41701

606-436-2662