Last Updated April 19, 2023
Easter Seals, Inc. (d/b/a "Easterseals") ("we," "our," or "us") understands that data privacy and the protection of personal information is important to you. This Privacy Notice explains how we collect, use and share your personal information, and your rights and choices regarding the personal information we collect about you.
Please read this Notice carefully to understand our policies and practices regarding your personal information and how we will process it. You can also click on the links below to navigate to a specific section.
1. Scope of Notice
This Privacy Notice applies to all donors, members, website visitors, business partners, employees, job applicants, and individuals who otherwise interact with Easterseals whom we collect personal information from. We often refer to your interactions with us as using our "services" throughout this Notice.
2. Personal Information Collection
We collect a variety of information as part of our operations, including personal information and other information. "Personal information" is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable individual.
a. How We Collect Personal Information
Easterseals collects information, including personal information, from and about its donors, event attendees and program participants, individuals who interact with our affiliate members, employees and job applicants, individuals who visit our website and other individuals who choose to interact with us. We collect information from or about you in the following ways:
b. Types of Personal Information We Collect
The types of personal information we collect depends on how you interact with us, including whether the interaction is through one of our affiliate members or directly with us. In many cases, the personal information we collect will be apparent from the context in which you provide the information.
We collect the following types of personal information from you depending on how you interact with us (i.e., donor, employee, etc.).
|Categories of Personal Information||Categories of individuals|
|Contact Information. This includes your name, mailing address, email address, social media handle, or other similar identifiers.||
|Identification Information. This includes your SSN, driver's license number, passport number, or similar legal identification information.||
|Profile Information. This includes information about your activity and interactions with us, including your donor tendencies and donation history, information you voluntarily provide to us or that we collect from other sources regarding your interests, preferences, and characteristics. We compile this information we collect about you to better understand you.||
|Health Information. This is information about your health, disability, or medical condition which may include "Protected Health Information" (PHI).||
|Financial Information. This includes information about your wealth and financial status, income, credit card, bank account, or payment information.||
|Location Information. This includes information about your location.||
|Professional or Employment-Related Information. Current or past job history or performance evaluations.||
|Internet or other similar network activity. Browsing history, search history, information on your interaction with a website, application, or advertisement.||
|Interaction Information. This includes information about your attendance at events we host or programs we sponsor, as well as information about correspondence with us and other ways you interact with us.||
|Sensitive Personal Information. We may collect certain sensitive personal information including race, gender, and age information. This information is collected in aggregate form.||
We may not collect all of the above categories of information from each category of individual who interacts with us. Please note that if you voluntarily provide us with additional information when you interact with us that does not fit one of these categories of information or individuals set forth above, we will collect the information and use it for the purposes you direct or that we disclose to you.
As noted above, in certain circumstances, we may also collect "Protected Health Information." "Protected Health Information" ("PHI") is individually identifiable health information. We sometimes collect PHI when we gather information about the effectiveness of our programs in order to understand whether a program that we or our affiliate members offered resulted in improved outcomes for the individuals or communities our programs are designed to serve.
3. How We Use Personal Information
We use personal information for our legitimate business purposes to further our mission and for other purposes disclosed to you at the time data is collected. More specifically, we use personal information in the following ways:
We may aggregate and de-identify personal information we collect from you to understand the effectiveness of our programs, services, and offerings, as well as to understand our donor base and donor trends. When we aggregate or de-identify information, it is no longer personally identifiable.
4. How We Disclose Personal Information
Easterseals may share your personal information in the following circumstances, and as otherwise described in this Notice:
5. Easterseals Affiliate Members
Easterseals has a number of affiliate members throughout the United States who interact directly with the populations we serve by bringing Easterseals' mission and work directly into the community in which the affiliate member operates. While our affiliate member organizations are associated with and use Easterseals branding, they may have their own practices regarding how they collect, use, share, and retain information when you interact with them.
