NOTICE OF PRIVACY PRACTICES

Voluntary Consent for Treatment
Metro Crisis Services’ Crisis Line considers all incoming phone calls to its Clinical Staff as representing voluntary consent for treatment. All people initiating crisis calls to Metro Crisis Services are considered clients, for the duration of that call, of the mental health and substance abuse professionals employed by Metro Crisis Services.

Protected Health Information
Metro Crisis Services’ Crisis Line creates and archives records of every client contact. These records are protected health information (PHI) which is regulated by the Health Insurance Portability and Accountability Act of 1996 Privacy and Security Rules (HIPAA) and other laws.

Protected health information includes any individually identifiable health information. This means data—such as name, age, gender, address—that is explicitly linked to a particular individual. It also includes health information which reasonably could be expected to allow individual identification.

When we report on our service activities or illustrate our work with “case history”-style descriptions, we use only aggregated or de-identified information; all potentially identifying information has been removed or changed.

In compliance with HIPAA, we protect your health information by:

  • Treating all of your health information that we collect as confidential.
  • Restricting access to your health information only to those MCS Clinical Staff members who need to know your health information in order to provide services to you.
  • Maintaining physical, electronic, and procedural safeguards to comply with federal and state regulations guarding your health information.

Disclosure of PHI with your written authorization
If you make a written authorization to release protected health information, MCS may share information about your contacts with us to healthcare providers that you designate in your authorization, in order to better provide quality treatment for you.

Disclosure of PHI without your written authorization
There are a few situations in which Metro Crisis Services is required or permitted to disclose protected health information without your consent:

  • Abuse—If we have reason to believe that a minor child, elderly person or disabled person has been abused, abandoned, or neglected, Metro Crisis Services must report this concern or observations related to these conditions or circumstances to appropriate authorities.
  • Serious Threat to Health or Safety—If you communicate to Metro Crisis Services an explicit threat of imminent serious physical harm or death to identifiable victim(s), and we believe you may act on the threat, or based on your recent behavior MCS personnel believe that there is a substantial likelihood that you will, in the near future, cause serious physical harm to yourself or another, we have a legal and ethical duty to take the appropriate measures to prevent harm to you or that person(s) including disclosing information to the police and warning the victim.

    If we have reason to believe that you present a serious risk of physical harm or death to yourself, we may need to disclose information in order to protect you. In this situation, we may disclose information to a family member, a friend, a law enforcement officer, or an EMS first responder, as we believe may be required to provide appropriate protection from harm.

    In all cases, we will only disclose what we believe is the minimum amount of information necessary to keep you or the other person(s) safe.

  • Health Oversight Activities—If you have filed a formal complaint against a licensed professional and a licensing authority is investigating the complaint, Metro Crisis Services may be required to disclose protected health information regarding your case.
  • Judicial and Administrative Proceedings—If you are involved in a court proceeding and a court subpoenas information about the professional services you have received from Metro Crisis Services, we may be compelled to provide the information. If you or your representative makes a legal claim against MCS, we may disclose protected health information to defend ourselves.
  • National Security—We may be required to disclose protected health information to authorized federal officials that is required for lawful intelligence, counterintelligence, and other national security activities.
  • Language Translation —If you communicate with us in a language other than English, we may need to use a third party to translate for us.
  • If you are under 15 years old—Under Colorado law, adolescents who are 15 and older may consent to their own treatment without the consent of their parents. People under age 15 require parental consent for treatment. The law allows parents to examine their child’s health records unless a clinical professional decides that this would be likely to injure the child.

Questions or complaints
If you believe that your HIPAA privacy protections have been violated, you have the right to file written complaint with Metro Crisis Services, or with the Department of Health and Human Services, Office of Civil Rights. We will not retaliate against you for filing a complaint.

You may contact our designated Privacy Officer:
Daniel Ward, CEO
dward@metrocrisisservices.org

For more information about HIPAA or to file a complaint:
The U.S. Dept. of Health & Human Services
Office of Civil Rights
200 Independence Avenue, S.W.
Washington, D.C. 20201


Web Privacy Policy and Important Notices

This notice provides Metro Crisis Services' policy regarding the nature, purpose, use and sharing of any information collected via this website. The information you provide on this Metro Crisis Services website will be used only for its intended purpose.

Submitting information to us is strictly voluntary. By doing so, you are giving Metro Crisis Services your permission to use the information for the intended purpose. If you do not want to give Metro Crisis Services permission to use your information, simply do not provide it. Please be aware that if you choose not to provide certain information, Metro Crisis Services may be unable to provide you with the information or services you desire.

