Summary of Notice of Privacy Practices

We understand that your health information is highly personal, and we are committed to safeguarding your privacy. This summary notice is shortened for easier understanding. The full Notice of Privacy Practices is also available to you on our website and in our care areas.

This notice describes how medical information about you may be used and shared and how you can get access to this information. Please review it carefully.

For part 2 substance use disorder records, this notice describes:

• How Part 2 health information about you may be used and disclosed
• Your rights with respect to your health information
• How to file a complaint concerning a violation of the privacy or security of your health information, or of your rights concerning your information

You have a right to a copy of this notice (in paper or electronic form) and to discuss it with our privacy officer at 833-718-1043 or privacyofficer@trinity-health.org if you have any questions.

Your Rights

You have the right to:

• Get a copy of your paper or electronic medical record
• Correct your paper or electronic medical record
• Request confidential communication
• Ask us to limit the information we share
• Get a list of those with whom we have shared your information - Accounting of Disclosures
• Get a copy of this privacy notice
• Choose someone to act for you
• File a complaint if you believe your privacy rights have been violated

Your Choices

You have some choices in the way that we use and share information as we:

• Tell family and friends about your condition
• Provide disaster relief
• Include you in a hospital directory
• Provide mental health care
• Market our services and sell your information
• Raise funds

How do we typically use or share your health information?

We typically use or share your health information in the following ways.

Treat you

We can use your health information and share it with others who are treating you.

This notice covers all treatment locations including hospitals, clinics, and substance use disorder treatment, which is called a Part 2 Program.

We provide medical treatment and have substance use disorder treatment programs that are covered by Federal regulations set out in 42 CFR Part 2 (a “Part 2” Program). If you receive this type of care, you may be asked to sign a general consent for treatment form for the Part 2 Program. Written authorization for treatment, payment, and operations purposes may be obtained once and can support future uses of health information for treatment, payment, and operations purposes without additional authorization under HIPAA.

Run our organization

We can use and share your health information to run our health system, improve your care, and contact you when necessary.

We use technology to support care and treatment that may use Artificial Intelligence (AI). Artificial intelligence technology uses health information to train and improve AI functionality. Our technology partners, including those with AI technology, must keep health information confidential under applicable law.

Bill for your services: We can use and share your health information to bill and get payment from health plans or other entities.

How else can we use or share your health information?

We are allowed or required to share your health information in other ways – usually in ways that contribute to the public good, such as public health and research. We must meet certain conditions in the law before we can share your information for these purposes.

Help with public health and safety issues: We can share health information about you for certain situations such as:

• Preventing disease
• Helping with product recalls
• Reporting adverse reactions to medications
• Reporting suspected abuse, neglect, or domestic violence
• Preventing or reducing a serious threat to anyone’s health or safety

Do research: We can use or share your information for health research.

Follow the law: We will share information about you if state or federal laws require it, including with the Department of Health and Human Services if it wants to see that we are complying with federal privacy law.

Respond to organ and tissue donation requests: We can share health information about you with organ procurement organizations.

Work with a medical examiner or funeral director: We can share health information with a coroner, medical examiner, or funeral director when an individual dies.

Workers’ compensation, law enforcement, and other government requests: We can use or share health information about you:

• For workers’ compensation claims
• For law enforcement purposes or with a law enforcement official
• With health oversight agencies for activities authorized by law
• For special government functions such as military, national security, and presidential protective services

Respond to lawsuits and legal actions

• We can share health information about you in response to a court or administrative order, or in response to a subpoena
• If we have substance use disorder patient records about you, subject to 42 CFR Part 2, we cannot use or share information in those records in civil, criminal, administrative, or legislative investigations or proceedings against you without (1) your consent or (2) a court order and a subpoena

Our Responsibilities

• We are required by law to maintain the privacy and security of your protected health information
• We will let you know if a breach occurs that may have compromised the privacy or security of your information
• We must follow the duties and privacy practices described in this notice and give you a copy of it
• We will not use or share your information other than as described in this notice unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind

Changes to the Terms of this Notice

We can change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available upon request, in our care areas, and on our web site.

Stricter State and Federal Law: If a privacy law applies and it is stricter than HIPAA, we will follow it.

Health Information Exchange ("HIE"): If available, we will share your health information with an HIE to share with other care providers. Your health information may include sensitive information. The HIE will transmit and store your health information. The HIE must protect your health information. State law may let you opt-out of the HIE. For more information, please contact our privacy officer at 833-718-1043 or email privacyofficer@trinity-health.org.

Sharing and Use of Your Health Information: To help improve your care, we may share your health information with others. Trinity Health is a national Catholic health care system, which includes other hospitals, nursing homes, and health care providers. We do share your health information to coordinate your care along with other clinical and business-related activities of Trinity Health.

• Medical Staff: We are in an Organized Health Care Arrangement ("OHCA") with medical staff. This means we share health information with medical staff for operations. It also means medical staff agree to follow terms in this Notice
• Business Associates: We may share health information with other companies as part of our business functions

Complaints: If you believe your privacy rights have been violated, you may file a complaint with our Privacy Officer or with the Secretary of the Department of Health and Human Services. Complaints can be submitted to us at privacyofficer@trinity-health.org, or by calling 833-718-1043, or in writing to our system privacy officer at: 20555 Victor Parkway, Livonia, MI 48152.

You will not be retaliated against for filing any complaint.