As described above, affiliate members share information with us, and we share information with our affiliate members. This information sharing occurs so that we can understand the impact of our and our affiliate members' programs and services, yield actionable insights, and drive future-forward decision making so that we can continue to further the Easterseals' mission of equity, inclusion, and access for individuals with disabilities.
Easterseals' website may contain links to other sites, including to our affiliate members, as well as links to non-affiliated third parties, such as social networks or business partners. These linked sites may have personal information collection, use, and disclosure practices that differ from Easterseals' practices. We encourage you to review the privacy policies of websites that you visit before sharing your personal information with them. Please also be aware that if you disclose personal information, PHI, or other sensitive information through public forums, at an event, or on online message boards, this information may be used by others. We take no responsibility for the content, security, or confidentiality of any information posted on or conveyed in these public spaces.
7. Security of Personal Information
Easterseals knows that information security is of the utmost important to our donors, affiliate members, website visitors, and individuals whose information we collect. We maintain reasonable technical, administrative, physical, and organizational safeguards in proportion to the sensitivity of information we collect that are designed to prevent unauthorized access, use, and disclosure of personal information.
However, no electronic data transmission or processing of personal information is completely secure, so we cannot guarantee the security of personal information. We encourage you to assist us with securing your personal information by using a strong password and not disclosing your login credentials, where applicable, to anyone. If we become aware of an incident that affects your personal information, we will investigate and comply with all reporting obligations.
8. Transmission of Health-Related Information
Easterseals understands the sensitivity of collecting and using health-related data. It is not Easterseals' intent to collect personally identifiable health-related information or PHI. If we do collect personally identifiable health-related information or PHI, it will not be used by or shared with entities other than Easterseals or our affiliate members, unless the information is de-identified. Any transfer of personally identifiable health-related data between Easterseals organizations will take place in a secure environment with access allowed only to certain qualified employees of Easterseals. Easterseals will comply with all regulations set forward by the Health Insurance Portability and Accountability Act (HIPAA). To learn more about HIPAA, visit the U.S. Department of Health and Human Services Office for Civil Rights.
9. Retention of Personal Information
We will retain your information only for as long as necessary to achieve the purpose for which it was collected. This may mean that we will continue to retain certain information even after we stop providing our services directly or indirectly to you, after you delete your user profile, or cease interacting with us, as required by law or for our legitimate business purposes. We may also retain de-identified, aggregated, or anonymous information that does not identify a particular individual. In all cases where we retain data, we do so in accordance with limitation periods and record retention obligations that are imposed by applicable law.
10. Your Rights and Choices Regarding your Personal Information
Easterseals offers various rights that are consistent with state consumer privacy laws. Easterseals offers the option to access, correct, and delete your personal information. If you are a registered user of our website, you can access your Easterseals profile and update your contact information and user preferences by clicking here. Upon your request, we will delete, aggregate, or de-identify personal information related to you that is retained in our organizational databases, unless we are required to continue to retain the information in an identifiable format. To exercise your right to deletion, or to modify or correct your information other than through the link above, please contact us via a method set forth in the below "Contact Us" section.
You can also change your communication preferences and opt-in or opt-out of marketing communications from Easterseals. To opt-out of receiving email communications, postal mail or from participating in the list rental and exchange program, or to request a disclosure of list rental and exchange information, please follow the directions below.
We will endeavor to fulfill all requests within a reasonable timeframe.
12. International Transfers of Personal Information
Easterseals and all of its affiliate members are located in the United States, and all programming offered by Easterseals and its affiliate members occurs in the United States. Because of the global nature of the internet, the Easterseals website may be accessible from jurisdictions other than the United States, even though Easterseals does not operate, provide, or market its services outside of the United States. If you access the Easterseals website outside of the United States, your information will be transferred to and processed in the United States. Since the data protection laws of various countries differ, information transferred to the United States may not be subject to the same level of protection as the jurisdiction in which you reside. If you choose to access our website from a jurisdiction outside the United States, we rely on your consent to transfer the data to the United States. To the extent you do not consent to data transfers to the United States, please do not provide us with your personal information or visit our website.
