Privacy Policy

Privacy Policy

 

Purpose

The following privacy policy is adopted to ensure that Core Mobile, Inc. (the Company) complies fully with all federal and state privacy protection laws and regulations. Protection of patient privacy is of paramount importance to this organization. Violations of any of these provisions will result in severe disciplinary action including termination of employment and possible referral for criminal prosecution.

 

Effective Date

This policy is in effect and is updated as of August 15, 2015.

 

It is the policy of the Company to adopt, maintain and comply with our privacy practices of customer and end-user data, which shall be consistent with HIPAA and California law.

 

Notice of Privacy Practices

It is the policy of the Company that a notice of our privacy policy be published on our website, and that all uses and disclosures of protected health information be done in accord with the Company’s privacy policy and practices.

 

Assigning Privacy and Security Responsibilities

It is the policy of the Company that specific individuals within our workforce are assigned the responsibility of implementing and maintaining this HIPAA Privacy Policy. Furthermore, it is the policy of the Company that these individuals will be provided sufficient resources and authority to fulfill their responsibilities.

 

Deceased Individuals

It is the policy of the Company that privacy protections extend to information concerning deceased individuals.

 

User Activity Information

Apple Health kit integration is used by the app to provide number of steps walked, heart rate and steps climbed by users in the app and communicated to physician treating the patient when patient provides the consent to provider. All the information is anonymized in our system for HIPAA compliance. The system is HIPAA and FISMA certified by the US Federal Government.

 

Minimum Necessary Use and Disclosure of Protected Health Information

It is the policy of the Company that for all routine and recurring uses and disclosures of PHI (except for uses or disclosures made 1) to or as authorized by the customer, client or end-user or 2) as required by law for HIPAA compliance such uses and disclosures of protected health information must be limited to the minimum amount of information needed to accomplish the purpose of the use or disclosure. It is also the policy of the Company that non-routine uses and disclosures will be handled pursuant to established criteria. It is also the policy of the Company that all requests for protected health information (except as specified above) must be limited to the minimum amount of information needed to accomplish the purpose of the request.

 

Marketing Activities

It is the policy of the Company that any uses or disclosures of protected health information for marketing activities will be done only after a valid authorization is in effect.

 

Prohibited Activities

No Retaliation or IntimidationIt is the policy of the Company that no employee or contractor may engage in any intimidating or retaliatory acts against persons who file complaints or otherwise exercise their rights under HIPAA regulations. It is also the policy of the Company that no employee or contractor may condition payment on the provision of an authorization to disclose protected health information except as expressly authorized under federal and state regulations.

 

Responsibility

It is the policy of the Company that the responsibility for designing and implementing procedures to implement this policy lies with the Privacy Official.

 

Verification of Identity

It is the policy of the Company that the identity of all persons who request access to protected health information be verified before such access is granted.

 

Mitigation

It is the policy of the Company that the effects of any unauthorized use or disclosure of protected health information be mitigated to the extent possible.

 

Safeguards

It is the policy of the Company that appropriate physical safeguards will be in place to reasonably safeguard protected health information from any intentional or unintentional use or disclosure that is in violation of the HIPAA Privacy Rule.

 

Material Change

It is the policy of the Company that the term “material change” for the purposes of these policies is any change in our HIPAA compliance activities.

 

Sanctions

It is the policy of the Company that sanctions will be in effect for any member of the workforce who intentionally or unintentionally violates any of these policies or any procedures related to the fulfillment of these policies. Such sanctions will be recorded in the individual’s personnel file.

 

Retention of Records

It is the policy of the Company that the HIPAA Privacy Rule records retention requirement of six years will be strictly adhered to. All records designated by HIPAA in this retention requirement will be maintained in a manner that allows for access within a reasonable period of time. This records retention time requirement may be extended at this Company’s discretion to meet with other governmental regulations or those requirements imposed by our professional liability carrier.

 

Regulatory Currency

It is the policy of the Company to remain current in our compliance program with HIPAA regulations.

 

Cooperation with Privacy Oversight Authorities

It is the policy of the Company that oversight agencies such as the Office for Civil Rights of the Department of Health and Human Services be given full support and cooperation in their efforts to ensure the protection of health information within this Company. It is also the policy of the Company that all personnel must cooperate fully with all privacy compliance reviews and investigations.

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