Policies

Privacy Policy

This privacy notice discloses the privacy practices for turningpnt.org. This privacy notice applies solely to information collected by this web site. It will notify you of the following:

  1. What personally identifiable information is collected from you through the web site, how it is used and with whom it may be shared.

  2. What choices are available to you regarding the use of your data.

  3. The security procedures in place to protect the misuse of your information.

  4. How you can correct any inaccuracies in the information.

  5. How policy changes will be communicated.

INFORMATION COLLECTION, USE, AND SHARING

We are the sole owners of the information collected on this site. We only have access to/collect information that you voluntarily give us via email or other direct contact from you. We will not sell or rent this information to anyone. Information collected includes you name, email, address, and phone number.

We will use your information to respond to you, regarding the reason you contacted us. We will not share your information with any third party outside of our organization, other than as necessary to fulfill your request.

Unless you ask us not to, we may contact you via email in the future to tell you about center news or changes to this privacy policy.

YOUR ACCESS TO AND CONTROL OVER INFORMATION

You may opt out of any future contacts from us at any time. You can do the following at any time by contacting us via the email address or phone number given on our website:

  • See what data we have about you, if any.

  • Change/correct any data we have about you.

  • Have us delete any data we have about you.

  • Express any concern you have about our use of your data.

LINKS

This web site contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

SECURITY

We take precautions to protect your information. When you submit sensitive information via the website, your information is protected both online and offline.

Wherever we collect sensitive information, that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for “https” at the beginning of the address of the web page.

While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.

CHANGES TO THIS POLICY

We may make changes to this privacy notice from time to time.  You may check back on this page at any time to see our current policy.

If you feel that we are not abiding by this privacy policy, you should contact us immediately via email at info@turningpnt.org.

Telehealth Consent Policy

Date Originated: 06.2024

Date Revised: 06.2024

CONSENT FOR TELEHEALTH

  • Client will sign a consent for telehealth during the electronic intake process. 

  • The provider will explain how the video conferencing technology that will be used to affect such a session will not be the same as a direct client/health care provider visit due to the fact that we will not be in the same room as the provider.

  • The client will be explained that a telehealth consultation has potential benefits, including easier access to care and the convenience of meeting from a location of my choosing.

  • The client will be explained this technology has potential risks, including interruptions, unauthorized access, and technical difficulties. The healthcare provider or the client can discontinue the telehealth consult/visit if it is felt that the videoconferencing connections are not adequate for the situation.

  • The clinician will ask and document the client's location in case of an emergency. In an emergency the clinician can inform the emergency contact of the issue or use 911 when the client's safety or others are in jeopardy.

CONSENT TO USE THE TELEHEALTH BY SIMPLE PRACTICE SERVICE

Telehealth by SimplePractice (HIPPA compliant) is the technology service Turning Point uses to conduct telehealth video conferencing appointments. It is simple to use and there are no passwords required to log in. All clients will sign a document acknowledging:

  • Telehealth by SimplePractice is NOT an Emergency Service and in the event of an emergency, I will use a phone to call 911.

  • Though my provider and I may be in direct, virtual contact through the Telehealth Service, neither SimplePractice nor the Telehealth Service provides any medical or healthcare services or advice including, but not limited to, emergency or urgent medical services.

  • The Telehealth by SimplePractice Service facilitates videoconferencing and is not responsible for the delivery of any healthcare, medical advice or care.

  • To maintain confidentiality, I will not share my telehealth appointment link with anyone unauthorized to attend the appointment.

TRAINING

  • All staff using Simple Practice will be trained on how to use the telehealth option.

  • All staff will be trained on telehealth confidentiality including: client and clinician should both be in an area where confidentiality can be maintained.

  • The clinician will determine if telehealth is appropriate for the client.

Client Confidentiality

Date Originated: 03.1997

Date Revised: 11.2023

An advisement of these provisions is signed by new employees on the first day of employment and annual training is provided regarding client confidentiality.

