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Care New England Legal Notices

Legal Notices

Please read the following information carefully. By choosing to use Care New England websites, you acknowledge and agree to the terms of our Legal Notices and our Disclaimer. Continuing to use Care New England websites indicates your acceptance of all terms and conditions of our Legal Notices and our Disclaimer. If you do not accept and agree to these terms and conditions, exit the website immediately.

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Legal Notices Legal Notices

Legal Notices

Care New England reserves the right to revise these terms and notices, and therefore encourages you to review them regularly, because using the websites will indicate your acceptance of, and agreement with, all terms and notices.

Care New England Health System

Care New England and its member organization do not provide medical advice, diagnosis or instruction through its websites. If you need emergency treatment or services, call 911. Care New England is not responsible for how the information in its websites is used.

Content and information on Care New England websites are protected by copyright law, and may not be reproduced, modified, distributed, in entirety or part, without the prior written consent of Care New England. The sole exception is that, unless otherwise stated, users may print or download information from Care New England websites for personal, non-commercial use only, provided they identify the source of the material and include a statement that the materials are protected by copyright law. Permission to reprint or otherwise reproduce any document in whole or in part is prohibited, unless prior written consent is obtained from the copyright owner.

  1. Limitation of Liability.

    Care New England and its affiliates, suppliers, and other third parties mentioned on this site are neither responsible nor liable for any direct, indirect, incidental, consequential, special, exemplary, punitive, or other damages whatsoever (including, without limitation those resulting from lost profits, lost data, or business interruption), arising out of or relating in any way to the site, site-related services and products, content or information contained within the site, and/or any hyperlinked website, whether based on warranty, contract, tort, or any other legal theory and whether or not advised of the possibility of such damages. Your sole remedy for dissatisfaction with the site, site-related services, and/or hyperlinked websites is to stop using the site and/or those services. Applicable law may not allow the exclusion or limitation of incidental or consequential damages, so the above limitation or exclusion may not apply to you.

  2. Accuracy and Integrity of Information

    Although Care New England attempts to ensure the integrity and accurateness of its websites, it makes no guarantees whatsoever as to the correctness or accuracy of the Site. It is possible that the Site could include typographical errors, inaccuracies or other errors, and that unauthorized additions, deletions and alterations could be made to the Site by third parties. In the event that an inaccuracy arises, please inform Care New England so that it can be corrected. Information contained on the Site may be changed or updated without notice.

  3. Visitor Chat Rooms and Other Interactive Areas

    Care New England may, but is not obligated to, monitor or review any areas of the Site where visitors transmit or post communications or communicate solely with each other, including, but not limited to, chat rooms, bulletin boards, and other user forums, and the content or any such communications. Care New England, however, will have no liability related to the content of any such communications, whether or not arising under the laws of copyright, libel, privacy, obscenity, or otherwise. Care New England retains the right to remove, in its sole discretion, communications that include any material deemed abusive, defamatory, obscene, or otherwise inappropriate.

  4. Links or Pointers to Other Sites

    Care New England makes no representations whatsoever about any other website that you may access through this Site. When you access a non-Care New England site, please understand that it is independent from Care New England, and that Care New England has no control over the content on that website. In addition, a hyperlink to a non-Care New England Website does not mean that Care New England endorses or accepts any responsibility for the content, or the use, of the linked site. It is up to you to take precautions to ensure that whatever you select for your use or download is free of such items as viruses, worms, Trojan horses, and other items of a destructive nature. If you decide to access any of the third party sites linked to this Site, you do this entirely at your own risk.

Persons or organizations who have other websites are permitted to link to any complete page on Care New England websites. Linking to specific elements on these websites, such as logos, trademarks, photographs, illustrations, online forms or surveys, is not permitted. Copying onto any other website or server of information, content, or material, including logos, trademarks, photographs, illustrations, online forms or surveys, in its entirety or part, is not permitted.

Terms and conditions stated in our Disclaimer and Legal Notices are entered into in the State of Rhode Island and will be governed by and construed in accordance with the laws of the State of Rode Island, exclusive of its choice of law rules. Each party to these terms and conditions submits to the exclusive jurisdiction of the state and federal courts sitting in Providence, Rhode Island, and waives any jurisdictional, venue, or inconvenient forum objections to such courts. In any action to enforce these terms and conditions, the prevailing party will be entitled to costs and attorneys fees. In the event that any of the terms and conditions are held by a court or other tribunal of competent jurisdiction to be unenforceable, such provisions shall be limited or eliminated to the minimum extent necessary so that these terms and conditions shall otherwise remain in full force and effect.

