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Circle Care Center
Notice of Privacy Practices

 

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

 

Effective: February 16, 2026

Replaces Notice Effective January 1, 2026

 

Circle Care Center

618 West Avenue

Norwalk, CT 06850

circlecarecenter.org

 

Privacy Officer: Taylor Edelmann

Phone: 203-852-9525 x327

Email: tedelmann@circlecare.org

 

Purpose

Circle Care Center respects your privacy. We are also legally required to maintain the privacy of your Protected Health Information (“PHI”) under the Health Insurance Portability and Accountability Act (“HIPAA”) and other federal and state laws.

This Notice of Privacy Practices (this “Notice”) is not an authorization. This Notice describes:

  • Our legal duties and privacy practices regarding your PHI, including our duty to notify you following a data breach of your unsecured PHI.
  • Our permitted uses and disclosures of your PHI.
  • Your rights regarding your PHI

 

Our Responsibilities

We create and maintain a record of the care and services you receive to provide your care and to comply with legal requirements. We will make reasonable efforts to use, disclose, and request only the minimum necessary PHI to accomplish the intended purpose.

 

Important Notice Regarding Redisclosure: Protected health information that we disclose pursuant to this Notice may be subject to redisclosure by the recipient and may no longer be protected by federal privacy laws or this Notice.

We are required to abide by the terms of this Notice currently in effect. We reserve the right to change the terms of this Notice at any time, and any changes will be effective for all PHI and SUD Records we maintain, including information created or received before the changes are made. If we make a material change to this Notice, we will: (1) post the revised Notice on our website at circlecarecenter.org; (2) make the revised Notice available in our office; and (3) provide the revised Notice to you upon request. We will also make reasonable efforts to provide you with a copy of the revised Notice at the time of your next visit to our facility or by mail or electronic means if you have requested such communications. The effective date of each version of the Notice will be clearly displayed at the beginning of the Notice.

 

Uses and Disclosures Your PHI Without Your Authorization

Uses and Disclosures for Treatment, Billing and Payment, and Healthcare Operations

  • Treatment. We may use or disclose your PHI and share it with other professionals who are treating you, including doctors, nurses or other personnel involved in your care. For example, your PHI may be provided to a physician to whom you have been referred to ensure that the physician has the necessary information to diagnose or treat you.
  • Billing and payment. We may use and disclose your PHI to bill and get payment from health plans or others. In some cases, we may share information about you with your health insurance company to determine whether it will cover your treatment.
  • Running our organization. We may use and disclose your PHI to run our practice, improve your care, and contact you when necessary. For example, we may use your PHI to manage the services and treatment you receive or to monitor the quality of our health care services.
  • Appointment reminders and health-related communications. We may use or disclose your PHI, as necessary, to contact you to remind you of appointments and to tell you about treatment alternatives or health-related benefits and services that may be of interest to you.

Other Uses and Disclosures

We may share your information in other ways, usually for public health or research purposes or to contribute to the public good. For more information on permitted uses and disclosures, see www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html. For example, these other uses and disclosures may involve:

    • Friends and family involved in your care. If you do not object, we may share your PHI with a family member, friend, relative, or close personal friend who is involved in your care or payment for your care, including following your death. If you are not able to tell us your preference, we may share information if we believe it is in your best interest. Parents and guardians will generally have the right to control the privacy of health information about minors unless the minors are permitted by law to act on their own behalf.
    • Business associates and subcontractors. We may disclose your PHI to contractors, agents, and other business associates (“Business Associates”) (and their subcontractors) who perform services for us, such as billing, legal, auditing, or IT services. The law requires our Business Associates and their subcontractors to protect your PHI in the same way we do. We also contractually require these parties to use and disclose your PHI only as permitted and to appropriately safeguard your PHI.
    • Incidental disclosures. Reasonable safeguards are used to protect your privacy, but certain incidental disclosures may occur as an unavoidable result of permissible uses or disclosures. For example, during the course of a treatment session, other patients in the treatment area may see or overhear discussion of your health information.
    • Public health and safety activities. We may disclose PHI for public health reporting; to prevent disease; to report injuries, births, and deaths; to report adverse medication reactions or medical device product defects; to report suspected child abuse or neglect, or domestic violence; and to avert a serious and imminent threat to public health or safety.
    • Complying with the law. For example, we will share your PHI if the Department of Health and Human Services requires it during investigations into our compliance with privacy laws.
    • Responding to legal actions. For example, we may share your PHI to respond to a court order, administrative subpoena, or other lawful process, such as a discovery
    • For example, we may share your PHI for some types of health research that do not require your authorization.
    • Working with medical examiners or funeral directors. For example, we may share PHI with coroners, medical examiners, or funeral directors when an individual dies.
    • Addressing workers’ compensation, law enforcement, or other government requests. For example, we may use and disclose your PHI for: workers’ compensation claims; health oversight activities by federal or state agencies; law enforcement purposes or with a law enforcement official; or specialized government functions, such as military and veterans’ activities, national security and intelligence, presidential protective services, or medical suitability.
    • Health information exchanges (including Connecticut’s Connie). We participate in one or more health information exchanges (“HIEs”) that allow us to securely share protected health information with other health care providers and entities for permitted purposes such as treatment, payment, and health care operations. As required by Connecticut law, we participate in Connie, the statewide HIE. Given the sensitivity of the health information we routinely handle for our patients, such as information  regarding reproductive health or HIV-related information, we generally only share  this information through HIEs with your consent. You may opt into having your information accessible through Connie or other HIEs we participate in at any time. To opt into the HIE or opt back out, contact Connie Customer Care at 866-987-5514, or contact our Privacy Officer for assistance.

