Effective: July 2015
Our policy regarding the collection and use of your information via the WriteTouchHealth website portal ("Portal") is set forth below. The Portal is committed to disclosing its privacy and data security policies.
IF YOU ARE A PATIENT, OR THE LEGAL REPRESENTATIVE OF A PATIENT, AND YOU CHOOSE TO REGISTER TO ACCESS THE PRIVATE PORTAL, YOU WILL BE CONFIRMING THAT YOU HAVE INITIATED THE WRITETOUCHHEALTH PATIENT PORTAL ACTIVATION REQUEST IN CONJUNCTION WITH YOUR PHYSICIAN’S OFFICE AND YOU WILL BE REQUIRED TO VIEW AND AGREE TO THE WRITETOUCHHEALTH PORTAL PATIENT REGISTRATION AGREEMENT IN ORDER TO FINALIZE YOUR REGISTRATION.
WRITETOUCHHEALTH MAY REVISE THIS POLICY REGARDING THE COLLECTION OF INFORMATION AT ANY TIME. SHOULD ANY NEW POLICY TAKE EFFECT, WRITETOUCHHEALTH WILL GIVE NOTICE TO YOU AND ALL USERS BY POSTING THE NEW POLICY ON THIS WEBSITE, AND THE NEW POLICY WILL APPLY ONLY TO INFORMATION COLLECTED THEREAFTER.
BY ACCESSING OR USING THIS WEBSITE AFTER SUCH CHANGES ARE POSTED, YOU AGREE AND CONSENT TO ALL SUCH CHANGES.
If you are a patient or legal representative, your physician's use and disclosure of your identifiable health information is subject to your physician's Notice of Privacy Practices. We cannot control any physician's use of a patient's identifiable health information. If you are a patient or legal representative of a patient, please contact your physician for a copy of their Notice of Privacy Practices. WRITETOUCHHEALTH provides this Portal on behalf of your physician and therefore protects identifiable health information as required by the applicable agreement between WRITETOUCH HEALTH and your physician and in accordance with applicable law. If you have any issues with the identifiable health information managed by your physician’s practice, please contact them directly, as we have no ability to change the information you have provided them.
Disclosure of Information Practices
Whether you are a patient or a physician, if we collect information from or about you via the Portal, we will tell you what information we are collecting. The amount and type of information that we receive depends on how you use this Portal and the information you choose to submit to us via the Portal.
Whether you are a physician or patient user, we may track use of your user name and may also capture the paths taken as you move from page to page (i.e., your "click stream" activity). When you log in, your user name and encrypted password will be logged by our system in an audit log but will not be used by us.
As a user of the Portal and if available, you may also choose to use the secure messaging feature of the Portal which will allows the exchange of communications between patients and the clinicians who treat them and which may contain identifiable health information. Communications sent via this feature are recorded and maintained by WRITETOUCHHEALTH. Portal users have the ability to view the trail of messages received and sent via their Portal account. WRITETOUCHHEALTH does not edit the content of the communications between patients and physicians.
Identifiable Health Information
You are not required to provide identifiable health information to visit this Website. However, if you are a patient or the legal representative of a patient, you must provide certain identifiable health information in order to complete your registration for the non-public Portal to access the health records maintained by your physician.
If you are a patient (or the legal representative of a patient), we will collect identifiable health information from you with your knowledge during the registration process and in the event you request information or services. We may collect any identifiable health information that you provide to us, such as your name, address, e-mail address, gender, birth date and phone number. If you access the Portal patient registration via the link provided by your physician, certain basic information may be pre-filled into your Portal registration, which you will need to verify.
When you register for the Portal via the Website, the registration process requires you to choose an email (to be used as your username) and password for your account, which you should keep and maintain as confidential. If you choose to share your user name and password you understand that those individuals to whom you share that information will have access to your identifiable health information and will be able to add to your identifiable health information as though they were you. You will be responsible for all activities by users resulting from sharing or not maintaining the confidentiality of your user name or password.