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Care New England Website Privacy Policy Website Privacy Policy

Care New England Website Privacy Policy

Effective Date: December 30, 2024
Date of Last Revision: December 20, 2024

This Privacy Policy explains how Care New England Health System and its member organizations listed below (together, referred to as “CNE”, “we”, “us” or “our”) may collect, disclose, maintain and use certain information about you when accessing the CNE website, https://www.carenewengland.org and its respective subpages and webpages which link to this Privacy Policy (“Sites”). This Privacy Policy applies to the following member organizations:

  • Affinity Physicians, LLC d/b/a/ Care New England Medical Group
  • Butler Hospital
  • Butler Hospital Foundation
  • Care New England Health System
  • Care New England Pharmacy, LLC
  • Kent Hospital
  • Kent Hospital Foundation
  • The Providence Center
  • VNA of Care New England
  • Women & Infants Hospital
  • Women & Infants Development Foundation

This Privacy Policy explains:

  • What types of information about you may be collected, disclosed, maintained and used when you access the Sites.
  • For what purposes information about you may be used internally by CNE when you access the Sites.
  • For what purposes information about you may be shared (disclosed) by CNE with other individuals and entities when you access the Sites.
  • What choices you have about your information when you access the Sites.

This Privacy Policy:

  • Does NOT apply to protected health information (“PHI”) which may be collected, disclosed, maintained and used, such as when you receive health care services from one of our providers. Please refer to our HIPAA Notice of Privacy Practices for more information about how we may use and share your PHI. This Privacy Policy only applies to the categories of information described in this Privacy Policy that is collected when you use our Sites.
  • Does NOT apply to publicly available information about you which we may receive.
  • Does NOT apply to de-identified or anonymized information which we may collect, maintain, use or disclose and which cannot reasonably be used to identify you.

Please read this Privacy Policy carefully. By accessing the Sites, you agree to this Privacy Policy and to our Legal Notices. If you do not agree with this Privacy Policy, you should not access our Sites. We may update this Privacy Policy from time to time for any reason and will make the updated Privacy Policy available here. Except as otherwise noted, the updated Privacy Policy will be effective as of the date it is posted on these Sites. By accessing the Sites, you agree that you are 18 years of age or older and are authorized to agree to this Privacy Policy and the Legal Notices. If you are under the age of 18, you may not access the Sites.

TYPES OF INFORMATION

When you access the Sites through the Internet, we (including our contracted service providers on our behalf), may collect certain identifiable information about you (“Personal Information”) as you browse and use the Sites. This may include information that you provide to us directly and information which is automatically collected when you access our Sites through the Internet.

Information You Directly Provide: We collect and maintain Personal Information which you may directly provide to us in connection with your access to our Sites includes:

  • Name, address, email, phone number, date of birth, zip codes, gender and any other information you may enter on our Sites, such as when using our “Contact”, “Request an Appointment”, “Volunteer”, “Donate”, “Job Application” or other forms. Please do not include any confidential or sensitive information when using our online forms unless specifically directed to. To the extent any information collected may be PHI, please see our HIPAA Notice of Privacy Practices.
  • Limited health information, such as if you provide information in connection with our Joint Program questionnaire or other general informational questionnaires.
  • Billing information, including account numbers, debit or credit card numbers, address, dates of birth and other information necessary to process payments if you utilize our online bill payment features. We may use a third party processor for such payments/donations and such third party processor may have additional privacy policies and terms. Please see our Third Party Content/Third Party Websites section for more information. To the extent billing information collected may be PHI, please see our HIPAA Notice of Privacy Practices.
  • Billing information, including account numbers, debit or credit card numbers, address, or other contact information if you are interested in making a donation online to one of our non-profit hospital foundations. We may use a third party processor for such payments/donations and such third party processor may have additional privacy policies and terms. Please see our Third Party Content/Third Party Websites section for more information.
  • Donor/Volunteer information, including employment information, financial information, and other information if you express an interest in donating, volunteering or otherwise getting involved with our member organizations.
  • Research related information, including related to joint research we may conduct with one of our third party research partners such as Brown University or Advance-CTR. For example, if you complete an online questionnaire in connection with one of our clinical studies, such as the Butler Alzheimer's Prevention Registry, you may be asked to provide demographic information, contact information, preliminary diagnoses or other health screening information. Please note that if you participate in research with a third party, additional privacy policies of the third party may apply and we are not responsible for how the third party may use your personal information. If we collect any PHI in connection with your participation in the research, such as for a study-specific survey or assessment, the HIPAA Notice of Privacy Practices will apply to use and disclosure of such PHI in connection with the research and this Privacy Policy will not apply.

