CONFIDENTIALITY

SUSPECTED ABUSE OF A CHILD, DEPENDENT ADULT, OR ELDER:

The therapist is required by law to report suspected abuse of a child, dependent adult, or elder to the appropriate authorities immediately.

THREAT OF SERIOUS BODILY HARM TO ANOTHER PERSON(S):

If a client is threatening serious bodily harm to another person(s), including potential communication of a life-threatening disease, the therapist must notify the police and inform the intended victim. 

THREAT OF SELF-HARM:

If a client intends to harm him- or herself, the therapist will make every effort to enlist their cooperation in ensuring their safety. If the client does not cooperate, the therapist will take further measures without their permission that are provided to the therapist by law in order to ensure the client's safety. 

PRIVACY POLICIES

FOR TREATMENT:  

Your PHI may be used and disclosed by those who are involved in your care for the purpose of providing, coordinating, or managing your health care treatment and related services. This includes consultation with clinical supervisors or peer review members. We may disclose PHI to any other consultant ONLY with your authorization.

FOR PAYMENT:

We may use and disclose PHI so that we can receive payment for the treatment services provided to you. This will only be done with your authorization. Examples of payment-related activities are: making a determination of eligibility or coverage for insurance benefits, processing claims with your insurance company, reviewing services provided to you to determine medical necessity, or undertaking utilization review activities. If it becomes necessary to use collection processes due to lack of payment for services, we will only disclose the minimum amount of PHI necessary for purposes of collection.

FOR HEALTH CARE OPERATIONS:

We may use or disclose, as needed, your PHI in order to support our business activities, including but not limited to: quality assessment activities, employee review activities, licensing, and conducting or arranging for other business activities. For example, we may share your PHI with third parties that perform various business activities (ex. billing or typing services) provided we have a written contract with the business that requires it to safeguard the privacy of your PHI. For training purposes, PHI will be disclosed ONLY with your authorization. Your PHI will also be used to remind you of your appointments. 

USES & DISCLOSURES REQUIRING AUTHORIZATIONS:

You may give written permission, which allows us to use or disclose PHI for purposes other than treatment, payment, or healthcare operations. We will always obtain your written permission before releasing your psychotherapy notes, which are notes about our conversation during private, group, joint, or family counseling sessions. These notes are given a greater degree of protection than PHI.

REVOCATION OF AUTHORIZATION: 

You may revoke this authorization at any time, in writing, except to the extent that your therapist or the therapist's practice has taken an action on the use or disclosure indicated in the authorization. If the authorization was obtained as a condition of obtaining insurance coverage and the law provides the insurer the right to contest the claim under the policy, you may not revoke this authorization.

USES & DISCLOSURES WITHOUT CONSENT OR AUTHORIZATION:

We may use or disclose PHI without your consent or authorization in the following circumstances: instances of child abuse, instances of adult abuse, instances of abuse of an elderly person or disabled adult, health oversight, judicial or administrative proceedings only as required by law, serious threat to health or safety, medical emergency, worker's comp claims, or as required by law.

YOUR RIGHTS REGARDING YOUR PHI

RIGHT OF ACCESS TO INSPECT & COPY:

You have the right, which may be restricted only in exceptional circumstances, to inspect and copy PHI that may be used to make decisions about your care. Your right to inspect and copy PHI will be restricted only in those situations where there is compelling evidence that access would cause serious harm to you.

RIGHT TO REQUEST AMENDMENT:

If you feel that the PHI we have about you is incorrect or incomplete, you may ask to amend the information, although we are not required to agree to the amendment.

RIGHT TO AN ACCOUNTING OF DISCLOSURES:

You have the right to request an accounting of certain of the disclosures that we make of your PHI. We may charge you a reasonable fee if you request more than one accounting in any twelve-month period.

RIGHT TO REQUEST RESTRICTIONS:

You have the right to request a restriction or limitation on the use or disclosure of your PHI for treatment, payment, or health care operations. We are not required to agree to your request.

RIGHT TO REQUEST CONFIDENTIAL COMMUNICATION:

You have the right to request that we communicate with you about medical matters in a certain way or at a certain location.

RIGHT TO A COPY OF THIS NOTICE:

You have the right to a copy of this notice. 

SOCIAL MEDIA COMMUNICATION POLICY

Some of the relevant ethical codes to consider in the context of Thrive’s social media policy state: 

• Therapists do not disclose client confidences except by written authorization or waiver, or where mandated or permitted by law. 
  
• Verbal authorization will not be enough except in emergency situations, unless prohibited by law. 
  
• When providing couple, family, or group treatment, the therapist does not disclose information outside the treatment context without a written authorization from each individual competent to execute a waiver. 
  
• In the context of couple, family, or group treatment, the therapist man not reveal any individual’s confidences to others in the client unit without the prior written permission of that individual. 
  
• Therapists are aware of their influential positions with respect to clients, and they avoid exploiting the trust and dependency of such persons. Therapists therefore make every effort to avoid conditions and multiple relationships with clients that could impair professional judgement or increase the risk of exploitation. Such relationships include, but are not limited to, business or close personal relationships with a client or the client’s immediate family. When the risk of impairment or exploitation exists due to conditions or multiple roles, therapists take appropriate precautions. 

