PRIVACY POLICY
Goldencare Hospice & Palliative Care, Inc., || Last revised: June 2021
We take privacy seriously and this Privacy Policy is intended to describe the personal information Goldencare Hospice & Palliative Care (“Goldencare Hospice & Palliative Care,” “we,” “our,” “us”) collects, including through our website (“Website”); how we use and share it; and rights you may have regarding this information. There are some important exceptions. In particular, much of the personal information Goldencare Hospice & Palliative Care obtains and maintains about individuals is information that we collect and maintain on behalf of our Accountable Care Organizations (“ACOs”), which is covered by the Health Insurance Portability and Accountability Act, or HIPAA (“Client Data”). Client Data is not described in or covered by this Policy. If you are a patient of a practice that participates in one of Goldencare Hospice & Palliative Care’s ACOs, you can find out more about their privacy practices from them. This Policy also does not apply to information we collect about our employees in the employment context and which is governed by different policies. By using the Website and our services, you consent to the terms of this Policy and to our collection, use, and dissemination of your information as described in this Policy.
DISCLOSURE STATEMENT
Goldencare Hospice & Palliative Care is privately owned and operated. Goldencare Hospice & Palliative Care, LLC. allows users to access health related information that is provided to us.
The information provided on the www.choosegoldencare.com website is for general informational purposes only. None of the information we provide on our website constitutes, directly or indirectly, the practice of medicine, the dispensing of our medical services, a professional decision or a treatment plan. You should not rely on the information provided on the www.choosegoldencare.com website as a substitute for personal medical advice or delay in seeking it because of something you read on our website.
Goldencare Hospice & Palliative Care, LLC, does not sell or rent your personally identifiable information to anyone, unless:
1. we have your consent to share the information
2. we respond to subpoenas, court orders, or legal process
3. we find that your actions on our websites violates the Goldencare Hospice & Palliative Care, LLC. Terms of service, or any of our usage guidelines for specific services we provide.
CODE OF RESPONSIBILITY:
We obey all laws and regulations that apply to our organization. This includes Federal, state and local laws and regulations.
- Our team obey all laws, regulations and guidelines that apply to their area of work.
- Our supervisors and managers make sure that all employees receive training in the laws and regulations that apply to their department or unit.
If you have any questions about the laws and regulations that apply, please contact our office.
Fraud, Abuse and The False Claims Act
Our team work hard to ensure that we create accurate and truthful patient bills and submit accurate claims for payment from any payer, including Medicare and Medicaid, commercial insurance, or our patients.
The Federal False Claims Act (31 USC 3729-33) imposes civil penalties on any person or organization for knowingly making a false record or filing a false claim with the government for payment.
“Knowing” can include deliberate or reckless ignorance of facts that make the claim false.
Examples of possible False Claims include someone knowingly billing Medicare for services that were not provided, or for services that were not ordered by a physician, or for services that were provided at sub-standard quality where the government would not pay.
A person who knows a False Claim was filed for payment can file a lawsuit in Federal Court on behalf of the government and, in some cases, receive a reward for bringing original information about a violation to the government’s attention. Penalties for violating the federal False Claims Act can be up to three times the value of the False Claim, plus from $5,500 to $11,000 in fines, per claim.
The False Claims Act protects anyone who files a False Claim lawsuit from being fired, demoted, threatened or harassed by his or her employer for filing the suit.
If a court finds that the employer retaliated, the court can order the employer to re-hire the employee and to pay the employee twice the amount of back pay that is owed, plus interest and attorney’s fees.
Our Corporate Responsibility Program supports compliance with the False claims Act by:
• Monitoring and auditing to prevent or detect errors in coding or billing.
• Educating our team that they are responsible to report any concern(s) about a possible False Claim at a CHP facility via our 3-Step
Reporting Process.
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Keep information about patients, employees and the organization confidential.
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Our team sees a wide range of information that is confidential, sensitive or proprietary. That includes information that we create and own or that is owned by others and provided to us for limited use.
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The information may be in many forms, including paper or electronic records, voice mail or in a person’s memory.
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Giving out this information improperly can harm individuals, our business partners and our organization.