Information We May Automatically Collect: We may collect and maintain certain information from you automatically when you visit our Sites (“Web Browsing Data”) including but not limited to:

  • HTTP headers, such as IP address, operating system/browser type and version number, model/manufacturer and model, web browser unique identifiers, as well as URL or ad which directed you to our Sites and similar device and domain information.
  • Activity, such as Sites visited, links clicked on, documents or videos viewed, page response time, length of visit, other Site interaction information and similar information.
  • Technical data to address and fix technical problems and improve the Services.
  • General geolocation information at a state level. We do not collect your precise geolocation.

Some of this Web Browsing Data we collect and maintain may be de-identified or anonymized (that is, cannot be reasonably used to identify you). We may aggregate, collect, maintain, use and disclose this de-identified data for any business purposes. De-identified data is not Personal Information and is not subject to this Privacy Policy. However, if we collect Web Browsing Data in a way that identifies you, it is Personal Information which we will only use and disclose as permitted by this Privacy Policy.

Cookies and Similar Technologies. We may automatically collect and maintain certain Web Browsing Data through use of cookies, pixels, web beacons and similar tracking technology. A “cookie” is a small text file stored on your browser or hard drive that allows your device to be identified as you browse through our Sites. If you visit our Sites again in the future, these cookies will recognize your device. The cookies that we set on our Sites are generally “first party” cookies, which means they stay on our Sites and collect information only when you interact with our Sites. Certain cookies are considered “necessary” to the operation of our Sites, while certain other improve your experience with our Sites and our operation of our Sites.

“Pixels” and “web beacons” are electronic images that can recognize or log certain data on your computer, such as if you view a website attached to the pixel or web beacon, and a description of such site and your activity there. These technologies help improve your experience and display more relevant information to you. We may also embed these within emails you may receive for informational, marketing or other purposes described by this Privacy Policy. By accessing our Sites, and agreeing to receive emails, you consent to our use of these types of technologies.

When you use a third party browser like Google or Safari to access our Sites, that third party may also place and use cookies, pixels or web beacons in connection with your use of that browser to access websites on the Internet. These are called “third party” cookies, which means the third party sets and controls these cookies and other technologies as you navigate websites, such as our Sites, using their browser. Many browsers allow you to choose to block cookies and similar tracking technologies. For example, if you use Google, Google may give you options to permit or deny cookies that Google may collect, maintain and use. We are not responsible for third party cookies that your third party browser may set and use, and you are responsible for reviewing the third party’s cookie and tracking technology policies to understand how the third party make collect your Personal Information through such technology.

PURPOSES FOR WHICH INFORMATION IS USED

We may collect, maintain and use your Personal Information as needed to operate, maintain, troubleshoot and improve our Sites, including but not limited to the following activities:

Information You Directly Provide:

  • Contact you to respond to an inquiry you have submitted through one of our Sites, or to provide you with information or notices about our services which you have indicated may be of interest to you, or to send you subscription materials if you sign up for one of our subscriptions.
  • Engage in customer support and feedback.
  • Conduct internal analysis, business operations, performance monitoring, troubleshooting, enhancements and upgrades and other activities related to operation, maintenance, and hosting of the Sites and our services.
  • Engage in marketing, analytics, advertising and informational related activities, such as emailing you information about available services, events and general health and wellness information, or understanding how visitors interact with and utilize our Sites.
  • Process a payment if you have chosen to pay a bill through our Sites or make a donation to one of our non-profit hospital foundations.
  • Maintain the privacy and security of our Sites, including investigating, responding to, and safeguarding against any incidents or breaches.
  • Comply with our legal obligations, such as responding to subpoenas, law enforcement or government requests where we are obligated by applicable laws to response.
  • Enforce our Legal Notices, including responding to any misuse of our Sites or other violations of our Legal Notices.
  • Any other purpose which you may agree to.

Information We May Automatically Collect

  • Engage in customer support and feedback.
  • Conduct internal analysis, business operations, performance monitoring, troubleshooting, enhancements and upgrades and other activities related to operation, maintenance, and hosting of the Sites and our services.
  • Engage in marketing, analytics, advertising and informational related activities, such as displaying relevant ads to you or understanding how visitors interact with and utilize our Sites.
  • Maintain the privacy and security of our Sites, including investigating, responding to, and safeguarding against any incidents or breaches.
  • Comply with our legal obligations, such as responding to subpoenas, law enforcement or government requests where we are obligated by applicable laws to response.
  • Enforce our Legal Notices, including responding to any misuse of our Sites or other violations of our Legal Notices.
  • Any other purpose which you may agree to.

