Easter Seals New York
Notice of Privacy Practices
This notice describes how information about you may be used and disclosed and how you may obtain access to this information. Please review this notice carefully. If you have any questions, or do not understand any part of this notice, please contact Easter Seals Security and Compliance Officer at: email@example.com
This notice describes Easter Seals New York’s (Easter Seals) Information Use and Disclosure practices. It describes how the personal and medical information that we collect about you will be used and shared with others. The policies apply to:
· Everyone in Easter Seals who is authorized to make notes about you or to review information about you
· All services and departments of Easter Seals
· All employees and other paid and volunteer Easter Seals personnel
· Easter Seals service, resource development, clinical and administrative support staff may share information with each other for services, payment, or operations described below
We understand that information about you is personal and we are committed to protecting your privacy. In our records we maintain data about you, your services, insurance information, etc. We need this information to provide you with services.
By law we are required to:
· Keep information about you private
· Provide you with a notice of our duties and policies concerning your personal health information
· Comply with the policies protecting information about you
Understanding Your Case Record/Information
Each time Easter Seals provides a service; additions are made to your health record. This information may be used as:
· Basis for planning your care, service(s) and treatment
· Means of communication among the health professionals who contribute to your care
· Legal document(s) describing the care you received
· Means by which you, or a third party payee, can verify that services billed were actually provided
· To collect payment for service(s)
· For service operations to educate our service staff and employees responsible for your medical care
· A source of data for medical research
· A source of information for public health officials charged with improving the health of state and Nation
· To prevent a serious threat to health and safety
· Your information may be used in the event of your death
· We may share your information with federal, state and local law when required to do so
· A source of data for facilitating planning and marketing
· A tool with which we can assess and continually work to improve the care we render, and the outcomes we achieve.
Other Informational Uses
In the event of circumstances not covered by this notice or the laws that apply to Easter Seals when we might share information about you, we will only do so with your written permission. If you provide us permission to use or disclose information about you, you may revoke that permission, in writing, at any time. If you revoke your permission, we will no longer use or share information about you for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures (sharing of information) we have already made with your permission, and that we are required to retain our records of the service that we provided to you.
o Ensure its accuracy
o Better understand who, what, when, where, and why others may access your health information
o Make informed decisions when authorizing disclosures to others
Your Informational Rights
Your case record is the physical property of the healthcare practitioner or facility that compiled it; however, this information belongs to you.
You have the right to:
· Request a restriction on certain uses and disclosures of your information
· Obtain a paper copy of the notice of information practices upon request
· Inspect and obtain a copy of your records
· Request an amendment to your case records
· Obtain an accounting of disclosures of your health information
· Request communications of your health information by alternative means or at alternative locations
· Revoke your authorization to use or disclose health information except if action has already been taken.
· Request confidential communications
Easter Seals may deny your request to inspect and copy your records in certain limited circumstances.
If you are denied access to information, you may file a grievance and request that the Easter Seals Privacy and Security Officer, or his or her designee, of the Easter Seals Privacy and Security Team review the denial. The privacy representative conducting the review will not be the person whom originally denied your request.
The Responsibilities of Easter Seals
Easter Seals New York is required to:
· Maintain the privacy of your health information
· Provide you with a notice of our legal duties and privacy practices with respect to information we collect and maintain about you
· Abide by the terms of this notice
· Notify you if we are unable to agree to a requested restriction
· Accommodate reasonable requests you may have to communicate health information by alternative means or by at alternative locations
Examples Of How We Will Disclosure Your Information For Treatment, Payment And Health Operations
We will use your health information for treatment.
For example: information obtained by your service provider will be recorded in your case record and used to determine the course of treatment and services that should work best for you. When a team of individuals are involved in your service delivery, with your written permission we will share certain agreed upon components of your record. This is to ensure that the team can best meet your needs.
We will use your health information for payment.
For example: A bill may be sent to you or a third-party payer. The information on or accompanying the bill may include information that identifies you, as well as your diagnosis (if applicable), procedures, and supplies used.
We will use your health information for continuous quality improvement agency operations.
For example: Members of the staff, the continuous quality improvement coordinator, or members of the quality improvement team may use information in your case record to assess the care and outcomes in your case and others like it. This information will then be used in an effort to continually improve the quality and effectiveness of the services we provide.
Supervisors of your service provider may also review your case record as part of the supervisory process of the agency. We want to ensure that best practice occurs in service delivery.