OVERVIEW

Federal confidentiality law, pursuant to United States Code 290dd-2, provides that records of client and family identifying information, diagnosis, prognosis, background, and treatment that are maintained in connection with a program of substance abuse (or other clinical diagnosis) education, prevention, training, treatment, rehabilitation, or research, be confidential and disclosed only for the purposes and under the circumstances outlined below (see Permitted Disclosure).  Records protected from unauthorized disclosure include any information acquired about a client and family, whether or not such information is in writing or recorded in some other form, and include all communication made by the client and family to program staff.  Memories and impressions of staff are considered records, and are protected by the regulations even if they are never recorded in any form.  Also included are computer passwords and all electronic systems of client information management.  The prohibitions of this law continue to apply to records concerning any individual who has been a client, irrespective of whether or when such individual ceases to be a client.

APPLICABILITY

The general rule prohibiting disclosure applies to all who have access to client records - agency personnel, researchers, auditors, or others.  The rule applies to these individuals whether or not they are compensated for their activity and it continues to apply to them after they have terminated their employment or relationship with the agency.  The prohibition on unauthorized disclosure applies whether or not the person seeking the information already has the information, has other means of obtaining it, enjoys official status, perceives special dispensation, has obtained a subpoena or warrant, is backed by the jurisdiction of state law, or is seeking the information in person, on the telephone, or in writing.  Any state provision permitting or requiring disclosure that is prohibited by federal law is invalid.  However, states may require greater restriction than federal regulations.

PENALTIES

Any person who violates any provision of this law could be fined in accordance with Title 18.  A violation of federal confidentiality law and regulations may be reported to the United States Attorney for the judicial district in which the violation occurs.  Specific criminal penalties may be imposed on persons, i.e., individuals or organizations that violate the law.  In the case of a first offense, the offender may receive a fine up to $500.  A fine up to $5,000 may be assessed for each subsequent offense.  Agency employees who violate confidentiality provisions will be subject to disciplinary action, up to and including termination from employment.

PERMITTED DISCLOSURE

  • Outside the agency:  The content of any record, as defined above (in Overview), may be disclosed outside the agency in accordance with the prior written consent of the client (and/or legal guardian) for whom the record is maintained.  Such consents are valid, and disclosure thus permissible until such a time consent is legally revoked or expires.  Documentation of consent is filed in the Releases section of each client master file.

  •  Within the agency:  Program staff may disclose information to other staff within the program/agency or to an entity having direct administrative control over the program/agency if the recipient needs the information in connection with duties that arise from the provision of client diagnosis, treatment, or referral.  This means all individuals who have access to patient records - because they work for or administratively direct programs including full-or-part-time employees and unpaid volunteers - may consult among themselves or otherwise share information if their job duties so require.  Conversely, staff members who do not need information about particular clients should not pursue or have routine access to such information.  While appropriate communication between agency staff is permitted, no confidential information about a client should at any time be disclosed to another client without the requisite consent.

  •  Special Circumstances:  Whether or not the client (and/or legal guardian) for whom the record is maintained gives written consent, the content of such a record may be disclosed in special circumstances as follows:

    • To medical personnel to the extent necessary to meet a bona fide medical emergency.

    • To qualified personnel for the purpose of conducting scientific research, management audits, financial audits, or program evaluation; however, such personnel may not identify, directly or indirectly, any individual client in any report of such research, audit, or evaluation or otherwise disclose client identities in any manner.

    • If authorized by an appropriate order of a court of competent jurisdiction and granted after application showing good cause, including the need to avert a substantial risk of death or serious bodily harm.  In assessing good cause, the court shall weigh the public interest and the need for disclosure against the injury to the client, to the client-agency relationship, and to the treatment services.  Upon the granting of such order, the court, in determining the extent to which any disclosure of all or any part of any record is necessary, shall impose appropriate safeguards against unauthorized disclosure.  Except as authorized by such court order, no said record may be used to initiate or substantiate any criminal charges against a client or to conduct any investigation of a client.