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Our associates must protect this information from being revealed or used without proper approval. They are to use such information only for the benefit of the patient and our organization.
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If you have questions about this principle, talk with your supervisor.
Proprietary Information
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Our team must use, preserve and protect intellectual property. This includes patents, trademarks or copyrights, and programs, software or information owned by other organizations, following the terms of our
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license or other agreement to use the property. We also must use and protect confidential information or data owned by others that is given to us for our use, such as client lists, price lists, contracts or documents,
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following any terms we agreed to when we received the information.
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Our team may not use confidential information that they obtain from competitors in violation of a non-compete agreement, prior employment agreement or other contract.
Standards of Responsible Conduct
Personnel Records And Information
Some jobs require access to other employee’s personnel files or other confidential information. This puts a special obligation on team to make sure this information is used or released only with proper authorization.
Improper access, release, or use of this information can harm our employees, patients and our organizations.
Peer Review Information
Peer review information must be protected, according to Federal and state laws and rules and our organization’s policies. These laws and rules protect this confidential information so that health providers can talk openly and honestly about professional performance. They also protect our organization and our efforts to safeguard this information. If you have questions about which peer review information may be protected, call our office.
Business Communications – Eavesdropping, Wiretapping Or Interception
State and Federal laws regulate wiretapping, eavesdropping and other forms of observing people by electronic means. Our policy is to obey all such laws that apply to our business.
It is against the law to use any electronic, mechanical or other device to monitor, copy or obtain the contents of any telegraph, telephone, facsimile, modem-transmitted email or other communications unless one (or sometimes all) of the parties involved agree to it.
You may violate the law merely by listening in on a conversation, even if you take no notes or make recordings.
Unless you receive approval ahead of time, you must do one of three things if you pick up a phone that is in use by others:
(1) You may listen to the call if you received prior permission to listen from every party to the call;
(2) You must identify yourself at once so that every person on the call knows that you are on the line, or
(3) You must hang up at once.
Gifts, Entertainment And Discounts
We conduct our business fairly. We do not offer, ask for, accept or give gifts, services, improper discounts, kick backs or other things of value to influence the business actions of any supplier, vendor, customer, contractor, government official or other associate. Tell your supervisor about any personal present or monetary receive at any time.
Our employees may not ask for money, rewards, gifts or any other thing of value from patients or their family members, or from contractors (except as approved for charity fund-raising).
Our associates may not accept money or rewards, or a gift that has more than a token value, from patients or their families.
If a patient or family member wishes to give more than a token amount of money as a gift, refer them to our AGENCY (if applicable) or other appropriate office for charitable donations.
Inside Information
Our employees do not use our business information for their personal profit or advantage. They also do not give any such information to anyone for any reason that is unrelated to performing their job duties
Participation On Outside Boards Of Directors
We encourage our associates to take part in the civic and social affairs of their communities. This may include serving on the boards of directors of various charitable. When serving on such boards, remember:
- Obtain your supervisor’s approval before serving on the board of directors of any organization that may have interests that conflict with ours;
- Do not discuss or vote on any matter that might affect the interests of our organization;
- When you speak as a board member, be sure you are not identified as speaking on behalf of our organization, unless you are given permission to do so, and
- Be sure you follow your organization’s policy on payment from outside groups, especially if your board duties require you to perform board work during your regular work hours.
CODE OF RESPONSIBILITY:
HUMAN DIGNITY, RESPECT AND HIGH QUALITY CARE
Maintain an environment where we treat everyone with dignity and respect
and where our hallmark is high quality care.
- Our team treats every person – including those we serve and others – with dignity and respect. We recognize each person’s worth, value and status.
- Our team makes decisions to admit, treat, transfer and discharge based on the medical findings of what is best for each patient, resident or client. Our team does not base decisions on the financial status of the patient, resident, client or the organization.
- Our team understands that patients, residents and clients must have reasonable access to care based on what is best for them. We are dedicated to high quality services.
- Our team will help our patients, residents and clients to manage their pain through appropriate and timely assessments and pain management care.
- Our team understands that patients, residents and clients must be allowed to express grievances or complaints and we will endeavor to resolve any grievances or complaints in a timely manner.
