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NOTICE OF PRIVACY PRACTICES

Effective Date: October 23, 2025 (original issue date 10/21/2014)

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.

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1. Our Commitment to Your Privacy

Hop Brook Counseling Center is required by law to maintain the privacy of your Protected Health Information (PHI) and to provide you with this Notice of our legal duties and privacy practices. We are required to abide by the terms of the Notice currently in effect. 

This Notice supersedes and replaces all previous Notices of Privacy Practices, including the one dated October 2014. We reserve the right to change this Notice at any time, and any changes will apply to all PHI we maintain, including information we created or received before the change. If we make a material change to our privacy practices, we will post the revised Notice on our website and have copies available upon request.

 

2. Uses and Disclosures for Treatment, Payment, and Health Care Operations (TPO)

We may use and disclose your PHI without your written authorization for the following purposes:

A. Treatment

We may use and disclose your PHI to provide, coordinate, or manage your health care and related services. This includes consultation with other health care providers, such as a primary care physician or a psychiatrist, regarding your treatment.

B. Payment

We may use and disclose your PHI to obtain payment for the services we provide. Examples include, but are not limited to:

  • Submitting claims to your insurance company.

  • Determining your eligibility or coverage for benefits.

  • Billing you or a third party directly for services.

C. Health Care Operations

We may use and disclose your PHI for our own health care operations, which include activities necessary for us to run our practice and ensure quality care. Examples include:

  • Quality assessment and improvement activities.

  • Training programs for staff or students.

  • Business planning and development, such as administrative, legal, and accounting services.

 

3. Uses and Disclosures That Require Your Written Authorization

We will not use or disclose your PHI for purposes other than TPO and those described in Section 4 without your specific written Authorization. You have the right to revoke an authorization at any time, in writing.

Use/Disclosure: 

Marketing: We must obtain your written Authorization for any use or disclosure of PHI for marketing purposes where we receive financial remuneration for making the communication.

Sale of PHI: We must obtain your written Authorization before disclosing your PHI in exchange for direct or indirect payment, which is considered a "sale" of PHI under the law.

Psychotherapy Notes: We must obtain a separate written Authorization for any use or disclosure of psychotherapy notes, except for limited purposes such as use for our own treatment, training, or to defend ourselves in a legal action.

 

4. Your Rights Regarding Your Protected Health Information (PHI)

You have the following rights regarding the PHI we maintain about you:

A. Right to Request Restriction of Uses and Disclosures 

You have the right to request restrictions on our use and disclosure of your PHI for treatment, payment, or health care operations. We are not required to agree to your request, EXCEPT in one situation:

  • Mandatory Restriction for Self-Pay: If you pay for an item or service in full and out-of-pocket, and you request a restriction on disclosure to your health plan (for purposes of carrying out payment or health care operations), we are required to honor that restriction, unless the disclosure is otherwise required by law.

B. Right to Receive Confidential Communications

You have the right to request that we communicate with you about your PHI in a certain way or at a certain location. For example, you may ask that we only contact you at work or via email. We will accommodate all reasonable requests.

C. Right to Inspect and Copy Your Record

You have the right to inspect and obtain a copy of your PHI that is contained in a designated record set for as long as we maintain the PHI.

  • We may charge you a reasonable, cost-based fee for copying, postage, or other supplies associated with your request.

  • If you request an electronic copy (e.g., via email or on a portable media), we must provide it in the requested format if it is readily producible.

D. Right to an Accounting of Disclosures 

You have the right to receive a list of certain non-routine disclosures we have made of your PHI for the six years prior to the request date.

  • Inclusions: The list will include disclosures for purposes such as public health, law enforcement, or as required by law.

  • Exclusions: The list will not include disclosures for TPO where the disclosure was not made electronically.

  • HITECH/EHR: We use an Electronic Health Record (EHR), we are currently exploring the requirements to provide an accounting of disclosures made electronically for Treatment, Payment, and Health Care Operations (TPO), as required by the HITECH Act. This right may be subject to future regulatory guidance.

E. Right to Amend

You have the right to request an amendment of PHI we maintain about you if you feel the information is incorrect or incomplete. We may deny your request if the information is accurate and complete, was not created by us, or is not part of the designated record set.

F. Right to a Paper Copy of This Notice

You have the right to a paper copy of this Notice, even if you have agreed to receive this notice electronically.

 

5. Special Circumstances and Mandatory Updates

A. Uses and Disclosures Related to Substance Use Disorder (SUD) Records (42 CFR Part 2) 

Our records containing information regarding treatment for substance use disorder (SUD) are protected by both HIPAA and the federal regulations known as 42 CFR Part 2, which are generally more stringent.

  • Single Consent: The 2024 update to Part 2 allows you to provide a single written consent for all future uses and disclosures of your SUD records for treatment, payment, and health care operations (TPO).

  • Redisclosure: If we disclose your SUD records for TPO under your single consent, the recipient (if a HIPAA Covered Entity or Business Associate) may further disclose those records as permitted by HIPAA.

  • Prohibition on Criminal/Civil Use: Even with your consent, federal law generally prohibits the use or disclosure of your SUD records in any criminal, civil, administrative, or legislative proceedings against you without your specific authorization or a court order meeting specific criteria.

  • SUD Counseling Notes: Notes documenting a SUD counseling session must be maintained separately and require separate written consent for disclosure, similar to psychotherapy notes under HIPAA.

B. Disclosures for Certain Government Agencies and Law Enforcement

We may disclose your PHI without your authorization for specific public health, legal, or safety purposes, including:

  • To report suspected abuse, neglect, or domestic violence as required or permitted by law.

  • To a correctional institution or law enforcement official if you are an inmate.

  • For workers’ compensation or other similar programs.

  • For judicial and administrative proceedings in response to a court order or subpoena (with certain limitations).

 

6. Mobile and Electronic Communication Privacy 

This section outlines the privacy practices specific to data collected from your mobile device or through electronic communication channels we operate, such as text messaging services for appointment reminders or general communication.

 

A. Mobile Data Privacy and Non-Marketing Disclosure

Any information we may collect from your mobile device (including your phone number, device identifiers, or interaction data with our communications) will be treated with the same confidentiality as your Protected Health Information (PHI), subject to the following limitations:

  • No mobile information will be shared with third parties/affiliates for marketing/promotional purposes.

  • All other categories of data sharing exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

B. Text Messaging and Other Electronic Communication

By opting in to our text messaging service (e.g., for appointment reminders or communication with your provider), you consent to receiving those messages. Standard messaging and data rates may apply.

  • Security: While we use secure, encrypted platforms for Protected Health Information (PHI) whenever possible, communications via standard, unencrypted text messages carry an inherent risk of disclosure. By opting in, you acknowledge this risk.

  • Opt-Out: You have the right to opt out of our text messaging services at any time. Your decision to opt out will not affect your ability to receive treatment.

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7. Privacy Officer Contact Information and Complaints

If you have questions about this Notice or believe your privacy rights have been violated, you may contact:

Kimberly O’Connor, Owner

Hop Brook Counseling Center, LLC 

202 Playhouse Corner 77 Main St. North Southbury, CT 06488 

or 

Hop Brook Counseling Center, LLC 1187 Queen Street Southington, CT 06489 

kim@hopbrookcc.com

You may also file a complaint with the Secretary of the U.S. Department of Health and Human Services (HHS).

We will not retaliate against you for filing a complaint.

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