Metro Crisis Services never collects information for commercial marketing. Metro Crisis Services complies with CAN-SPAM and never creates individual user profiles or sells your information.

Automatically Collected Information
We collect and temporarily store certain technical information about your website visit for use in website management and community service monitoring. This information may include:

  1. The Internet domain from which you access our Web site (for example, "gmail.com" or "comcast.net. ");
  2. The IP address (a unique number for each computer connected to the Internet) from which you access our Web site;
  3. The type of browser (e.g., Firefox, Internet Explorer, Safari) used to access our site;
  4. The operating system (Windows, Mac) used to access our site;
  5. The date and time you access our site;
  6. The URLs of the pages you visit;
  7. Your username, if you logged in to private sections of our website;
  8. The URL of the forwarding site, if you visited our Metro Crisis Services website through a link from another site.

This information is used to help us make our website and our services more useful for you. We make no attempts to identify individual users or their usage habits. Raw data logs are retained temporarily as required for management purposes only.

Information Collected for Tracking (Cookies)
A cookie is a small file that a website transfers to your computer to allow it to remember specific information about your session while you are connected. Your computer will only share the information in the cookie with the Web site that provided it, and no other Web site can request it. There are two types of cookies, session and persistent. Session cookies last only as long as your Web browser is open. Once you close your browser, the cookie disappears. Persistent cookies store information on your computer for longer periods of time.

The Metro Crisis Services website may use session cookies for technical purposes such as to enable better navigation through the site. You may use your browser to turn off or remove cookies at any time. This may, however, make certain website functions more difficult to use.

At no time is your private information, whether stored in persistent cookies or elsewhere, shared with third parties who have no right to that information. If you do not wish to have session or persistent cookies stored on your machine, you can turn them off in your browser. However, this may affect the functioning of the Metro Crisis Services website.

Personal Information
If you choose to provide us with personal information by completing an online form or sending us an email, we will use that information to respond to your message and to help you get the information or services you have requested.

If you send protected health information (PHI) to us via email, chat, IM, or other electronic methods, we will safeguard that information as described above. Please remember that depending on the way that you connect to the Internet and the way that your messages are routed to us, these communications aren’t necessarily secure during transmission. We are unable to guarantee security of your PHI during transmission.

Some pages of our website may invite you to provide your name, address, or other identifying information on registration forms, surveys, questionnaires, or feedback forms. If you prefer that we not have your identifying information, don’t complete such forms.

Interaction with Children
In compliance with the Children’s Online Privacy Protection Act (COPPA), Metro Crisis Services does not knowingly gather any information online from children under the age of 13. A child under 13 years old may inadvertently provide personal information online through our website. If we discover that this has happened, the information about the child will be deleted immediately.

We collect no information about you or your child other than protected health information described in the previous section. Parents with any concerns related to online information provided by children under age 13 may call us at 888-885-1222 or may contact our organization’s Privacy Officer, listed below.

Website Security Notice
For site security purposes and to ensure that this website remains available to all users, our computer system employs software programs that monitor network traffic to identify unauthorized attempts to upload or change information. Anyone using this system expressly consents to such monitoring and is advised that if such monitoring reveals evidence of possible abuse or criminal activity, such evidence may be provided to appropriate law enforcement officials.

Unauthorized attempts to hack, crack, attack, scrape, download, upload, or change information on Metro Crisis Services servers are strictly prohibited and may be punishable by law, including under the Computer Fraud and Abuse Act of 1986 and the National Information Infrastructure Protection Act of 1996. Metro Crisis Services will vigorously pursue prosecution of any alleged violators.

Accessibility
We want to ensure that our services are accessible to individuals with disabilities and those whose principal language is not English. If you have any difficulty viewing any page on our website with adaptive technology, or need language translation to use the information presented here, please call 888-885-1222 for assistance.

Linking Policy and Disclaimer of Endorsement
This website contains links to other sites that are created and maintained by other organizations and individuals. Metro Crisis Services provides links to these sites as a service to our users. The presence of a link on our website is not a Metro Crisis Services endorsement of the site, the organization, its activities, or its services.

When users follow a link to an outside website, they are leaving the Metro Crisis Services site and are subject to the privacy and security policies of the owners of the outside website. Metro Crisis Services is not responsible for the information collection practices of non-Metro Crisis Services sites.

Metro Crisis Services Privacy Officer
Daniel Ward, CEO
dward@metrocrisisservices.org

Date of publication: September 10, 2010

Copyright © 2010, Metro Crisis Services, Inc., Denver, Colorado USA. All rights reserved.