- The responsible physician or other licensed independent practitioner will clearly explain the outcome of any treatment or procedure to our patients, residents or clients, and to their families when appropriate, especially if outcome differs significantly from expected results
WEBSITE USE POLICY
1. Changes and Updates
We reserve the right to amend, alter, or otherwise change this Privacy Policy at our sole and absolute discretion. If we amend this Policy, we will post any changes on this page and update the date at the top; so be sure to check back periodically. Your continued use of the Website after changes have been posted will constitute your acceptance of this Privacy Policy and any changes.
2. Personal Information We Collect and Use
For purposes of this Privacy Policy, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. It does not include deidentified or aggregate information, or public information lawfully available from governmental records.
This section describes the categories of personal information we may have collected about you in the last 12 months, and the categories of personal information we may continue to collect about you. (Please note that the types of personal information listed in each category are examples only; they are not exhaustive.)
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Personal identifiers and contact information, such as name, date of birth, postal and email address, telephone and fax number, National Provider Identifier (“NPI”) number, Group Practice Number, state medical license number, tax identification number, and other unique identifiers
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Internet or other electronic network activity information, such as IP address, device identifiers and other online identifiers, data related to your browser, and browsing and search history
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Demographic information, such as gender, military service, citizenship status and other protected class information that you may choose to provide us to the extent permitted by law
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Commercial and financial information, such as accounts payable information relating to our service providers, vendors, and contractors • Educational, professional, or employment-related information, such as information about where you work and your company’s name, your position, what certifications or degrees you have obtained, or your educational, professional and employment history, and resume information (e.g., from job applicants)
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Audio and visual information, such as the sound of your voice, or your image, if you attended and spoke at a webinar that we hosted or attended an event with us or left us a voicemail
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Location information, as it can be derived from your IP address
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Other information you or others provide us: You may provide us with other personal information in communicating or otherwise interacting with us, such as information about your family and associations
3. Sources From Which We Collect Personal Information
The categories of sources from whom we may collect personal information include the following:
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Information that you or others give to us directly (e.g., by communicating with us, submitting information through our Website, registering for a webinar, or applying for a job with us), from our practices that participate in our ACOs, and from business contacts (e.g., a referral for a job candidate)
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Third party sources, including data collection and aggregation services that, in turn, obtain this data from publicly available sources. We also obtain information from proprietary databases
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Automated collection, such as through website analytic services and cookies
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Our service providers, which includes technology/website hosting providers, analytics providers, and systems administrators
4. Purposes for Which We May Use the Personal Information
We collect each of the categories of personal information above for a variety of purposes, including:
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To contact you, including to respond to your inquiries and questions and to contact you with information about services and promotional or other information that may be of interest to you, to consider you for employment (either at Goldencare Hospice & Palliative Care or to provide that information to a practice that participates in one of our ACOs)
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To operate our business and offer or provide services and products (including client services, events, and information and fulfilling our contractual obligations)
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To identify individuals, practices, or groups that might work with us, and pay you for, or communicate with you about, products or services you provide to us
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To identify potential practices that may want to participate in one of our ACOs
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To understand what information and services you may be interested in
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To offer, maintain, and improve our Website and the services that we provide or make available, including troubleshooting, and to give us insights on how you and other users utilize the Website
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To facilitate marketing or re-marketing our services to you, including to track and associate Internet search and browsing behavior with our advertisements
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For statistical, analytical, and business operations and planning purposes
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To satisfy legal and regulatory requirements, protect health and safety, defend our legal interests, or to respond to valid legal requests
5. Categories of Entities with Which We Share Personal Information.
In the last 12 months, we may have disclosed each of the categories of personal information above with third parties for a business purpose and may continue to do so. The categories of third parties with which we share personal information include:
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Service providers, such as information technology providers, website analytics and cookie providers, recruiting and hiring vendors and other contractors (e.g. we use Lever to assist with our employee recruitment and hiring process. You can review Lever’s privacy policy at https://www.lever.co/privacy-policy)
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Practices that participate in our ACOs and other business contacts (Please note that this Privacy Policy does not apply to the use of information by Goldencare Hospice & Palliative’s participating practices)
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Law enforcement, governmental authorities, or other third-parties as required by law, in response to legal requests, to protect our rights and interests, or for the protection of others
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Third parties who may acquire all or part of our business or assets or act as successors in interest to our business or to whom we transfer any of our rights or obligations
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As described to you when collecting the information
By using our Website or our services, you agree that, in the event of a transfer such as a merger, acquisition, or sale of assets, your personal information and any other assets may continue to be used by the acquirer or its successors in a manner consistent with this Policy.