13. Information from Children
Our website is not directed towards children under the age of 13. We do not knowingly collect personal information from anyone under the age of 13 through our website without parental consent. If you become aware that we have collected personal information from an individual under the age of 13 through our website without parental consent, please let us know so that we can take appropriate action.
14. Changes to this Notice
We may update this Privacy Notice from time to time. If we make material updates to this Notice, we will endeavor to provide you notice by placing a prominent notice on this website and/or sending an email notification of the change. We will also update the "last updated" date at the top of this policy. Any changes will be effective immediately on posting unless otherwise indicated. Continued use of our services after updates to our Notice will be deemed consent to the changes.
15. Contact Us
If you have any questions about this Notice or our information practices, please contact us by emailing us through this link or directly at email@example.com, calling us toll-free at 800-221-6827, or writing to us at:
Easter Seals, Inc.
Attn: Privacy Manager
141 W. Jackson Blvd
Chicago, IL 60604
In accordance with the requirements of the HIPAA Privacy Rule
The Health Insurance Portability and Accountability Act of 1996
Effective January 1, 2019
2399 E. Walton Blvd. Auburn Hills, MI 48326
Phone: (248) 475-6400
Fax: (248) 475-6402
We value you as a consumer of our agency and we take the privacy of your health information seriously. A number of laws and regulations, including HIPAA, the Health Insurance Portability and Accountability Act of 1996 and Public Act 258 of the Michigan Mental Health Code, protect your health information.
1. This notice will tell you about the ways in which we may use and disclose medical information about you. It also describes our obligations and your rights regarding the use and disclosure of medical information. We are required by law to:
a. Make sure that medical information that identifies you is kept private;
b. Give you this notice of our legal duties and privacy practices with respect to medical information about you and;
c. Follow the terms of the notice that is currently in effect
2. More detailed information about how health information about you may be used and disclosed and how you can get access to this information is available from the program from which you receive services. Or, you may contact our Privacy Officer at 248-475-6400 for this information.
3. During the time that you are using services at our agency, we will collect and keep different kinds of information about you. This information is called Protected Health Information (PHI). We want you to understand how we might use the information we collect.
4. Use of recording devices (audio or video) is strictly prohibited by you, a representative, or a family member, whether on Easterseals Michigan property or not, unless specifically consented to, in writing, by all parties. A violation of this policy could result in legal action, civil or criminal, including as described in Public Act 328; MCL 750.539, et seq.
The following is some information that gives you a summary of your privacy rights:
“Protected Health Information” means:
Information about you that may identify you and relates to your past, present or future physical or mental health or condition, and health care services related to your health or condition.
Examples of this may include:
Your name, address, telephone number and date of birth
Your diagnosis (the condition for which you are receiving treatment)
Your treatment plan and goals
Your progress toward those goals.
Your information will be used to help us to provide you health care services.
We will use your information when we are giving you services. We may disclose your information when we are helping you get other services you need.
We will disclose parts of your information to get payment for your health care services.
We may use or disclose your health information to obtain help for you in an emergency.
We may disclose your health information for surveys and other quality improvement projects.
We may sometimes use or disclose your information without your permission when the law requires it.
We may disclose parts of your information for public health uses.
We may disclose your information if the Food and Drug Administration requires it.
We may disclose your information to follow rules for workers’ compensation and other similar programs.
In certain situations, we will disclose your information to the police.
If you are incarcerated, we may use or disclose your information that we created or received while we provided services to you.
If you are a member of the armed forces, we may release medical information about you as required by military command authorities. We may also release medical information about foreign military personnel to the appropriate foreign military authority.
We may disclose medical information about you for public health activities to:
o Prevent or control disease, injury or disability
o Report child abuse or neglect
o Report reactions to medications
o Notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition
o Notify the appropriate government authority if we believe you have been the victim of abuse, neglect or domestic violence. We will only make this disclosure if you agree or when required or authorized by law.
If you are involved in a lawsuit or a dispute, we may disclose medical information about you in response to a court or administrative order. We may also disclose medical information about you in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute, but only if efforts have been made to tell you about the request or to obtain an order protecting the information requested.