Uses and Disclosures That Require Your Written Authorization

Other uses and disclosures not described in this Notice will be made only with your written authorization. If you have a clear preference for how we share your information in the situations described below, please contact our Privacy Officer at the contact information above and we will make reasonable efforts to follow your instructions.

In these cases, we will not share your information unless you give us your written permission:

  • Most sharing of a mental health care professional’s notes (psychotherapy notes).
  • Marketing purposes.
  • Selling or otherwise receiving compensation for disclosing your PHI
  • Certain research activities.
  • Other uses and disclosures not described in this Notice.

In a civil, criminal, administrative, or legislative proceeding against an individual, we will not use or share information about your substance abuse treatment records unless a court order requires us, or you give us your written permission.

Fundraising: We may contact you for fundraising efforts, but you can tell us not to contact you again. You may revoke your authorization at any time, but it will not affect information that we have already used and disclosed.

 

Your Rights

You have the following rights regarding your health information:

Inspect and Copy Your Health Information

You have the right to inspect and obtain a copy of your health information, including medical and billing records maintained in paper or electronic form.

  • How to request: Submit your request in writing to our Privacy Officer or make your request orally or through electronic means.
  • Response time: We will respond to your request within 30 days. If we need additional time, we will notify you in writing within the initial 30-day period and may take up to an additional 30 days to respond.
  • Format: You may request your records in the format of your choice, including paper copy, electronic copy, or by directing us to send your records to a third party. If you would like an electronic copy, we will provide one in the form and format you request if readily producible, or in a readable electronic form we agree upon.
  • Unencrypted electronic transmission: You may request that we send your records via unencrypted email or other electronic means. If you make this request, we will inform you of the risks of unencrypted transmission. If you still wish to proceed, we will honor your request, and you accept the risks associated with such transmission.
  • In-person inspection: You may inspect your records in person at no charge. During in-person inspection, you may use your personal device (such as a smartphone) to take notes or photograph your health information.
  • Fees: We may charge a reasonable, cost-based fee for copies (not to exceed any state-imposed maximum fee). Our fee schedule is posted on our website at circlecarecenter.org. You may request an individualized fee estimate before we fulfill your request, and you may request an itemized bill after your request is completed.
  • Identity verification: We will verify your identity before releasing records, but we will not impose unreasonable identity verification measures such as requiring notarized signatures or in-person identification when other reasonable methods are available.
  • Denials: In some limited circumstances, we may deny your request. Under federal law, you may not inspect or copy: psychotherapy notes; information compiled in reasonable anticipation of litigation; PHI restricted by law; information related to medical research where you agreed to participate; information whose disclosure may result in harm to you or another person; or information obtained under a promise of confidentiality. If we deny your request for a reason that is subject to review, you may request that the denial be reviewed.

 

Request Amendment of Your Medical Record

If you believe that the health information we have about you is incorrect or incomplete, you may request an amendment in writing. We will respond within 60 days. If we deny your request, we will provide a written notice that explains our reasons. You will have the right to submit a written statement of disagreement to be included in your records.

 

Request Restrictions on Uses and Disclosures

You have the right to ask us to limit what we use or share about your PHI for treatment, payment, or operations, or with certain persons involved in your care. For these requests, we are generally not required to agree and may say “no” if it would affect your care.

However, we will agree not to disclose information to a health plan for purposes of payment or health care operations if the requested restriction concerns a health care item or service for which you or another person, other than the health plan, paid in full out-of-pocket, unless disclosure is otherwise required by law.

Other Rights

  • Accounting of disclosures: You have a right to request an “accounting of disclosures” every 12 months, except for disclosures made with your written authorization; for purposes of treatment, payment, or healthcare operations; required by law; or made more than six (6) years prior to the date of the request.
  • Confidential communications: You may request that we communicate with you about health matters in a certain way or at a certain location. We will accommodate reasonable requests made in writing.
  • Breach notification: You have the right to be notified within sixty (60) days of the discovery of a breach of your unsecured protected health information if there is more than a low probability the information has been compromised.
  • Paper copy of this notice: If you are receiving this Notice electronically, you have the right to a paper copy of this Notice at any time.

Personal representative: If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your PHI. We will confirm the person has this authority before we take any action.

 

File a Complaint

You have the right to complain if you feel we have violated your privacy rights. We will not retaliate against you for filing a complaint.

You may file a complaint:

  • Directly with us by contacting our Privacy Officer at the contact information above. All complaints must be submitted in writing.
  • With the Office for Civil Rights at the U.S. Department of Health and Human Services. You may visit hhs.gov/ocr/privacy/hipaa/complaints/ or mail your complaint to:

Centralized Case Management Operations

U.S. Department of Health and Human Services

200 Independence Avenue, S.W., Room 509F HHH Bldg.

Washington, D.C. 20201

OCRComplaint@hhs.gov

 

Special Protections for Certain Information

Some kinds of information, such as alcohol and substance abuse treatment, HIV- related, mental health, psychotherapy, and genetic information, are considered so sensitive that state or federal laws provide special protections for them. Therefore, some parts of this general Notice may not apply to these types of information. If you have questions or concerns about the ways these types of information may be used or disclosed, please speak with your health care provider.

 

State Law

Where Connecticut state law provides greater privacy protections or rights than HIPAA, we will follow state law. Similarly, where federal regulations such as 42 CFR Part 2 (governing certain substance use disorder treatment records) provide greater protections, we will follow those more stringent requirements.

 

Contact and Questions

If you have questions about this Notice or how your PHI may be used or disclosed, please contact our Privacy Officer at the contact information above.

 

By signing below, you are acknowledging that you have read and received, or have been given the opportunity to receive, a copy of our Notice of Privacy Practices.