6. Marketing, Cookies, and Analytics
Website Analytics: We use Google Analytics and other cookies and similar technologies to evaluate the use of our Website. Google Analytics’ data practices are governed by the Google Analytics Terms of Service and the Google Privacy Policy, as they may be amended from time to time. For more information about Google Analytics and the information it collects, you can visit Google Analytics’ policies here. You can view the Google Analytics’ Opt-Out Browser Add-On here. We also use Pardot to learn more about how you use the Website. Pardot sets a cookie on your browser to remember your preferences when you return to our site; these cookies store a unique identifier. To learn more about the cookies that Pardot sets, you can visit Pardot’s website here.
Marketing: We may use data collected from our Website to make you personalized offers relating to our products and services on our site or on third-party sites that you visit (e.g., Facebook, Twitter, and LinkedIn) through the use of cookies in conjunction with other parties. We also deploy a pixel from AdRoll to track your behavior on our site and facilitate re-marketing of our products and services on other third-party sites that you visit later. For a list of third-party sites where we may re-market our product and services to you via the AdRoll pixel, please click here. For information about AdRoll’s California Consumer Privacy Act (“CCPA”) disclosures, please click here. If you are interested in learning more about online behavioral advertising, and your ability to opt out of this type of advertising, sometimes called interest-based advertising, we encourage you to visit one of the advertising industry-developed opt-out pages, such as https://youradchoices.com/ or http://www.aboutads.info/. Please note that while we provide these links for your convenience, these are third-party sites that we do not control (see below).
7. How We Protect Personal Information. While we implement reasonable security measures to help safeguard your data, no security system is impenetrable. We cannot and do not guarantee the security of our servers or databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. Please use caution any time you provide information over the Internet.
8. Children under 18. The Website is not designed for, directed to, or intended to be used by children under the age of 18. If we obtain actual knowledge that a child under the age of 18 is using the Website, we will take steps to delete such information as soon as possible.
9. Do-Not-Track Requests. Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. We currently do not take action in response to these signals.
10. Third-Party Links. Our Website may contain third-party content and links to websites operated by third parties over which we have no control. We are not responsible for the content or security of third-party websites. Such third-party content and links are included solely for your convenience and do not constitute Goldencare Hospice & Palliative Care’s approval, endorsement or warranty of any third-party website or content. We are not responsible for the accuracy, completeness or reliability of the information, products or services offered or sold through any linked websites. You use them at your own risk. Should you click on a link to a third-party website, the privacy policy of that website will apply instead of our Privacy Policy. We recommend you review that website’s privacy policy and terms of use before using them
11. Your Rights in Relation to the Personal Information We Hold About You
A. Your Email Address. One of the elements of personal information that you may provide is your email address. You may stop receiving emails from us by selecting the “unsubscribe” link included in all commercial emails you receive from us.
B. For California Users. Under California Civil Code section 1798.83, California residents may request information regarding the types of personally identifiable information we share with third parties for direct marketing purposes, and the identities of the third parties with whom we have shared such information during the immediately preceding calendar year. We do not provide personal information to third parties for their direct marketing purposes.
C. Additional Rights for California Residents Under the CCPA. Because Goldencare Hospice & Palliative Care operates as a business associate to other entities under the Health Insurance Portability and Accountability Act with respect to most of the personal information it holds, only limited categories of the personal information Goldencare Hospice & Palliative Care maintains may be subject to the CCPA. In addition, at this time, the CCPA includes exemptions for certain information processed exclusively in the business-to business context (e.g., information about an individual acting in his or her capacity as an employee of an entity providing or receiving a service from the relevant business). If you are a California resident whose information is covered by the CCPA, you may have the rights described in this section of this Privacy Policy.