We may release medical information if asked to do so by a law enforcement official:
o In response to a court order, subpoena, warrant, summons or similar process
o To identify or locate a suspect, fugitive, material witness, or missing person
o About the victim of a crime if, under certain limited circumstances, we are unable to obtain the person’s agreement
o About a death we believe may be the result of criminal conduct
o To report a crime, the location of the crime or victims, or the identity, description or location of the person who committed the crime
o We may release medical information about you to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law
We may use your information for business operations.
We may use your information to do the business of this agency which may include conducting quality assessment and improvement activities.
We may use parts of your information to send you newsletters and other information.
We may use parts of your information for business planning and development.
You have the right to review and make copies of your protected health care information, which may be provided in paper and/or electronic form. A fee may be charged for the costs of copying, mailing, or other supplies associated with your request.
You have the right to request a restriction or limitation on your protected health care information. To request restrictions, you must make your request in writing on the ESM “Request for Restrictions on the Use and/or Disclosure” Form.
You have the right to be told when we disclose your protected health care information and to whom.
o To request this list of accounting for disclosures, you must submit your request in writing to the Easterseals Michigan Corporate Compliance Team. Your request must state a time period which may not be longer than six years and may not include dates before April 2003. Your request should indicate in what form you want the list (e.g. paper or electronic). The first accounting you request is free. For additional requests, we may charge you for the costs of providing the accounting. We will notify you of the cost involved and you may choose to withdraw or modify your request at that time before any costs are incurred.
You have a right to request that we communicate with you about confidential matters in a certain way or at a certain location.
You have the right to amend parts of your protected health information if you think they are incorrect or incomplete.
You have a right to a paper copy of this notice. You may ask us to give you a copy of this notice at any time.
Even if you have agreed to receive this notice electronically, you are still entitled to a paper copy of this notice.
You may obtain a copy of this notice at our website, www.EastersealsMichigan.com or contact the Easterseals Michigan Privacy Officer at (248) 475-6400.
You have a right to be notified of any breach of your PHI.
You have the right to opt out of being contacted for fund-raising purposes.
You have the right to restrict certain disclosures of PHI to a health plan when you (or any person other than the health plan) pay for treatment out of pocket in full.
EASTERSEALS MICHIGAN IS NOT REQUIRED TO AGREE TO YOUR REQUEST AND/OR MAY DENY YOUR REQUEST BASED ON STATE AND FEDERAL LAWS. EASTERSEALS MICHIGAN WILL PROVIDE YOU IN WRITING WITH REASONS FOR THE DENIAL OF YOUR REQUEST CHANGES TO THIS NOTICE: WE RESERVE THE RIGHT TO CHANGE THIS NOTICE. WE RESERVE THE RIGHT TO MAKE THE REVISED OR CHANGED NOTICE EFFECTIVE FOR MEDICAL INFORMATION WE ALREADY HAVE ABOUT YOU AS WELL AS ANY INFORMAITON WE RECEIVE IN THE FUTURE. WE WILL POST A COPY OF THE CURRENT NOTICE ON THE EASTERSEALS MICHIGAN WEBSITE. THE NOTICE WILL CONTAIN THE EFFECTIVE DATE.
This “Notice of Privacy Practices” applies to all services provided to you by Easterseals Michigan. In accordance to HIPAA requirements, our agency also has “Business Associate Agreements” with each organization with which we do business that may relate to your personal health care information. Each Business Associate must also comply with the requirements of HIPAA, and where applicable, the Michigan Mental Health Code or other federal or state laws and regulations.
You may receive marketing materials from Easterseals Michigan. You have the option to opt out of receiving these materials by contacting our Marketing Department. Easterseals Michigan does not sell your PHI for marketing purposes.
Depending on your services received from Easterseals Michigan, you may have additional privacy protection under existing or future state laws. We are committed to complying with all applicable laws when we use or disclose your health information.