If you are a registered patient user of the Portal, your identifiable health information (or that of the patient for whom you are the legal representative) currently stored electronically in your physician records will become accessible to WRITETOUCHHEALTH in order to provide you access to such information through the Portal. Your electronic health records are not permanently stored in the Portal or Website, but a temporary copy of them is displayed via the Portal when you are logged in with your user name and password.
Non-Identifiable Health Information
Either WRITETOUCHHEALTH or our third web statistics vendor on behalf of WRITETOUCHHEALTH may also collect non-identifiable information, which is automatically collected as you browse or otherwise access this Website and Portal. We may collect such information by tracking, or asking our third party vendor to track, your click-stream activity when such information is not tied to a user ID through the use of "cookie" technology or by tracking internet protocol (IP) addresses, as explained below.
Like many companies, we may use "cookie" technology on and off of the Website and Portal. “Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. They enhance your online experience by saving your preferences while you are visiting a particular website. The cookies do not contain any identifiable health information and cannot profile your system or collect information from your hard drive.
When you view our Website or Portal we may place a cookie on your computer, which may be either temporary or permanent. Temporary cookies are used to complete transactions with this Website or Portal and for other purposes such as counting the number of visits to our certain web pages. These temporary cookies are eliminated when you exit your browser.
A permanent cookie may also be stored on your computer by your browser. When you log in, this type of cookie tells us whether you've visited us before or if you are a new visitor. The cookie doesn't obtain any identifiable health information about you or provide us with any way to contact you, and the cookie doesn't extract any information from your computer.
The "help" portion of the toolbar on most browsers will tell you how to prevent your browser from accepting certain types of cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Please note that disabling temporary cookies may prevent you from using and accessing this Website and Portal. Disabling permanent cookies may also impact your use and access of the Website and Portal and in particular will not allow you to see any personalization (including your health record) on the Website or Portal that you may activate.
In addition, if you visit our Website again after deleting a cookie, a new cookie may be activated.
We may also log and track IP addresses for systems administration purposes and for reporting usage trends. Your IP address is usually associated with the physical place from which you enter the Internet, the name of the domain and host from which you access the Internet, the browser software you use and your operating system, and the date and time you access the Website or Portal. By collecting your IP address, we may record the page that linked you to this Website, the web pages you visit, the ads you see or click on, and other information about the type of web browser, computer, platform and settings you are using, and any search terms you enter on this Website or Portal. IP addresses are not used to track an individual user’s session. This information only helps us determine how often different areas of our Website and Portal are visited.
We may combine non-identifiable information collected automatically (such as through IP addresses, cookies or click-stream monitoring) with any previously submitted personal information that we may have received from you.
We may collect your geographic location based on your IP address and other location-based data.
We may also use various third party internet vendors to collect, track and analyze track analytical data regarding Website usage and trends.
Users of the Portal may have the opportunity to participate through the Portal in various WRITETOUCHHEALTH surveys depending on the survey and as permitted by law.
Any survey responses that you choose to submit may be aggregated, de-identified and provided or sold to third parties as set forth below.
How Will Your Information Be Used And Disclosed?
Identifiable Health Information
We may use any identifiable health information or other information that you voluntarily provide us in order to provide you with information, products or services that you may request from WRITETOUCHHEALTH.
If you are a patient or the legal representative of a patient, any identifiable health information that you share via the Portal will be made accessible to your physician and will become a part of the records maintained by your physician, which records are subject to your physician's Notice of Privacy Practices. WRITETOUCHHEALTH has no control over or responsibility for your physician's use or disclosure of information that you may provide via the Portal or Website.