PURPOSES FOR WHICH INFORMATION IS DISCLOSED (SHARED)

Although we generally maintain the privacy of your Personal Information, in certain circumstances, we may disclose (share with a third party) your Personal Information that we collect and maintain as a result of your access to our Sites. The purposes for which we disclose your Personal Information and the category of third party are described generally below.

  • We share Personal Information with our contracted service providers, subcontractors and agents who may help us to provide, operate, maintain and host the Sites, perform marketing, data analysis and other internal operations and services on our behalf, or who process payments or donations through the Sites on our behalf.
  • We may share Personal Information with government agencies, regulatory entities, law enforcement entities, courts and other entities if we are mandated by applicable laws or legal processes to provide Personal Information.
  • We may share Personal Information with third party business partners, individuals and entities in connection with a dissolution, merger, sale, or reorganization where Personal Information may be considered part of any assets which may be transferred or shared as part of the transaction or related due diligence, such as if one or more of our health care organizations merger with or are sold to another health care entity.
  • We may share Personal Information with third party websites which you may navigate to when clicking on a link embedded in our Sites. Personal Information which is shared in these circumstances is generally limited Web Browsing Data such as IP address and other header information and the URL of our web page that you visited their website from in order to correctly direct you from our Sites to the third party’s website. See our Third Party Consent/Websites section below for more information.
  • We may share Personal Information with third party websites if we place an ad on such third party’s website and you click on our ad. Personal Information which is shared in these circumstances is generally limited Web Browsing Data such as IP address and other header information and the URL of the website that you visited our ad from so that we know that our ads are being seen and are helpful to visitors. See our Third Party Consent/Websites section below for more information.
  • We may share Personal Information with other individuals or entities as related to enforcing our rights under the Legal Notices, protecting the availability, confidentiality or integrity of the Sites and Personal Information or safeguarding our Sites, visitors or the general public from harm.

THIRD PARTY CONTENT/WEBSITES

Our Sites may include, from time to time, content which may be created, maintained and made available by a third party, such as videos, audio clips, articles and other informational and educational resources (“Third Party Content”). We may also include links within our Sites to web pages operated and maintained by third parties, such as YouTube, WebMD, Google and similar informational and educational resources provided by third parties on the Internet (“Third Party Websites”). Some of these Third Party Websites may also relate to clinical trial registries and third party research opportunities, as well as to entities with which we may collaborate on research, or direct you to an external payment processor if you are paying a bill or making a donation. From time to time, these third party links may also be provided in our email or print brochures and newsletters.

We have no control over and are not affiliated in any way with Third Party Content and Third Party Websites. Third Party Content and Third Party Websites are provided by third parties on an “as is” basis and we make no representations or warranties about their accuracy, completeness, availability or appropriateness of such, and expressly disclaim any and all liability with respect to such Third Party Content and Third Party Websites. If you navigate to a Third Party Website by clicking a link on our Site, you should review the Third Party Websites privacy policy to understand how the third party may collect, maintain, use or disclose your personal information, including with other websites. Any personal information which a third party collects, maintains, uses and discloses about you when you access their websites is not subject to this Privacy Policy.

SECURITY OF PERSONAL INFORMATION

We implement industry standard technology in order to safeguard our Sites and the Personal Information which may be collected and maintained in connection with the Sites. We take seriously the privacy and security of your Personal Information and implement safeguards to protect such information from use or disclosure in a manner not permitted by this Privacy Policy.

Use of the Internet is inherently risky, and we unfortunately cannot guarantee all Personal Information will remain secure. We cannot guarantee that any links accessible through our Sites are error, virus or malware freed and expressly disclaim any and all liability with respect to such Third Party Content and Third Party Websites. If you have any privacy or security concerns or suspect a security issue, please contact us immediately at privacy@carene.org.

CHILDREN

We do not knowingly collect Personal Information or allow use of the Sites by children under the age of 18. If you are under the age of 18, you may not use the Sites.

INTERNATIONAL DATA TRANSFERS

We do not knowingly collect, maintain, use or disclose Personal Information from individuals who are not present within the United States. If you are not located in the United States, you should not access and use the Sites and you should contact us directly by phone. We maintain Personal Information only in the United States and in accordance with the laws of the United States. 

REVISIONS

We may update this Privacy Policy from time to time for any reason and will make the updated Privacy Policy in effect available here. The updated Privacy Policy will be effective as of the date it is posted unless we post a different effective date. You should review the Privacy Policy each time you access our Sites. If you do not agree with any changes, you may stop accessing our Sites at any time.