Business Associates: There are some services provided in our organization through contacts with business associates. Examples include janitorial services, vendors who maintain copy machines, our auditors, our accrediting body, and other contract monitoring bodies. When these services are contracted, we may disclose your health information to our business associate so that they can perform the job we’ve asked them to do and bill you or your third-party payer for services rendered, or they may have access to your health information due to the proximity of health information to their work. To protect your health information, however, we require the business associate to appropriately safeguard your information through a business associate agreement.
Notification and Communication with the Family: We may use or disclose information to notify or assist in notifying a family member, personal representative, or another person responsible for your care, your location, and general condition.
Marketing: We may contact you to provide appointment reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to you. We may also send your information about our agency such as newsletters, etc.
Fundraising: We may contact you as part of a fund-raising effort.
Workers Compensation: We may disclose health information to the extent authorized by and to the extent necessary to comply with laws relating to workers compensation or other similar programs established by law.
Public Health: As required by law, we may disclose your health information to public health or legal authorities charged with preventing or controlling disease, injury, or disability.
Correctional Institution: Should you be an inmate of a correctional institution, we may disclose to the institution or agents thereof, health information necessary for your health and the health and safety of other individuals.
Law Enforcement: We may disclose health information for law enforcement purposes as required by law or in response to a valid subpoena.
Federal law makes provision for your health information to be released to an appropriate health oversight agency, public health authority or attorney, provided that a work force member or business associate believes in good faith that we have engaged in unlawful conduct or have otherwise violated professional or clinical standards and are potentially endangering one or more patients, workers or the public.
Any use of your protected health information outside of this notice will not occur without your written permission.
For More Information or to Report a Problem:
If have questions and would like additional information, you may contact the Easter Seals Privacy and Security Officer.
If you believe your privacy rights have been violated, you may file a complaint with Easter Seals. To file a complaint with Easter Seals, follow the grievance procedure and request that your grievance be reviewed by the Easter Seals Privacy and Security Officer, Christine McMahon at: 555 Auburn Street, Manchester, New Hampshire 03103. Submit your complaint in writing. We will not retaliate against you for filing a complaint.
Some service recipients may also have the right to file a privacy complaint with the United States Secretary of the Department of Health and Human Services.
We may change this Notice
Easter Seals reserves the right to change this notice. We reserve the right to make the revised or changed notice effective for information we already have about you as well as any information we receive in the future. Should our information practices change, we will mail a revised notice to the address you have supplied us, as well as, posting a copy of the current notice at Easter Seals facilities.
ACKNOWLEDGEMENT OF RECEIPT
The above Consumer Information Use, Disclosure, and Release Notice provides information about how we may use and share protected information about you. You have the right to review the notice before signing this acknowledgement. As provided in our notice, the terms of our notice may change.
My signature below indicates that I understand the above, and I have been provided with a copy of the notice of privacy practices.
Signature of individual, if applicable Date
Signature of legal representative, if applicable Date Relationship to individual
Distribution: Original in Easter Seals record; copy to individual or legal representative
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.
- Scope of Notice
- Personal Information Collection
- How We Use Personal Information
- How We Disclose Personal Information
- Easterseals Affiliate Members
- Links to Other Sites
- Security of Personal Information
- Transmission of Health-Related Information
- Retention of Personal Information
- Your Rights and Choices Regarding your Personal Information
- International Transfers of Personal Information
- Information from Children
- Changes to this Notice
- Contact Us
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:
- Directly from you. We collect information directly from you when you make a donation, create a user profile on our website, attend an event or program we are offering, apply for employment or gain employment with us, when you visit our website, and when you otherwise voluntarily submit or provide information to us.
- Automatically. When you visit and interact with our website, we collect information automatically through cookies. For more information about cookies on our website, please visit the section below titled "Cookies."
- From our Affiliate Members. We rely on our affiliate members to provide us with information about the individuals they provide services to and interact with 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 to ensure that our services and programs make the most impact in the communities we serve.
- From Other Sources. We may collect information about you from other sources and we may combine information from other sources with information we collect through our services or interactions with you. Examples of the other sources we most frequently collect information from includes national donor data bases and registries, and companies that compile mailing lists about individuals.
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:
- Provide our services, programs, and events to the communities and individuals we serve.
- Send you confirmations about event or program registration, or donations.
- Process donations and gifts made to Easterseals or our affiliate members.
- Understand our donor base and potential donors.
- Measure the effectiveness of our services, programs, and events, including services, programs, and events offered by our affiliate members.
- Communicate with you about our services, programs, events, happenings, and news.