To the extent permitted by applicable law, WRITETOUCHHEALTH may use your participation in the Portal to communicate to you special offers and featured items as well as special offers and featured items from third parties, WRITETOUCHHEALTH, WRITETOUCHHEALTH's affiliates, and/or other suppliers and vendors. If you are receiving additional communications and special offers, you may revoke your authorization to receive such materials from WRITETOUCHHEALTH via the Portal at any time by contacting us using the contact information below or as outlined in the applicable communication. We will implement your revocation as soon as is commercially reasonable. WRITETOUCHHEALTH cannot control any communications and other materials that you may receive directly from third parties.
We will also use your information to customize your browsing experience and communicate with you and otherwise respond to your questions and suggestions regarding use of the Portal as may be permitted by applicable law.
We may share your information only with our suppliers and vendors to the limited extent permitted by applicable law. We require those suppliers and vendors to comply with all applicable data privacy laws and regulations, including HIPAA. We do not sell, lease or rent your identifiable health information. We may also use your geographic location to provide you with specific content and direct you to your closest service providers to the extent permitted by applicable law.
Non-Identifiable Health Information
The non-identifiable, aggregated health information we collect may be shared with our suppliers and vendors and used in the aggregate to create summary statistics that help us analyze website usage trends, assess what information is of most and least importance, determine technical design specifications, arrange the Website in the most user-friendly way, and identify system performance or problem areas.
We may aggregate and de-identify in accordance with HIPAA identifiable health information, either alone or with other data to create anonymous "aggregate data" regarding the users of our Website and Portal. Aggregate and de-identified data is information that describes the habits, treatment plans, usage patterns, other medical record data and/or demographics of users as a group but does not reveal the identity of particular users. This data will not identify you, but will be used as statistical information to determine such things as user demographics and usage patterns of our Website and Portal. WRITETOUCHHEALTH may use aggregate data to understand the needs of our community of users and determine what kinds of programs and services we can help provide. Aggregate data may also be provided or sold to third parties, including for the purpose of getting targeted content to you by third party vendors, suppliers, business partners and/or affiliates a picture of our community and services and/or participation in surveys or receipt of emails from third parties.
Other Use and Ownership
We also reserve the right to share your information collected from this Website or Portal with third parties to the extent permitted by applicable law including but not limited to the requirements under HIPAA, and, in the case of identifiable health information, pursuant to WRITETOUCHHEALTH's business associate agreement with the applicable physician.
While no web site can guarantee security, we maintain physical, administrative, electronic, technical and procedural safeguards to help protect your personal information collected via the Portal as required by applicable law. While we cannot guarantee that loss, misuse or alteration to data will not occur, we use industry standards, such as Secure Socket Layers ("SSL") technology, to help safeguard against such occurrences. In certain areas, the information passed between your browser and our system is encrypted with SSL technology (which covers any messages, PII or communications a person directs to WRITETOUCHHEALTH or the clinician team) to create a protected connection between you and our website to ensure confidentiality.
Our data is both physically and electronically secured and is protected from open access to the Internet by using firewall and encryption technology. We limit access to personally identifiable information about you to our employees and third-party agents, who we reasonably believe need to have access to your information to provide you with the information or services you request via the Portal.
In the event that a breach in our security systems occurs and there is a possibility that an unauthorized person acquires your personal information, we will notify you of such a breach as may be required by applicable law.
In order to help maintain security, you should never share your user ID or password and should always sign out when you are finished using the Portal.
We will maintain your information and allow you to request updates at any time by logging into your Portal account to access your information. We will also take steps to make sure that any updates that you provide are processed in a timely and complete manner.
Third Party Websites
What if I am accessing this Portal from outside of the United States?
Transfer of Data
Important Note Regarding Children
This Website and Portal is not directed toward children under 18 years of age and WRITETOUCHHEALTH does not knowingly collect or use information from children under 18 through this Website or Portal. Any information submitted via the Portal regarding a minor under the age of 18 must be submitted by the minor's legal representative. To the extent permitted by applicable state law, minors may access their identifiable health information through their physician.
McHeyzer Management, Inc.
4823 Broadway Street, Addison TX 75001