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
HIPAA NOTICE OF PRIVACY PRACTICES AT EASTER SEAL SOCIETY OF WESTERN PENNSYLVANIA
Effective Date: April 12, 2003
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.
PLEASE REVIEW IT CAREFULLY.
If you have any questions about this notice, please contact Easter Seal Society of Western Pennsylvania’s Privacy Officer at (412) 281-7244.
Privacy Officer’s Contact Information:
Tina L. Outrich
Vice President of Programs/Services
2525 Railroad Street,
Pittsburgh, PA 15222
WHO WILL FOLLOW THIS NOTICE
This notice describes the privacy practices of Easter Seal Society of Western Pennsylvania and all of its Affiliates and other persons listed below (together, “Provider” or “we”). “Affiliates” means:
All of these persons and entities follow the terms of this notice and may share protected health information with each other for treatment, payment or provider operations purposes as described in this notice.
OUR PLEDGE REGARDING PROTECTED HEALTH INFORMATION
We understand that protected health information about you and your health is personal. We are committed to protecting your protected health information. In order to provide you with quality care and to comply with legal requirements, we create a record of the care and services you receive from the Provider. This notice applies to all of the records of your care maintained by the Provider. Your other health care providers, such as your personal doctor, may have different policies or notices regarding the use and disclosure of your protected health information created and maintained in the doctor’s own office or clinic.
This notice provides the ways in which the Provider may use and disclose your protected health information. It also describes your rights and certain of the Provider’s obligations regarding use and disclosure of your protected health information.
The provider is required by law to:
HOW WE MAY USE AND DISCLOSE PROTECTED HEALTH INFORMATION ABOUT YOU
The following categories describe different ways that we “use” and “disclose” you protected health information. Each category is followed by an explanation and in some instances an example. For purposes of this notice, the term “use” refers to protected health information that is used within the Provider for your treatment, the Provider’s operations, or the payment of your care. The term “disclose” refers to protected health information that is given to outside entities for one of the purposes described in this notice. Whether your protected health information is used or disclosed, the use or disclosure will fall within one of the categories listed below and will be used or disclosed only in the minimal amount necessary to carry out the purpose. The term “may” means that the Provider is permitted under federal law to use or disclose this information without obtaining an additional or specific authorization from you to do so. Even though the Provider may be permitted to use or disclose information in a given instance, it does not mean that we will use or disclose the information. We will still try to assure that any use or disclosure is in your interest or is consistent with practices in the health care field.
For Treatment. We may use and disclose protected health information about you to provide you with medical treatment or services. We may disclose protected health information about you to doctors, nurses, technicians, medical students, and Provider personnel who are involved in taking care of you at the Provider. For example, a doctor treating you for an injury may need to know if you have diabetes because diabetes may slow the healing process. In addition, the Provider may need to tell the dietician if you have diabetes so that the dietician can arrange for appropriate meals. Different departments of the Provider also may share protected health information about you in order to coordinate the different things you need. We also may disclose protected health information about you to people outside of the Provider who may be involved in your medical care when you are absent from the Provider, such as family members, clergy, providers of day services, volunteers, Independent Support Coordinators, case managers, respite care workers and others we have engaged to provide services that are part of your care.
For Payment. We may use and disclose protected health information about you so that the treatment and services you receive from the Provider or other providers may be billed to and payment may be collected from you, the government, an insurance company or a third party. For example, we may disclose information to the county or state mental health and/or mental retardation agency in order to receive payments for your treatment. We may also tell your insurer or governmental payer about a treatment you are going to receive to obtain prior approval or to determine whether your plan or the government will cover the cost of the treatment.
For Health Care Operations. We may use and disclose protected health information about you for Provider operations or operations of another provider or payer. These uses and disclosures are necessary to run the Provider and make sure that all of our clients receive quality care. For example, we may use protected health information to review our treatment and services and to evaluate the performance of our staff in caring for you. We may also combine protected health information about many Provider clients to decide what additional services the Provider should offer, what services are not needed, and whether certain new treatments are effective. We may also disclose information to doctors, nurses, technicians, medical students, direct care providers, behavioral therapists, special therapists, and other Provider personnel for review and learning purposes. We may also disclose information in order to comply with our incident reporting requirements under state, local, or federal law. We may also combine the protected health information we have with the protected health information from other providers to compare how we are doing and see where we can make improvements in the care and services we offer. We may remove information that identifies you from this set of protected health information so others may use it to study health care delivery without learning who the specific clients are.
Health Care Quality Units and Other Quality Review Organizations. We may disclose information to the Pennsylvania Department of Public Welfare, the Office of Mental Retardation, and other state and county mental health and mental retardation agencies through their appointed agents, including Health Care Quality Units and independent monitoring groups, in order to comply with federal, state and local laws and regulations.