    • Federal confidentiality provisions and regulations by law do not apply to the reporting, under state law, of incidents of suspected child abuse and neglect to the appropriate state or local authorities.  All treatment programs must strictly comply with state provisions of mandatory child abuse reporting laws.  However, the exemption for child abuse reporting applies only to initial reports of child abuse or neglect and not to requests or subpoenas for additional information or records, even if the records are sought for use in civil or criminal investigations or proceedings resulting from the program’s initial report.  Thus, client files must still be withheld from child protection agencies absent an appropriate court order or client (and/or legal guardian) consent.

    • When a client has committed or threatened to commit a crime on program premises or against program clients or personnel, the confidentiality regulations permit the program to report the crime to a law enforcement agency or to seek its assistance.  In such a situation, the program may disclose the circumstances of the incident or threat, including the suspect’s name, address, last known whereabouts, and status as a client in the program.  The program must have reasonable grounds to believe the person(s) being reported did commit the crime(s) or make the threat.  Programs should not provide law enforcement with a blanket list of all conceivable suspects.

CONFIDENTIALITY PROCEDURES

  • Confidentiality regulations require programs to notify clients of the existence of federal confidentiality law and regulations, and to give a written summary of the confidentiality provisions and exceptions.  The notice and summary should be provided to clients at admission, or “as soon thereafter as the client is capable of rational communication.”

  • Written client records must be stored in a secure room or a locked file cabinet.

  • Electronic records of clients must be protected at all times.  Staff must use appropriate log on/log off procedures to protect sensitive client information. Two factor authentication is required.

  • Password access must be protected and passwords should not be shared between staff.

  • If a program receives a request for records disclosure that is not permitted by the confidentiality regulations, the program must refuse to make the disclosure and must be sure to do so in a way that does not reveal whether the individual has ever been a client of the agency.  An appropriate program response is, “Federal law prohibits me from disclosing that information.”  The program may give inquiring parties copies of the regulations and explain restrictions on disclosure as long as the program does not affirmatively identify a particular individual as a client whose records are confidential.

  • The Clinical Director or designee is responsible for processing all non-routine inquires and requests regarding client records.

  • All program staff, as needed and on a case-by-case basis, should refer questions about records disclosure to the Clinical Director or Executive Director.

  • All materials that contain client-identifying information must be physically handled in such a manner as to protect client information from being exposed to any unauthorized persons.

  • Confidential or identifying client information should not be taken from agency premises, or accessed from a computer outside of the agency except in extraordinary circumstances, and then on the approval of the Clinical Director or designee.  (Note:  Staff members providing Community Based Services will, by nature of their jobs, sometimes maintain client information with them outside the facility, and management of this information is conducted with utmost prudence and discretion.) 

  • Care should be taken that staff conversations regarding agency clients are not overheard by clients.  In addition to such action being a breach of confidentiality for the client(s) being discussed, it will also undermine the trust and confidence of those clients observing staff discussing sensitive information in a non-professional manner.

  • The paper shredder or a designated secure disposal bin must be used to dispose of printed materials containing any form of client identification.  DO NOT place these materials in the garbage.

  • Special guidelines apply to client access to their own files.  See immediate supervisor or designee if a client asks to see his or her master file. All Behavioral Health Administration policies will be followed.

  • Should an employee meet any client (including family members/guardians, etc.) by happenstance in a public place, the employee should not initiate a greeting to that client. 

To err on the side of caution, all agency personnel should keep the general rule of the law uppermost in mind and operate on the following principle:  Do not disclose anything about a client without being able to explain why the regulations permit the particular disclosure.

Agency employees are expected to maintain, in confidence, information pertaining to internal business affairs and personnel matters.  This confidentiality must be maintained during and after tenure of employment. Any concerns over confidentiality can be directed to your supervisor or the Executive Director.