OTHER USES OF MEDICAL INFORMATION:
Other uses and disclosures of medical information not covered by this notice or the laws that apply to us will be made only with your written permission. If you provide Easterseals Michigan permission to use or disclose medical information about you, you may revoke that permission, in writing, at any time. If you revoke your permission, we will no longer use or disclose medical information about you for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain our records of the care that we provided you.
BREACHES OF PHI:
Easterseals Michigan privacy and security policies and procedures were updated to comply with the breach reporting and notification requirements of the HITECH Act, passed as part of the American Recovery and Reinvestment Act of 2009.
If you have any concerns about our privacy practices, or if you feel your rights have been compromised, you have a right to file a complaint with Easterseals Michigan at:
2399 E. Walton Blvd.
Auburn Hills, MI 48326
Or, you may file a complaint with:
Region V, Office for Civil Rights,
U.S Department of Health and Human Resources
233 N. Michigan Avenue, Suite 240
Chicago, IL 60601
All complaints must be submitted in writing. Please be assured that if you file a privacy complaint, your complaint will be handled in a professional manner, and you will not be subject to any type of penalty for filing the complaint.
We want to make it easy for you to make informed health care decisions. Your Easterseals Michigan service staff are more than happy to assist you with any questions that you may have about your services. If you have any questions about this Notice, please contact our Privacy Officer at (248) 475-6400.
Notice of Non-Discrimination
Easterseals Michigan complies with applicable Federal civil rights laws and does not discriminate on the basis of race, color, national origin, age, disability, or sex. Easterseals Michigan does not exclude people or treat them differently because of race, color, national origin, age, disability, or sex.
Provides free aids and services to people with disabilities to communicate effectively with us, such as:
Qualified sign language interpreters
Written information in other formats (large print, audio, accessible electronic formats, other formats)
Provides free language services to people whose primary language is not English, such as:
Information written in other languages
If you need these services, contact your case manager.
If you believe that Easterseals Michigan has failed to provide these services or discriminated in another way on the basis of race, color, national origin, age, disability, or sex, you can file a grievance with:
Stephanie Wolf Hull
Corporate Compliance Officer
2399 E. Walton Blvd.
Auburn Hills MI 48326
(248) 475-6300 – phone
(248) 475-2900 – fax
You can file a grievance in person or by mail, fax, or email. If you need help filing a grievance, your case manager is available to help you. You can also file a civil rights complaint with the U.S. Department of Health and Human Services, Office for Civil Rights, electronically through the Office for Civil Rights Complaint Portal, available at https://ocrportal.hhs.gov/ocr/portal/lobby.jsf , or by mail or phone at:
U.S. Department of Health and Human Services
200 Independence Avenue SW
Room 509F, HHH Building
Washington, D.C. 20201
Complaint forms are available at http://www.hhs.gov/ocr/office/file/index.html
Easterseals Michigan cumple con las leyes federales de derechos civiles aplicables y no discrimina por motivos de raza, color, nacionalidad, edad, discapacidad o sexo.
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ܒܸܫܠܡܐܝܹܠܗܠܩܢܘܢܹܐܠܚܼܝܡܹܐܕܸܙܕܩܹܐܡܕܼܝܢܝܹܐܦܹܕܪܠܝܹܐܘܡܬܒEasterseals Michigan ،ܐܘܼܡܬܢܝܐܐܘ،ܥܘܡܪܵܐ ܪܼܢܓܐ،ܐܘܐܼܨܐܘܡܥܼܘܟܼܘܬܐܐܘܓܸܢܣܐ.ܦܘܼܪܫܘܼܢܝܐܒܸܢܝܐܥܠܛܘܼܗܡܐ،ܐܘܿܢܼܬܘܠܝܼܿܒܕܩܿܘܢܵܡܨܼܝܬ،ܵܝܐܵܪܿܘ1 ܙܘܗܪܐ: ܐܢܐܼܚܬܘܢܟܐܗ◌ܸܡܙܡܝܼܬܘܿܢܠܫܢܐܐܵܬ-(248) 475-6300
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