COMPLAINTS/QUESTIONS

If you have any questions or complaints about this Privacy Policy, please do not hesitate to contact us at privacy@carene.org. We welcome your comments and concerns.

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HIPAA HIPAA

Joint HIPAA Notice of Privacy Practices for CNE Member Organizations

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.

I. WHO WE ARE
This Notice describes how medical information about you may be used or disclosed and how you can get access to this information. Care New England Health System includes each of its hospitals, health care entities, and physician practices that are a direct or indirect subsidiary of Care New England Health System. This notice will use the terms “CNE” or “we,” “us” or “our” to describe the entities privacy practices listed at the end of this notice. This Notice also describes the privacy practices that apply to our employees (including, but not limited to, those employed health care professionals and other employed individuals with access to your medical or billing records), and all other health care professionals (such as doctors and nurses) allowed to enter or access information in your medical record when they are providing services in our facilities. Please know that you may also receive a separate privacy notice from your individual health care provider which may describe the privacy practices of his or her own medical practice.

II. OUR PRIVACY OBLIGATIONS
We are required by law to protect the privacy of your health information (“PHI”) and we take this obligation very seriously. Additionally, we are required by law to provide you with this Notice of our legal duties and privacy practices with respect to your PHI, and to notify you in the event of a breach of your unsecured PHI. While in certain circumstances we may use and/or disclose your PHI (as detailed in Section III and Section IV of this Notice), generally we may not use and/or disclose any more PHI than is necessary to accomplish our purpose for such use and/or disclosure and we are required to abide by the terms of this Notice.
We may change the terms of this Notice at any time. Any change will apply to all of your PHI that we already have and will include any PHI created or received prior to our formally issuing any new Notice setting forth the change. When we change this Notice, we will promptly issue the new Notice by posting the new Notice prominently at the facilities, and on the websites, of each CNE affiliate where health care services are provided and on the CNE website at carene.org. You may also obtain any new Notice by requesting a new Notice from the CNE affiliate where you received services or CNE Compliance Services at the address listed in Section IX.

III. HOW WE MAY USE AND/OR DISCLOSE YOUR PHI WITHOUT YOUR WRITTEN AUTHORIZATION
We may use and/or disclose your PHI for many different reasons. In certain situations, which are described in Section IV of this Notice, your written authorization must be obtained in order to use and/or disclose your PHI. However, your authorization is not required for the following uses and/or disclosures by us:
A. Use of PHI for treatment, payment and health care operations.
1. For treatment. We may use and/or disclose your PHI with physicians, nurses, medical students, and others who provide you with health care services or are involved in your care. For example, if you are being treated for diabetes, we may disclose your PHI with your primary care physician and/or a nutritionist in order
to coordinate your care. Sharing of PHI may be through the use of a shared electronic health record.
2. For payment. We may use and/or disclose your PHI in order to bill and collect payment for the health care services we provide to you. For example, we may disclose your PHI with your health plan to obtain payment from your health plan for the health care services we provide to you. We may also disclose your PHI to billing companies and companies that process our health care claims or to other health care providers when your PHI is required for them to receive payment for the health care services they provide to you.
3. For health care operations. We may use and/or disclose your PHI in order to operate our organization. For example, we may use your PHI to evaluate the quality of health care services that you receive, or to evaluate the health care professionals who provide health care services to you. We may also disclose your
PHI to our accountants, attorneys and others in order to make sure we are complying with applicable laws.
B. Other uses and disclosures of your PHI that do not require your authorization (except with respect to certain Highly Confidential Information as described in Section IV), we may also use and/or disclose your PHI for the following reasons:
1. As required or authorized by law. We may use and/or disclose your PHI (i) when required by any applicable federal, state or local law; (ii) in response to a legal order or other lawful process; or (iii) to a coroner, medical examiner or funeral director as authorized by law.
2. Public health. We may use and/or disclose your PHI to (i) report health information to public authorities for the purpose of preventing or controlling disease, injury or disability; (ii) report child abuse and neglect to the government authority authorized to receive such reports; (iii) report abuse, neglect or domestic violence, if we reasonably believe you are a victim of such acts, to the government authority authorized to receive such reports; (iv) report information about products under the jurisdiction of the U.S. Food and Drug Administration; (v) alert a person who may have been exposed to a communicable disease or may otherwise be at risk of contracting or spreading a disease or condition; (vi) report information to your employer as required under laws addressing work-related illnesses and injuries or workplace medical surveillance; or (vii) provide proof of immunization if the school is required by state law to have them for admission.
3. Health oversight. We may use and/or disclose your PHI for the purpose of assisting the government when it investigates or inspects a health care provider or organization.
4. Organ donation. We may use and or disclose your PHI to notify organ banks to assist them in organ, eye, or tissue donation and transplants to the extent permitted by state law.
5. Research. We may use and/or disclose your PHI for research purposes. Depending on the circumstances, state law may require us to obtain your authorization before using and disclosing your PHI for research purposes. If state law requires us to obtain your authorization, we will do so before using or disclosing your PHI for research purposes.
6. To avoid harm. We may use and/or disclose your PHI to law enforcement or other appropriate persons, in order to avoid a serious threat to the health or safety of a person or the public.
7. Other government functions. We may use and/or disclose your PHI for certain military and veterans’ activities, national security and intelligence purposes, protective services for the president of the United States, or correctional facility situations.
8. Workers’ compensation. We may use and/or disclose your PHI in order to comply with workers’ compensation laws.
9. Appointment reminders and health-related benefits or services. We may use your PHI to give you appointment reminders, registration/insurance updates, billing or payment matters, pre-procedure assessment, test results, or to give you information about treatment choices or other health care services or benefits we offer.
10. Fundraising. We may use your information to contact you for fundraising purposes. Donations are used to expand and support health care services and programs we provide to the community. If you do not wish to be contacted for fundraising purposes, you may call us at (401) 921-8526. Please provide your full name, address, and phone number. You are free to opt out and your decision will not impact your treatment or payment for services.
11. For integration with affiliated health care providers. As permitted by law, we may use and/or disclose your PHI with health care providers who are affiliated with CNE, and the CNE affiliates may share PHI with each other as necessary to carry out treatment, payment, or health care operations.

