Privacy Policy
Last modified: September, 2022
This policy describes the types of information that Care Coordination Systems, LLC
(“CCS or “We”) may collect from you or that you may provide when you use the
Community Health Record applications (“the CHR Applications”) and associated
software in the course of your employment, and our practices for collecting, using,
maintaining, protecting, and disclosing that information. This policy applies to information
we collect when you use any of the CHR Applications, and in email, text, and other
electronic messages between you and your employer and CCS.
This policy does not apply to client information entered by you into the CHR Applications.
That information is protected by law and by Business Associate Agreements between
CCS, your employer, and the Community Hub with which your employer is affiliated (“the
Community Hub”).
Please read this policy carefully to understand our policies and practices regarding your
information and how we will treat it. By accessing or using the CHR Applications, you
agree to this privacy policy. This policy may change from time to time (see Changes to
Our Privacy Policy below). Your continued use of the CHR Applications after we make
changes is deemed to be acceptance of those changes, so please check the policy
periodically for updates.
Information We Collect About You and How We Collect It
CCS collects several types of information from and about users of the CHR Applications,
including:
information by which you may be personally identified such as name, e-mail
address, or any other identifier by which you may be contacted online or offline
(“personal information”);
information that is about you but individually does not identify you, such as the
name of your employer and the information which you enter into the CHR
Applications; and
information about your internet connection, the equipment you use to access the
CHR Applications, and usage details.
We collect some information directly from you when you or your employer provides it to
us, and other information (such as information about your computer and internet
connection, including your IP address, operating system, and browser or tablet type)
automatically as you use the CHR Applications. The information we collect automatically
is statistical and technical data and not personal information, but we may tie this
information to personal information about you that you or your employer provide to us.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any
personal information:
to verify that you are a “Licensed User” of the CHR Applications;
so that you, your employer, and the Community Hub may store data in and make
use of the CHR Applications to provide care coordination services;
to provide technical support to you, your employer, and the Community Hub;
in any other way we may describe when you provide the information; and,
for any other purpose with your consent.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not
identify any individual, without restriction. We may disclose personal information that we
collect or you provide as described in this privacy policy:
to your employer, the Community Hub, and entities with which they have
contracted to provide care coordination services;
to contractors, service providers, and other parties we use to support our business,
and who are bound by contractual obligations to keep personal information
confidential and use it only for the purposes for which we disclose it to them; and
to fulfill the purpose for which you provide it;
for any other purpose disclosed by us when you provide the information; and,
with your consent.
We may also disclose your personal information:
to comply with any court order, law, or legal process, including to respond to any
government or regulatory request.
to enforce or apply the terms of our license of the CHR Applications; and
if we believe disclosure is necessary or appropriate to protect the rights, property,
or safety of CCS, our customers, care coordination clients, or others.
CCS does not provide personal information to third parties for marketing purposes.
Data Security
We have implemented measures designed to secure your personal information from
accidental loss and from unauthorized access, use, alteration, and disclosure. The safety
and security of your information also depends on you. You are responsible for keeping
the password you use for access to the CHR Applications confidential. Do not share your
password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure.
Although we do our best to protect your personal information, we cannot guarantee the
security of personal information transmitted to our system in the course of using the CHR
Applications. Any transmission of personal information is at your own risk. We are not
responsible for circumvention of the security measures contained within the CHR
Applications.
Changes to Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on our website. The
date the privacy policy was last revised is identified at the top of the page.
Contact Information
Our General Counsel and Chief Information Security Officer, Michael P. Morley, is our
senior privacy officer. To ask questions or comment about this privacy policy, or for any
other questions regarding our privacy policies and practices, contact him at
general.counsel@ccs.health.