This notice describes how personal information about you may be used and disclosed and how you can get access to this information. Please review it carefully.

This Notice is effective as of: March 8, 2021

Inspera Health and its affiliated network providers located in and outside of the United States respect confidentiality and only release personal information about you in accordance with federal and state laws. While Inspera Health does not treat any health conditions or otherwise provide medical treatment. All care decisions are between you and your health care providers. However, the personal information covered by this Privacy Notice may include your health or healthcare information.

This notice describes our policies related to the use of the records of your participation in our program generated by Inspera Health. With some exceptions, we use or disclose only portions of your personal information that are necessary to satisfy the need for which the information is being used or disclosed.

Privacy Contact. If you have any questions about this policy or your rights, please contact the Inspera Health Privacy Officer at privacy@insperahealth.com.

In order to effectively operate our program (in which you have voluntarily enrolled), there are times when we will need to share your personal information with others beyond our organization for various purposes. This includes:

• Services. We may use or disclose personal information (including condition specific information) about you to provide, coordinate, or manage your participation in our program or any related services. This may include sharing information with others inside and outside our organization that we are consulting with or referring you to, such as, but not limited to, Biometric Wellness Screening, Health Risk Assessments, Self-Reported Health Surveys, Fitness, Massage, Behavioral Counseling, Nutrition Counseling, and Health Coach professionals.
• Payment. Information will be used to obtain payment for the program’s operation and services or for billing purposes, if warranted.
• Healthcare Operations. We may use information about you to coordinate our business activities. This may include setting up your appointments; training staff; conducting quality assessment and improvement activities; performing licensing, accreditation, or certification activities; and conducting or arranging for auditing functions, including fraud and abuse detection.

Under Illinois and federal law, information about you may be disclosed without your consent in the following circumstances:

• Follow-Up Appointments/Support. We will be contacting you to remind you of future appointments or information about program alternatives or other health-related benefits and services that may be of interest to you.
• As Required by Law. This would include situations where we are required to disclose personal (including healthcare) information under federal, state or local law.
• Disclosure for Judicial or Administrative Purposes. In certain circumstances we may disclose information in response to a lawful court or administrative order, subpoena or other legal process.
• Governmental Requirements. We may disclose information to a health oversight agency for activities authorized by law, such as audits, investigations, inspections, and licensure. We are also required to share information, if requested with the Department of Health and Human Services, to determine our compliance with federal laws related to health care.
• Law Enforcement Purposes. In certain circumstances we may disclose information to police or other law enforcement officials as required by law.
• Health Care Operations. Inspera Health is allowed to disclose your personal (including health) information to its “business associates,” meaning individuals or companies that provide services to Inspera Health.  This includes billing companies, software vendors, attorneys, and other service providers. Inspera Health requires that all business associates comply with the requirements of HIPAA and appropriately safeguard your information.
• De-Identified Information. We may disclose personal (including health) information that does not identify a specific individual and with respect to which there is no reasonable basis to believe that the information can be used to identify an individual.
• Workers Compensation. We may disclose information as authorized by and to the extent necessary to comply with state law regarding workers compensation or similar programs.
• For Public Health Purposes. We may disclose information for public health purposes, such as for reporting, investigation or surveillance of contagious diseases or in response to notices from the federal Food and Drug Administration regarding drugs or medical devices.
• For Health Oversight Activities. We may disclose information for oversight activities, such as for licensing, audits by Medicare or Medicaid, and for investigations of possible violations of healthcare laws.
• For Health Related Research. We may disclose information for health related research that has been approved by an Institutional Review Board or its equivalent.
• To Prevent a Serious Threat to Health or Safety.
• To Business Associates. We may disclose information to Business Associates who perform health care operations for us who have agreed to comply with applicable privacy and security laws.

You have the following rights under state and federal law:

• Copy of Record. You are entitled to inspect the program record we have generated about you. We may charge you a reasonable fee for copying and mailing your record.
• Confidential Methods of Communication. You have the right to receive communications in a confidential manner.
• Alternative Method of Communication. You have the right to receive this Notice electronically and to receive information by alternative means of communication or at alternate locations.
• Release of Records. You may consent in writing to release your program records to others for any purpose you choose. This could include your attorney, employer, or others who you wish to have knowledge of your participation in the program. You may revoke this consent at any time, but only to the extent no action has been taken following your prior authorization.
• Restriction on Record. You may ask us not to use or disclose part of the personal information. This request must be in writing. Inspera Health is not required to agree to your request if we believe it is in your best interest to permit use and disclosure of the information. The request should be submitted to Inspera Health’s Privacy Officer at privacy@insperahealth.com.
• Contacting You. You may request that we send information to another address or by alternative means. We will honor such request as long as it is reasonable, and we are assured it is correct. You are entitled to a paper copy of this privacy notice if you request it.
• Highly Confidential Information. Federal and state law may require that special privacy protection be given to certain personal (including health) information about you including AIDS/HIV records, Alcohol and Drug Abuse Treatment Program information, as well as mental health information. If such information about you is requested, your written authorization is required before it can be disclosed. You will be notified when your written authorization is required.
• Amending Record. If you believe that something in your record is incorrect or incomplete, you may request we amend it. To do this, contact Inspera Health’s Privacy Officer at privacy@insperahealth.com and request an amendment to your health information. In certain cases, we may deny your request. If we deny your request for an amendment, you have a right to file a statement that you disagree with us. We will then file our response, and your statement and our response will be added to your record.
• Accounting for Disclosures. You may request an accounting of any disclosures we have made related to your personal information (except for information we used for services, payment, or health care operations purposes), information that we shared with you or your family, or information that you gave us specific consent to release (including, but not limited, to information released pursuant to a properly executed Authorization). It also excludes information we were required by law to release.
• Notice of Disclosure of Prohibited Health Information. You will be notified when prohibited health information about you has been improperly disclosed.
• Questions. If you have any questions, would like a copy of this Policy, or have any concerns you would like to discuss, please contact Inspera Health’s Privacy Officer at privacy@insperahealth.com.
• Complaints. If you believe that Inspera Health has violated your privacy rights, or you disagree with any action we have taken with regard to your personal information, you may file a complaint with Inspera Health or contact the Secretary of Health and Human Services.  We will not retaliate against you for filing a complaint.
• Revocation of Authorization. You may revoke your authorization, except to the extent we have taken action following your prior authorization, by delivering a written notification to us.
• Changes in Policy. Inspera Health is required to abide by the Notice in effect and reserves the right to change its Privacy Policy based on the needs of our business and changes in state and federal law.