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Town of Davie, Florida

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NOTICE OF PRIVACY PRACTICES
The Health Insurance Portability and Accountability Act of 1966  - “HIPAA”

Purpose of This Notice:

    To provide information to employees on how medical information about them is collected, how that information may be disclosed and how they can get access to this information.  Please contact the Town Plan Privacy Official if you have any questions about this Notice.

     Confidentiality is a top priority for the Town of Davie.  We are committed to maintaining the highest level of confidentiality with all of the information we receive from our employee’s and subscribers to the various health benefit plans of the Town.  The Town requires that contracted third-party administrators of the Towns health plans meet HIPAA security standards for all information, including that which is transmitted or maintained electronically.  

     The Town respects the privacy of personal information and understands the importance of keeping this information confidential and secure.  The Town protects the confidentiality of the personal information we receive following Federal and State laws.  Our practices apply to current and former employees, whether subscribers to benefit plans or not and complies with the “Protected Health Information” (PHI) HIPAA disclosure requirements.

Types of Personal Information We Collect:

    The Town does not initiate, collect or maintain any true personal medical records or similar information on any employee.  That PHI that is collected is incidental to the employment and benefit administration process.  The Town does receive and maintain billing records that summarizes the claims history, claims expenses, and types of claims experienced by individuals for whom the plan sponsor has provided health benefits under the group plans.  Those records are de-identified and individuals are rendered unidentifiable.  Those records are maintained out of business necessities related to bill paying and auditing and generally administering the group plans.

     The Town does collect a variety of personal information to administer a member’s life, health, dental and other similar coverage’s.  Some of this information is provided by members in enrollment forms, surveys and correspondence (such as address, Social Security number, and dependent information).  The Town also receives personal information (such as eligibility and limited claims information) through transactions with our providers, third-party administrators and members, former employers, insurance agents, other insurers, and health care providers.  

     We retain this information even after an employee’s enrollment ends and/or the employee leaves their position with the Town.  We limit the collection of personal information to that which is necessary to administer the business of the Town, provide quality service and benefits, and meet regulatory requirements.

How We Protect Personal Information:

    Personally identifiable information is described as data that is unique to an individual, such as a name, address, telephone number, social security number and date of birth (DOB).  At times the Town and/or its benefit providers may request personal information from you through internet sites in order to deliver requested materials to you, respond to your questions, or deliver a product or service.

    The Town requires each of its benefit providers to maintain a Notice of Privacy Practices and to comply with all HIPAA regulations concerning privacy of member information.  The Town also requires benefit providers and third-party administrators to meet strict physical, electronic and procedural security standards to protect personal information and to maintain internal procedures to promote the integrity and accuracy of that information.

    All medical information in the possession of the Town and/or its employees, regardless of source, is treated with the strictest confidentiality and will only be released to other parties at the written request of or the written authorization of the employee or person the records concern.  Employees are not permitted to distribute or release any medical information concerning any other employee or employee dependant by internal or external e-mail or other electronic means when such transfer of information is not a necessary part of the administration of the Towns business.

HR-4.04.a
 

     Pursuant to the Florida Public Records Law, most of the Town documents/records are open for inspection, review and copying by the public.  All non-medical personnel records that are not exempt from Florida’s public records law shall be open for public inspection during regular office hours.       

Disclosure of Personal Information:

1.      The Town may share any of the personal information collected within our organization as permitted by law and as may be necessary to manage our employee work force.

2.      The Town maintains physical, electronic, and procedural safeguards that protect your information.  

3.      The Town will verify that any persons requesting information about you or your relationship with the Town is entitled to such information prior to providing it.  For example, we may give information to heirs/beneficiaries concerning the existence and amount of life insurance and pension funds following receipt of notice of the death of a covered employee.

4.      We will share non-public personal information about you outside the Town only to service your request, or as authorized by you or as required or permitted by court order.

Individual rights to Access and to correct Personal Information:

    Employees have the right to inspect and copy any of the personal information collected in connection with employment, benefit enrollment, benefit administration, and personnel administration.  In addition employees have access to any information about them that was collected in anticipation of a lawsuit or legal claim.  The Town of Davie will respond to all such written employee requests for information in a timely manner.

    Employees have the right to request a restriction of their Protected Health Information (PHI).  Employees may ask the Town not to use or disclose any part of their PHI obtained for the purpose of treatment, payment or healthcare operations.  
                                                                                                                                     
     The Town’s goal is to keep our employee information up-to-date with correct and accurate information.  We have procedures in place to ensure the integrity of our information and for the timely correction of incorrect information.  If you believe that any personal information we have about you is not accurate, please let Human Resources Management know about your concerns.

    The Town of Davie may amend this privacy policy from time to time.  

     In accordance with applicable law, the Town is providing employees with this Notice describing our PRIVACY POLICY AND PRACTICES.  

     If you have any questions please contact the Plan Privacy Official in the Human Resources Management Department.

    Where individuals may file complaints concerning Health Information Privacy:

                     Region IV, Office for Civil Rights                             (404) 562-7886
                     Department of Health and Human Services            (404) 562-7881   FAX
                     Atlanta Federal Center, Suite 3B70                         (404) 331-2867  TDD
                     61 Forsyth Street, SW
                     Atlanta, GA  30303-8909

    For more information about the HIPAA Privacy rule or to obtain a copy of the Office for Civil Rights (OCR) Complaint Form you may contact any OCR office or go to internet site  www.hhs.gov/ocr/hipaa/.