Snoasis Medical Privacy Policy
This policy describes how we may use and disclose protected health information. Protected health information means any health information about a patient that identifies a patient or that could be used to identify a patient. In this policy, we call protected health information “medical information.” This policy also explains patients’ rights and our duties with respect to medical information about patients. In addition, it explains how patients can complain if they believe we have violated their privacy rights.
Who Will Follow This Policy
This policy describes how Snoasis Medical, Inc., and its agents and employees (collectively, the “Company”, “Snoasis” or “we”), use and disclose a patient’s medical information.
Our Pledge Regarding Medical Information
Snoasis understands that medical information about a patient’s health is personal. We are committed to protecting their medical information. Snoasis products are provided to licensed dental clinicians. Through the course of doing business, such as conversations between a patient and Snoasis or enrolling a patient in a Snoasis-sponsored research study, Snoasis is required by law to:
- Make sure that medical information identifying a patient is kept private, unless written consent for use of identifiable information is given by patient; and
- Follow the terms of the privacy policy that is currently in effect.
How We May Use and Disclose Medical Information About a Patient Without a Patient’s Prior Written Consent
The following categories describe different ways that we use and disclose a patient’s medical information. Not every use or disclosure in a category will be listed. All of the ways we are permitted to use and disclose information will fall into one of the categories. In general, and except as provided for below, we will not communicate with a patient directly and will only communicate with the treating clinician. However, since our responsibilities also apply to the patient, it is important we recognize those responsibilities and limitations.
Patient Inquires
Snoasis does engage in marketing activities directed at patients and potential patients. In addition to providing information to patients, Snoasis helps patients find a clinician who offer Snoasis products as a treatment option. These requests could be by phone, e-mail, or mail. In all cases, Snoasis will work in good faith, resources permitting, to help patients. Follow-up efforts may include sending the patients contact information to a clinician.
Website Registration
To use Snoasis Medical’s website applications and to access downloads found on the website, registration may be required. Registration information is stored on a secure database; accessible only to Snoasis. Each patient profile contains private, personal information.
Snoasis Sponsored Research
Snoasis intends to document the clinical use of its products. Part of this includes recruiting patients from the general public. In some cases, prospective patients may first contact Snoasis. Snoasis performs an initial evaluation to determine study eligibility. In some cases, Snoasis may interview the prospective patient in order to further determine study eligibility before moving forward with an evaluation performed by a licensed dental clinician. In the process of screening patients, Snoasis collects personal and confidential information.
Required by Law
We may use or disclose medical information about a patient when we are required to do so by federal, state or local law.
Health Oversight Activities
We may disclose medical information to a health oversight agency for activities authorized by law. These activities are necessary for the government to monitor the health care system, government programs, our compliance with civil rights laws, and to make sure we are complying with various government regulations. For example, the Food & Drug Administration requests a review of patient records.
Judicial and Administrative Proceedings, Lawsuits and Disputes
We may disclose medical information about a patient in the course of any judicial or administrative proceeding in response to an order of the court or administrative tribunal. We may also disclose medical information about a patient in response to a subpoena, discovery request, or other legal process; but only if efforts have been made to tell the patient about the request or to obtain an order protecting the information from being disclosed.
Law Enforcement
We may release medical information if required to do so by a law enforcement official; In response to a court, grand jury or administrative order, a subpoena, a warrant, a summons or similar process; To identify or locate a suspect, fugitive, material witness, or missing person; About an actual or suspected victim of a crime and that person agrees to the disclosure. If we are unable to obtain that person’s agreement, in limited circumstances, the information may still be disclosed; About a death we believe may be the result of criminal conduct; About criminal conduct at any of our facilities; In emergency circumstances to report a crime; the location of the crime or victims; or the identity, description or location of the person who committed the crime; or, As required by law.
To Avert A Serious Threat to Health or Safety
We may use or disclose medical information about a patient if we believe the use or disclosure is necessary to prevent or lessen a serious or imminent threat to the health or safety of a person or the public. Any disclosure would only be to a person(s) able to help prevent the threat. We also may release information about a patient if we believe that disclosure is necessary for law enforcement authorities to identify or apprehend an individual who has admitted participation in a violent crime or who is an escapee from a correctional institution or from lawful custody.
National Security and Intelligence
We may disclose medical information about a patient to authorized federal officials for the conduct of intelligence, counter-intelligence, and other national security activities authorized by law.
Food and Drug Administration (FDA)
We may disclose to the FDA health information relative to adverse events with respect to Snoasis products.
Other Uses and Disclosures
Other uses and disclosures of medical information not covered by this policy or the laws that apply to us will be made only with the patient’s written permission. If a patient provides us with permission to use or disclose medical information about the said patient, for example, for use in a video testimonial, the patient may revoke that permission, except to the extent where disclosures have already been made, in writing, at any time by writing to the Vice President of Operations, Snoasis Medical, Inc., 535 16th Street, Suite 320, Denver, CO 80202 (the “Privacy Officer”).
Patient’s Rights With Respect to Medical Information About Such Patient
Right to Inspect and Copy
The patient has the right to inspect or copy personal and confidential information about said patient held by Snoasis. To do so, they should make a request in writing to the Vice President of Operations, Snoasis Medical, Inc., 535 16th Street, Suite 320, Denver, CO 80202. We may deny the request to inspect and copy medical information if the medical information involved is: Information compiled in anticipation of, or use in, a civil, criminal or administrative action or proceeding; If we deny the patient’s request, we will inform the patient of the basis for the denial, how the patient may have our denial reviewed, and how the patient may complain. If the patient requests a review of our denial, it will be conducted by a licensed health care professional designated by us, who was not directly involved in the denial. We will comply with the outcome of that review.
Right to Copy of this Policy
A patient has the right to obtain a paper copy of our Privacy Policy.
Our Right to Change Our of Privacy Practices
We reserve the right to change this policy. We reserve the right to make the revised or changed policy effective for medical information we already have about a patient as well as any information we receive in the future.
Complaints
A patient may make a complait to us or to the United States Secretary of Health and Human Services if the patient believes we have violated their privacy rights. These complaints must be in writing and must be filed within 180 days of when the patient learned of, or should have known about the violation. To make a complait to the Secretary of the Department of Health and Human Services contact: Region VIII, Office for Civil Rights, U.S. Department of Health and Human Services, 1961 Stout Street – Room 1185 FOB, Denver, CO 80294-3538. Fax: (303) 844-2025.
A patient will not be retaliated against or penalized for filing a complaint. In this situation we will not take action against a patient.
Questions and Information
If a patient has any questions or wants more information concerning this Privacy Policy, please contact Vice President of Operations, Snoasis Medical, Inc., 535 16th Street, Suite 320, Denver, CO 80202.