IV. HOW WE MAY USE AND/OR DISCLOSE YOUR PHI AFTER OBTAINING YOUR WRITTEN AUTHORIZATION
We must ask for your written authorization for any other use and/or disclosure of your PHI which was not described in Section III. If you authorize us to use and/or disclose your PHI, you can later revoke the authorization and stop any future use or disclosure of your PHI under that prior authorization. You can revoke an authorization by providing a written request of such revocation to the CNE affiliate where you received services or by contacting CNE Compliance Services.
A. Highly Confidential Information. Certain state and federal laws require special privacy protections for certain highly confidential information about you, including the subset of your PHI that: (i) is maintained in psychotherapy notes; (ii) is about services for mental health treatment provided by us; (iii) is about services for alcohol or drug abuse or addiction by substance abuse programs operated by us; or (iv) involves genetic information (“Highly Confidential Information”). We must generally get your authorization to disclose any Highly Confidential Information about you, but may disclose it without first getting your authorization in the following circumstances:
1. Psychotherapy notes. In general, we will not use or disclose information recorded by a mental health professional to document or analyze conversations with you in therapy, unless you authorize us to do so. However, we can use or disclose such PHI without your authorization for the following purposes: (a) the health professional who recorded the information can use it to treat you; (b) in limited situations, we can use or disclose such PHI in connection with mental health counseling training that occurs at one of our facilities; (c) we can use or disclose your psychotherapy notes to defend against any legal proceeding brought by you; and (d) compliance with law, public health, health oversight, or to avoid harm (each as described in Section III).
2. Mental health treatment. Information regarding your mental health treatment may be used by or disclosed to those who are providing you with treatment. It may also be disclosed to entities responsible for paying for your care, such as insurance companies, but only the amount of information necessary for payment purposes will be disclosed. If they ask and we think it is in your best interest, we may tell your lawyer, your guardian or conservator (if any), or a member of your family that you are a patient, unless you tell us not to. If you are a patient, we may tell the mental health advocate your name and when your treatment began, unless you tell us not to. Information regarding your mental health treatment may be disclosed when ordered by a court or otherwise required by law,
such as reports of suspected child abuse or reports to the department of health or other regulatory agencies. We may also use or disclose mental health treatment information for purposes of program evaluation or research under limited circumstances. If you are a minor, your mental health treatment records may be released to your parent or guardian under certain circumstances. In an emergency, information regarding your mental health treatment may be used or disclosed in order to prevent someone (including you) from being harmed.
3. Drug and alcohol treatment records. The confidentiality of alcohol and drug abuse related PHI which is maintained by the substance abuse programs we may operate is protected by federal law and regulations. In general, we may not tell a person outside the program that you attend the program, or disclose any information identifying you as an alcohol or drug abuser unless: (a) you consent in writing; (b) the disclosure is allowed by a court order; or (c) the disclosure is made to medical personnel in a medical emergency or to qualified personnel for research, audit, or program evaluation. Violation of the federal law and regulations by a substance abuse program is a crime. Suspected violations may be reported to appropriate authorities in accordance with federal regulations. Federal law and regulations do not protect any information about a crime you may commit either at substance abuse program or against any person who works for the substance abuse program or about any threat to commit such a crime. Federal laws and regulations do not protect any PHI about suspected child abuse or neglect from being reported under state law to appropriate state or local authorities. (See 42 U.S.C. 290dd-3 and 42 U.S.C. 290ee-3 for federal laws and 42 CFR part 2 for Federal regulations.)
B. Marketing. We will not make any disclosure of your PHI for purposes that would constitute marketing without your written authorization. For example, we will not accept any payments from other organizations or individuals in exchange for making communications to you about treatments, therapies, health care providers, settings of care, case management, care coordination, products or services unless you have given us your written authorization or unless the communication is permitted by law. That said, we may (1) provide refill reminders or communicate with you about a drug or biologic that is currently prescribed to you so long as any payment we receive for making the communication is reasonably related to the cost of making the communication; or (2) market to you in a face-to-face encounter and give you promotional gifts of nominal value.
C. Sale of PHI. We will not make any disclosure of your PHI that would constitute a sale of PHI without your written authorization.

