1. Our Privacy Obligations

We are required by law to maintain the privacy of medical and health information about you and inform you about our privacy policy with respect to Protected Health Information (PHI). “Protected Health Information” generally includes individually identifiable information about your past, present, or future physical or mental health, the health care you have received, or payment for your health care.

2. Uses and Disclosures without Your Authorization

1. Use and/or Disclosure for Treatment, Payment and Health Care Operations. We may use and/or disclose Protected Health Information without your authorization for certain treatment provided to you, for certain payment purposes, and for certain health care operations as detailed below.
   1. For treatment purposes. Your Protected Health Information will be used to provide you with health care. We will disclose your Protected Health Information to personnel who provide you with health care services or are involved in your care. For example, if you’re being given home care, we may disclose your Protected Health Information to a nurse in order to coordinate your care.
   2. For health care operations. We may use and disclose your Protected Health Information in order perform support functions necessary for the operation of MedicALL. This includes, but is not limited to, quality improvement, case management, receiving and responding to patient comments and complaints, physician reviews, compliance programs and audits.
   3. Using your Protected Health Information to contact you. We may access your Protected Health Information in order to 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.
2. Disclosure to Family, Friends, or Others. We may provide your Protected Health Information to a family member, friend, or any other person you indicate that is either involved in your care or the payment for your health care, unless you object in whole or in part. If your opportunity to agree or object cannot practicably be provided because of an emergency situation, we may disclose your PHI to such a person (but only to the extent that the Protected Health Information is directly relevant to that person’s involvement with your health care) if we determine that the disclosure is in your best interests.
3. Public Health Activities. We may disclose Protected Health Information for the following public health activities and purposes: (1) to report health information to public health authorities for the purpose of preventing or controlling disease, injury or disability; (2) to report child abuse and neglect to public health authorities or other government authorities authorized by law to receive such reports; (3) to report information about products under the jurisdiction of the Ghana Food and Drug Administration; (4) to alert a person who may have been exposed to a communicable disease or may otherwise be at risk of contracting or spreading a disease or condition; and (5) to report information to your employer as required under laws addressing work-related illnesses and injuries or workplace medical surveillance.
4. Judicial and Administrative Proceedings. We may disclose Protected Health Information in response to a legal order or other lawful process.
5. Law Enforcement Officials. We may disclose Protected Health Information to law enforcement officials in compliance with a court order
6. Coroners, and Medical Examiners. We may disclose Protected Health Information to a coroner or medical examiner as authorized by law. Such disclosures may be necessary to identify a deceased person or determine cause of death.
7. Health or Safety. We may use or disclose Protected Health Information to prevent or lessen a serious and imminent threat to a person’s or the public’s health or safety.
8. Inmates. If you are an inmate of a correctional institution or under custody of law enforcement, we may (under certain specific circumstances) release health information about you to the correctional facility or law enforcement official.

3. Uses and Disclosures With Your Authorization

1. Use or Disclosure with Your Authorization. Except as indicated in Section II above, we may use or disclose Protected Health Information only when you give us your authorization. Further, you may revoke your authorization, except to the extent that we have taken action in reliance upon it, by delivering a written revocation statement to the Chief Administrator.
2. Genetic Information. Except in certain cases (such as a paternity test for a court proceeding, anonymous research, newborn screening requirements, or pursuant to a court order), we will obtain your authorization prior to obtaining or retaining your genetic information (for example, your DNA sample).
3. AIDS or HIV Related Information. If Protected Health Information contains AIDS or HIV- related information, that information is confidential and shall not be disclosed without your authorization, except as follows. Such information may be released without your authorization to medical personnel directly involved in your medical treatment. If you are deemed to lack decision-making capacity, we may release such information (only if necessary and unless you request otherwise) to the person responsible for making health care decisions on your behalf (spouse, primary caretaking partner, an appropriate family member, etc.). Under certain circumstances, such information may also be released without your authorization for scientific research, certain audit and management functions, and as may otherwise be allowed or required by law or court order.
4. Marketing Communications. We will obtain your authorization for the use or disclosure of your Protected Health Information for marketing purposes. However, this does not apply to communications that are made: (1) face-to-face by our staff to you; (2) to describe a health-related product or service that is offered by us; (3) for your treatment; or (4) for your care management or to direct or recommend alternative treatments, health care providers, etc.

4. Your Rights

1. For Further Information, Complaints. If you desire further information about your privacy rights, and are concerned that we have violated your privacy rights, you may contact our Chief Administrator. We will not retaliate against you if you file a complaint with us.
2. Right to Request Additional Restrictions. You may request restrictions on our use and disclosure of Protected Health Information: (1) for treatment, payment and health care operations; (2) to individuals (such as a family member, other relative, close personal friend or any other person identified by you) involved with your care or with payment related to your care; or (3) to notify or assist in the notification of such individuals regarding your location and general condition. While we will consider all requests for additional restrictions carefully, we are not required to agree to a requested restriction.
3. Right to Receive Confidential Communications. You may request, and we will accommodate, any reasonable written request for you to receive confidential communications of Protected Health Information by alternative means.
4. Right to Amend Your Records. You have the right to request that we amend Protected Health Information maintained in your medical record file or billing records. We will comply with your request unless we believe that the information that would be amended is accurate and complete or other special circumstances apply.
5. Right to Notification of Security Breach. In the event that there is a security breach of your Protected Health Information, you have the right to be notified by MedicALL.