Appointed Reminders. We may use and disclose protected health information to contact you as a reminder that you have an appointment for treatment or medical care at the Provider.
Treatment Alternatives. We may use and disclose protected health information to tell you about or recommend possible treatment options or alternatives that may be of interest to you.
Health-Related Benefits and Services. We may use and disclose protected health information to tell you about health-related benefits or services that may be of interest to you.
Fundraising Activities. We may use contact information, such as your name, address and phone number, and the dates you received treatment or services from the Provider to contact you and your family members in an effort to raise money for the Provider. We may disclose this contact information to a foundation related to the Provider so that the foundation may contact you and your family members in raising money for the Provider. If you do not want the Provider or the foundation to contact you or your family members for fund raising efforts, you must notify the Privacy Officer in writing.
Provider Directory. We may include certain limited information about you in the Provider directory while you are a client of the Provider. This information may include your name, location at the Provider, your general condition, and your religious affiliation. The directory information, except for your religious affiliation, may also be released to people who ask for you by name. Your religious affiliation may be given to a member of the clergy, such as a priest or rabbi, even if they do not ask for you by name. This is so family, friends, and clergy can visit you at the Provider and generally know how you are doing.
Individuals Involved in Your Care or Payment for Your Care. We may disclose protected health information about you to your family members, your personal friends or any other person identified by you, but we will only disclose information that we feel is relevant to that person’s involvement in your care or the payment for your care. If you are feeling well enough to make decisions about your care, we will follow your directions as to who is sufficiently involved in your care to receive information. If you are not present or cannot make these decisions, we will make a decision based on whether we believe it is in your best interest for a family member or friend to receive private health information and how much information they should receive. Obviously, we are inclined to provide greater information to close family members than to friends.
We may also disclose information to disaster relief agencies or to family, friends or others in an effort to locate or identify members or personal representatives.
Research. Under certain circumstances, we may use or disclose protected health information about you for research purposes. For example, a research project may involve comparing the progress of all clients who received one therapy to those who received another, for the same condition. All research projects, however, are subject to a special approval process. This process evaluates a proposed research project and its use of protected health information, trying to balance the research needs with clients’ need for privacy of their protected health information. Before we use or disclose protected health information for research, the project will have been approved through the research approval process, but we may, however, disclose protected health information about you to people preparing to conduct a research project, for example, to help them look for clients with specific medical needs, so long as the protected health information they review does not leave the Provider.
In certain situations, we are required to ask your specific permission, such as when the researcher will have access to your name, address or other information that reveals who you are, or will be involved in your care at the Provider.
As Required By Law. We will disclose protected health information about you when required to do so by federal, state or local law. For instance, the Provider is obligated to report to public health officials the occurrence of certain communicable diseases, or acts of violence. Additionally, the Provider is required to report certain incidents to the Pennsylvania Department of Public Welfare.
To Avert a Serious Threat to Health or Safety. We may use and disclose protected health information about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. Any disclosure, however, would only be to someone able to help prevent the threat.
Day Providers. We may use and disclose information about you if necessary to facilitate your application for admission to, or use of day programs such as supported employment and sheltered employment.
Residential Facilities. We may use and disclose information about you if necessary to facilitate your application for admission into, or use of residential facilities.
In-Home Services. We may use and disclose information about you if necessary to facilitate your application for, or use of in-home services.
Family Living Arrangements. We may use and disclose information about you if necessary to facilitate your application for admission into, or use of family-living arrangements.
Supports Coordinators. We may use and disclose information about you as necessary for supports coordinators and case managers to complete their duties for you.
Transfers. We may use and disclose information about you to another Provider to which you are being transferred or which is considering you as a transfer.
Employers. We may use and disclose information about you to an employer or prospective employer in connection with your application for, or continuation of employment.
Organ and Tissue Donation. If you are an organ or tissue donor, we may release protected health information to organizations that handle organ procurement or organ, eye or tissue transplantation or to an organ donation bank, as necessary to facilitate organ or tissue donation and transplantation.
Military and Veterans. If you are a member of the armed forces, we may release protected health information about you as required by military command authorities. We may also release protected health information and foreign military personnel to the appropriate foreign military authority.
Workers’ Compensation. We may release protected health information about you for workers’ compensation or similar programs. These programs provide benefits for work-related injuries or illness. Under the privacy regulations, workers’ compensation claims are exempted from coverage, and thus we may release protected health information about you to your employer for workers’ compensation purposes.
Public Health Risks. We may disclose protected health information about you for public health activities. These activities generally include the following:
Health Oversight Activities. We may disclose protected health information to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure. The federal government had determined that it must have access to this information to adequately monitor beneficiary eligibility for government programs (for example, Medicare or Medicaid), compliance with program standards, and/or civil rights laws.