- Respond to your comments, inquiries, and customer service requests.
- Market our events, services, programs, and potential donor opportunities to you. You may opt-out of marketing communications at any time.
- Provide you with employment, or consider you for employment with Easterseals.
- Process payroll and other benefits afforded to our employees.
- Improve and personalize our content and services.
- Monitor and analyze trends regarding our services, programs, and events, including services, programs, and events offered by our affiliate members.
- Protect against and prevent fraud, unauthorized transactions, and manage risk exposure.
- Enforce our legal rights and agreements.
- Comply with applicable legal requirements.
- Carry out any other purpose you consent to, that we disclose to you at the time your data is collected, or that you direct us to.
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:
- Affiliate Members. We share information with our affiliate members in order to understand and improve the impact of our and our affiliate members' programs, services, and offerings. Please see the section below titled "Easterseals Affiliate Members" for more information.
- Service Providers, Vendors, and Consultants. We rely on third parties to perform functions on our behalf. Some of these service providers include marketing service providers, payment service providers who help us process donations and pay our employees, cloud storage providers, website hosting platforms, client relationship management providers, HR or employee benefits providers, and content providers. We endeavor to ensure written agreements are in place with all service providers, vendors, and consultants where feasible and appropriate. All service providers, vendors, and consultants are required to use the information we disclose to them at our direction and only for the purpose(s) for which it was disclosed to them, and they are required to adhere to security and confidentiality measures.
- List Rental and Exchange Program. We may share certain information about our donors with national donor registration and list service providers in order to grow our donor base and more effectively reach current and prospective donors. If you do not wish for your information to be shared with these third parties, you may opt-out by contacting us via a method set forth in the "Contact Us" section below or by visiting our website and contacting us through a means listed on our website. If you would like to know which third parties participate in the list rental and exchange program, you may also contact us via one of the methods listed below.
- Law Enforcement Agencies, Courts, Regulators, Government Authorities, or Other Third Parties. We may disclose your information: 1) to apply with a legal obligation or court order; 2) when we believe in good faith that the law requires it; 3) at the request of governmental authorities conducting an investigation; 4) to verify or enforce our policies, procedures, terms of service, and other agreements, or to protect the rights, property, safety, and security of Easterseals, our members, vendors, business partners, service providers, affiliate members, website visitors, or the public; 5) to respond to an emergency; or 6) when we believe it is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity.
- Successor Entities, Buyers, Transfers and Mergers and Acquisitions. We may disclose your information to a buyer, potential buyer, successor in interest, or to an organization in connection with a bankruptcy, transfer, merger or acquisition, or other transfer of some or all of Easterseals' or an affiliate's assets, which may include your information. If this occurs, we will endeavor to ensure that the successor entity uses your personal information in accordance with this Privacy Notice, or provides you with notice and a choice about future use of your personal information.
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.
- Email: If you are a registered user of easterseals.com, login to change your email preferences.You may also opt out of certain non-essential marketing email communications using the "unsubscribe" link at the bottom of the email.
- Postal Mail: Opt-out of postal mail solicitations
- List Rental and Exchange: Opt-out of list rental and exchange program
- Disclosure Request: Request disclosure of list rental and exchange practices
We will endeavor to fulfill all requests within a reasonable timeframe.
- Functionality. These cookies are necessary for us to ensure that the website functions properly.
- Security. These cookies are necessary for us to mitigate the risk of data breaches and similar attacks by ensuring that requests are submitted to our website from proper domains.
- Authentication. These cookies allow us to authenticate user requests and to maintain session information related to users.
- Preference. These cookies allow our website to remember which events you have signed up or registered for, the products you place in your shopping cart, and to recognize your device.
- Advertising. These cookies allow us to provide you with more relevant advertisements.
- Analytics. These cookies enable us to learn more about how users and visitors interact with our website, including pages visited, how much time is spent on each pages, and similar information. We use this information in aggregate.
- Third-Party. These cookies are placed by third parties such as Google and social media networks. These cookies track and monitor how you interact with our services and other websites, provide us insight into how you interact with our website (such as analytics), facilitate account registration and login, and also enable the sharing of content from our services to these third parties. We do not control the data use or sharing practices of these third parties. If you do not wish to accept third party cookies, we encourage you to update your browser settings accordingly.
- Chrome: https://support.google.com/chrome/answer/95647?hl=en
- Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
- Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09
- Internet Explorer: https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d
- Safari: https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac
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 firstname.lastname@example.org, 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