V. WHEN YOU MAY OBJECT TO OUR USE AND/OR DISCLOSURE OF YOUR PHI
A. Patient directories. Except for those instances in which you may be a patient receiving mental health treatment or patient or attendee of an alcohol or substance abuse program, we may include your name, room number or unit, general condition, and religious affiliation in the patient directory of our hospital affiliates for use by clergy and visitors who ask for you by name. You may choose not to have this information in our patient directories. If you choose not to have this information in the directory, we cannot tell visitors, callers or delivery people (such as mail or flowers) that you are a patient and, unless you give specific contact information to another person (family member, etc.). If you are unable to object to your information being included in our patient directory, we may include your information in our patient directory and use or disclose such information if we determine that it is in your best interest and consistent with your past requests (if any) until such time that you are able to indicate that you do not want your information included.
B. Disclosures to family, friends, or others. Except for certain circumstances involving Highly Confidential Information, we may disclose your PHI with a family member, friend, or other person who is involved in your care or the payment for your health care.

VI. YOUR RIGHTS REGARDING YOUR PHI
A. Your right to request limits on our use of PHI. You may ask that we limit how we use and/or disclose your PHI. We will consider your request but are not legally required to agree to your request unless the disclosure is (i) to a health plan for purposes of carrying out payment or health care operations; and (ii) the PHI pertains solely to a health care item or service for which you have paid us out of pocket in full. If we agree to your request, we will follow your limits, except in emergency situations. You cannot limit the uses or disclosures that we are legally required or allowed to make.
B. Your right to choose how we send PHI to you. You may ask that we send information to you at a different address (for example, to your work address rather than your home address) or by different means (for example, by e-mail instead of regular mail). We will agree to your request, as long as we can easily provide it in the way you requested. Also, you may ask us to send a copy of your PHI directly to another person designated by you. This request must be in writing, signed by you, and clearly identify the designated person and where to send the information.
C. Your right to view and get a copy of PHI. You may view or obtain a copy of your PHI. However, there are some circumstances in which we may deny your request. Your request must be in writing. If we do not have your PHI, but know who does, we will tell you who has it. We will reply to you within 30 days of your request. If we deny your request, we will tell you, in writing, our reasons for the denial and explain what appeal rights you have, if any. If you request a copy of your PHI, we may charge a fee if permitted to do so by law. Instead of providing the PHI you requested, we may offer to give you a summary or explanation of the PHI, as long as you agree to that and to the cost in advance.
D. Your right to receive an accounting of disclosures. You have the right to get a list of the parties to whom we have disclosed your PHI. Some disclosures will not be listed, however. For example, the list will not include disclosures related to treatment, payment, or health care operations; disclosures you have previously authorized; disclosures made directly to you or some disclosures to your family; disclosures in our patient directory; disclosures for national security purposes; disclosures to corrections or law enforcement personnel; or disclosures made before April 14, 2003.
We will respond to your request within 60 days. We will include the disclosures made in the last six years unless you request a shorter time. The list will include the date of each disclosure, the identity of person(s) to whom the disclosure was made, the type of information disclosed, and the reason for the disclosure.
We will not charge you for the list. If you make more than one request in the same year, however, we may charge you a fee for each additional request. For a list, you must make a written request to the CNE affiliate where you received services at the address listed in Section IX.
E. Your right to correct or update your PHI. If you feel that there is a mistake in your PHI, or that important information is missing, you may request a correction. Your request must be in writing, include a reason for the request and be addressed to the CNE affiliate where you received services or to CNE Compliance Services.
We will respond within 60 days of your request. We may deny your request if the PHI is (i) correct and complete; (ii) not created by us; (iii) not allowed to be shared with you; or (iv) not in our records. If we deny your request, we will inform you of the reason for the denial. You may then file a written statement of disagreement, or you may ask that your original request and our denial be attached to all future disclosures of your PHI. If we agree to honor your request, we will change your PHI, inform you of the change, and tell any others who need to know about the change to your PHI.
F. Your right to a paper copy of this notice. You may ask us for a copy of this Notice at any time even if you have agreed to receive this Notice electronically. This notice is also available on the website at carenewengland.org.