Lawsuits and Disputes. If you are involved in a lawsuit or a dispute, we may disclose protected health information about you in response to a court or administrative order. We may also disclose protected health information about you in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute, but only if appropriate efforts have been made to tell you about the request or to obtain an order protecting the information requested.
Law Enforcement. We may release protected health information if asked to do so by a law enforcement official:
Coroners, Medical Examiners and Funeral Directors. We may release protected health information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death. We may also release protected health information about clients of the Provider to funeral directors as necessary to allow them to carry out their duties.
National Security and Intelligence Activities. We may release protected health information about you to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.
Protective Services for the President and Others. We may disclose protected health information about you to authorized federal officials so they may provide protection to the President, other authorized persons or foreign leads of state or conduct special investigations.
Inmates. If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release protected health information about you to the correctional institution or law enforcement official. This release would be necessary (1) for the institution to provide you with health care; (2) to protect your health and safety or the health and safety of others; or (3) for the safety and security of the correctional institution.
YOUR RIGHTS REGARDING MEDICAL INFORMATION ABOUT YOU
You have the following rights regarding protected health information we maintain about you:
Right to Inspect and Copy. You have the right to inspect and copy protected health information that may be used to make decisions about your care. Usually, this includes medical and billing records, but does not include psychotherapy notes.
To inspect and copy protected health information that may be used to make decisions about you, you must submit your request in writing to the Privacy Officer. If you request a copy of the information, we customarily charge a fee for the costs of copying, mailing or other supplies associated with your request.
We may deny your request to inspect and copy in certain very limited circumstances. If you are denied access to protected health information, you mat request that the denial be reviewed. Another licensed health care professional chosen by the Provider will review your request and the denial. The person conducting the review will not be the person who denied your request. We will comply with the outcome of the review.
Right to Append and Amend. If you feel that protected health information we have about you is incorrect or incomplete, you may ask us to append or amend the information. You have the right to request an amendment for as long as the information is kept by or for the Provider. If we do not agree to amend your information, you may add a supplemental statement to your records indicating why you believe the information should be changed. We will append or otherwise link your statement to your records.
To request an amendment, your request must be made in writing and submitted to the Privacy Officer. In addition, you must provide a reason that supports your request.
We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to amend information that:
Right to an Accounting of Disclosures. You have the right to request an “accounting of disclosures.” This is a list of several types of the disclosures we made of protected health information about you.
To request this list or accounting of disclosures, you must submit your request in writing to the Privacy Officer. Your request must state a time period which may not be longer that six years and may not include dates before April 14, 2003. Your request should indicate in what form you want the list (for example, on paper, electronically). The first list you request within a 12-month period will be free. For additional lists, we may charge you for the costs of providing the list. 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. The Provider will comply with your request within 60 days.
Right to Request Restrictions. You have the right to request a restriction or limitation on the protected health information we use or disclose about you for treatment, payment or health care operations. You also have the right to request a limit on the protected health information we disclose about you to someone who is involved in your care or the payment for your care, like a family member or friend. For example, you could ask that we not use or disclose information about a surgery you had.
We are not required to agree to your request. If we do agree, we will comply with your request unless the information is needed to provide you emergency treatment. To request restrictions, you must make your request in writing to the Privacy Officer. In your request, you must tell us (1) what information you want to limit; (2) whether you want to limit our use, disclosure or both; and (3) to whom you want the limits to apply, for example, disclosures to your spouse.
Right to Request Confidential Communications. You have the right to request that we communicate with you about medical matters in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail.
To request confidential communications, you must make your request in writing to the Privacy Officer. We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.
Right to a Paper Copy of This Notice. You have the 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.
To obtain a paper copy of this notice, please call our Privacy Officer at 412.281.7244.
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 protective health information we already have about you as well as any information we receive in the future. We will post a copy of the current notice at our site. The notice will contain on the first page, in the top right-hand corner, the effective date. In addition, each time you register at or are admitted to the Provider for treatment or health care services as a client, we will offer you a copy of the current notice in effect.
If you believe your privacy rights have been violated, you may file a compliant with the Provider or with the Secretary of the Department of Health and Human Services. To file a complaint with the Provider, contact:
Tina L. Outrich
Vice President of Programs/Services
Easter Seal Society of Western Pennsylvania
2525 Railroad Street,
Pittsburgh, PA 15222
All complaints must be submitted in writing.
You will not be penalized for filing a complaint.
OTHER USES OF PROTECTED HEALTH INFORMATION
Other uses and disclosures of protected health information not covered by this notice or the laws that apply to us will be made only with your written authorization. If you provide us permission to use or disclose protected health 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 protected health information about you for the reasons covered by you 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 provide to you.