Right to request disclosure of information we collect and share about you
Individuals whose personal information is covered by the CCPA have a right to request that Goldencare Hospice & Palliative Care provide the following information:
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The categories of personal information Goldencare Hospice & Palliative Care collected about you
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The categories of sources from which Goldencare Hospice & Palliative Care collected the personal information
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The business or commercial purposes for which Goldencare Hospice & Palliative Care collected and/or sold the personal information
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The categories of third parties with which Goldencare Hospice & Palliative Care shared the personal information
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The specific pieces of personal information Goldencare Hospice & Palliative Care collected over the past 12 months
You can also submit a request to us for the following information:
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The categories of personal information, if any, Goldencare Hospice & Palliative Care has sold about you, categories of third parties to which Goldencare Hospice & Palliative Care sold that personal information and the categories of personal information sold to each type of third party
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The categories of personal information that Goldencare Hospice & Palliative Care has disclosed for a business purpose
Right to request the deletion of personal information we have collected from you
You also have the right to request the deletion of personal information we have collected. After receiving and appropriately verifying a request to delete your information, we will delete the personal information we have collected about you, except for situations where specific information is necessary for us to: provide you with a good or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law. We may also retain information where another exception to the deletion requirements in California Civil Code § 1798.105(d) applies. In addition, the law permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us.
Sales of personal information : We do not sell personal information.
How to exercise your rights
To exercise your right to request the disclosure of your personal information that we collect or share, or to ask us to delete your information, either email us at ccpa@choosegoldencare.com or contact us at 855-655-0500. Depending on the nature of your request, we may ask you for additional information to verify your request and identity and a declaration attesting to your identity, signed under penalty of perjury, as described more fully below. We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations.
Our process for responding to CCPA requests
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Requests for Specific Pieces of Personal Information: If you submit such a request, we may ask you for three pieces of personal information for verification purposes. Additionally, we may also ask you for a declaration attesting to your identity, signed under penalty of perjury.
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Requests for Categories of Personal Information: If you submit such a request, we may ask you for at least two pieces of personal information for verification purposes.
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Requests for Deletion of Personal Information: If you submit such a request, we may ask you for at least two pieces of personal information for verification purposes.
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Requests for Household Information: There may be some types of personal information that can be associated with a household. Requests for access or deletion of household personal information must be made by each member of the household.
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Denials: If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. In that case, or if we are denying your request for another reason, including because we serve as a service provider to another entity to which your request should be submitted, we will notify you.
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Timing: We will respond to requests for access or deletion as soon as practicable and, in any event, generally not more than within 45 days after receipt of your request. We may extend this period to 90 days in some cases.
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Designating an Agent: Please note that you may designate an agent to submit requests on your behalf. The agent can be a natural person or a business entity that is registered with the California Secretary of State. If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our agent verification process. Please contact us at ccpa@choosegoldencare.com or 855-655-0500 for more information.
We are committed to honoring your rights
We are committed to complying with the law. If you exercise any of the rights explained in this policy, we will continue to treat you fairly. Consistent with California Civil Code § 1798.125, we will not discriminate against you because you exercised any of your CCPA rights, including by denying you goods or services, charging different prices or rates for goods or services, providing a different level or quality of goods or services, or suggesting that you will receive a different price or rate or level or quality for goods or services.
Accessibility
We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests, please contact us toll free at 855-655-0500 or send an email to disabilityaccess@choosegoldencare.com.
12. International Users
Our Website is hosted in the United States and is intended for access and use by individuals located in the United States only. By using our Website or our products and services, you consent to the transfer of your personal information to the United States as described in this Privacy Policy. Please do not use the Website, our products, or our services if you do not agree to the transfer and processing of your personal information in the United States or if it is illegal to do so in your home country.
13. Contacting Us
If you have questions on the processing of your personal information, would like to exercise any of your rights, or are unhappy with how we’ve handled your information, please contact us here: Privacy Officer or email us at ccpa@choosegoldencare.com.
If you would like to assert your privacy rights, you may also call us toll free at 855-655-0500 or submit a request via email at ccpa@choosegoldencare.com.