VII. MINORS AND PERSONAL REPRESENTATIVES
In most situations, parents, guardians, and/or others with legal responsibilities for minors (children under 18 years of age) may exercise the rights described in this Notice on behalf of the minor. However, there are situations where minors may themselves exercise the rights described in this Notice and minors’ parents or guardians may not.


VIII. TO FILE A COMPLAINT ABOUT OUR PRIVACY PRACTICES
You can complain if you feel we have violated your rights by contacting the CNE affiliate where you received services or by contacting the CNE Privacy Officer at the telephone number listed in Section IX or by sending a written complaint to the Secretary, U.S. Department of Health and Human Services, 200 Independence Avenue S.W., Washington, D.C. 20201. Your complaint will not alter or affect the care we provide to you.

IX. PERSONS TO CONTACT FOR INFORMATION ABOUT THIS NOTICE
If you have any questions about this Notice or wish to request a new Notice, wish to file a complaint about our privacy practices, feel that we may have violated your privacy rights, disagree with a decision we made about access to your PHI, or wish to provide notice or make a request for any other reason set forth in this Notice, please contact the CNE Privacy Officer at: Care New England Compliance Services, 800 Butler Drive, Providence, RI 02906, (401) 277-3660, or cnecompliance@carene.org.

Care New England Affiliates: Butler Hospital, Care New England Medical Group, Kent Hospital, The Providence Center, VNA of Care New England, Women & Infants Hospital. Also may include other affiliates not listed above.

For a version of this Notice in Spanish, please click here.

Effective date of this Notice: September 4, 2018

 

Care New England (CNE) Health System Compliance Program

The goal of Care New England's Compliance Program is to help guide and assist all employees in complying with all laws and regulations, and to provide a means to educate, communicate, monitor and report compliance issues. The program is a comprehensive effort to promote ethical, compliant, and legal behavior while detecting and preventing fraud, waste, abuse, and policy violations. Simply put, the CNE Compliance Program is designed to assist employees and business partners to integrate these values and effective performance improvement into all aspects of operations.

The chief compliance officer (CCO) reports directly to the Board of Directors and the department functions independently of the operating divisions. The department's mission is to maintain a structure and process that promotes ethical behavior, compliance with legal requirements, and CNE policies, resulting in quality care, accurate financial practices, and organizational excellence. 

 

Compliance Line Hotline (1-877-TELL-CNE) 

 

A key element of the CNE Compliance Program is the telephone service called the ComplianceLine that can be accessed by dialing 1-877-835-5263.

The ComplianceLine is a completely confidential resource that can be used anonymously to allow all members of the CNE community to voice concerns over any situation that may conflict with CNE's commitment to excellence or to report misconduct that could give rise to legal liability if not corrected. An impartial independent company transcribes information reported by callers and communicates this information to the chief compliance officer (CCO) or his/her designee so that appropriate verification, investigation, and resolution can take place. A unique code is assigned to each call for follow-up communication by the anonymous caller. 

The CCO provides regular reports to the Board's Audit & Compliance Committee that summarize ComplianceLine usage as well as any material findings from investigations resulting from calls and other similar communications.

Chief Compliance Officer

If you have an ethical question or concern, or if you want to report an ethics violation:

  • Call Jennie Henriques, CNE Chief Compliance Officer, directly at (401) 277-3660.
  • Email the Care New England compliance officer cnecompliance@carene.org.
  • Call the Care New England Toll-free Compliance Line at 1 (877) 835-5263.

All inquiries are confidential. Our policy prohibits retaliation of any kind for inquiries made in good faith.

 

View the Code of Conduct Booklet