EMAILS, CELL PHONES, COMPUTERS, AND FAXES ARE NOT PRIVATE:

No form of client communication is 100% guaranteed to be private. Conversations can be overheard, emails can be sent to the wrong recipients, and phone conversations can be listened to by others. But in today’s age of email, Facebook, Twitter and other social media, therapists must be more aware than ever of the ethical pitfalls they can fall into by using these types of communication. 

Although they add convenience and expedite communication, it is important to be aware that computers, email, and cell phone communication can be accessed relatively easily by unauthorized people and therefore can compromise the privacy and confidentiality of such communication. Emails are vulnerable to such unauthorized access since servers have unlimited and direct access to all emails that go through them. Although you may be using various encryption software programs to protect your privacy, emails and data on computers may not be encrypted, faxes can be sent erroneously to the wrong address, and computers, including laptops, may be stolen. It is best if your computer(s) are equipped with a firewall, virus protection, and passwords. You should password-protect and back up all confidential information from your computers on a regular basis. 

IF YOU NEED TO CANCEL OR CHANGE AN APPOINTMENT TIME:

A telephone call or SMS (text) may get the message to your Thrive therapist in a timely manner. Please notify your therapist if you decide to avoid or limit, in any way, the use of emails, cell phones, SMS (text), faxes, or storage of confidential information on computers. If you communicate confidential or private information via SMS (text) or email, your therapist will assume that you have made an informed decision in reaching out to them via any of these means of communication. They will view it as your agreement to take the risk that such communication may be intercepted, and will honor your desire to communicate on such matters via email and SMS. Please do not use emails or faxes for emergency communication. Due to computer or network problems, emails may not be deliverable, and your therapist may not check emails or faxes daily. 

If your email content is related to your therapy sessions, please note that emails are not completely secure or confidential. If email communication outside of therapy requires more than 5 minutes to read and respond to, you may be charged for the professional services rendered in 15-minute increments. Please indicate if you intend to pay these charges, or your therapist will save the email communication for review during your appointment time. Please do not send forwarded messages, regardless of how inspirational they may seem, to your therapist’s professional email address. Therapists use their professional email accounts for work-related issues, and do not want to risk viruses spread by forwarded emails.

SOCIAL MEDIA SHOULD BE CONSIDERED PUBLIC COMMUNICATION:

Messaging on social networking sites such as Twitter, Facebook, or LinkedIn is not secure. Using Wall postings, @replies, or other means of engaging with your therapist online could comprise your confidentiality if you have already established a client/therapist relationship. It may also create the possibility that these exchanges will become a part of your legal medical record and will need to be documented and archived in your chart. Your therapist may not read these messages in a timely fashion. If you need to contact your therapist between sessions, the best way to do so is by phone. 

Friending may expose you and your therapist’s professional relationship and undermine your privacy. This social network policy serves as your notification that being linked as friends or contacts on these sites can compromise your confidentiality and our respective privacy. As in any other public context, you have control over your own description of the nature of your relationship with your therapist, if you choose to disclose a professional relationship. For example, if you see your therapist at church or school and you ignore him/her, they would follow your lead and do the same. If you introduce him/her to your friends, he/she would agree to your description of how you know them. Your therapist will not confirm or deny any professional relationship between themselves or their clients on any social network sites. Thrive therapists reserve the right to discontinue any social network connection without prior notification, and they encourage you to do the same. Thrive therapists discourage the use of social network sites for any communication about the therapeutic relationship, including scheduling issues, due to the lack of privacy protection. In addition, viewing your online activities without your consent and without an explicit arrangement towards a specific purpose could potentially have a negative influence on your working relationship. If there are things from your online life that you wish to share with your therapist, please bring them into your sessions where you and your therapist can view and explore them together, during the therapy hour. Thrive’s current treatment agreement states that each therapist keeps client information private and does not share it with others, unless there is reason to believe that the client or another individual is at risk. It is easy to forget that when we type names into a search engine or a field on a social network, we are also sharing information with others. If you have questions about this, please bring them up when you meet with your therapist. 

LOCATION-BASED SERVICES REVEAL YOUR LOCATION: 

If you use location-based services (LBS) on your mobile phone, you may wish to be aware of the privacy issues related to using these services. Thrive is not placed as a check-in location. However, if you have GPS tracking enabled on your device, it is possible that others may surmise that you are a therapy client due to regular check-ins at the Thrive office on a weekly basis. Please be aware of this risk if you are intentionally checking in from the Thrive office or if you have a passive LBS app enabled on your phone. 

Therapists do not use search engines to learn about you, so it is NOT a regular part of their practice to search for clients on Google, Facebook, or other search engines. Extremely rare exceptions may be made during times of crisis. If a therapist has a reason to suspect that you are in danger and you have not been in touch via the usual means, there might be an instance in which using a search engine becomes necessary as part of ensuring your welfare. These are unusual situations, and if a therapist ever resorts to a search means, it will be fully documented and discussed with you when you meet. 

BUSINESS REVIEW SITES ARE INEFFECTIVE PLACES TO VOICE YOUR COMPLAINTS:

You may find Thrive’s practice on sites such as Yelp, Healthgrades, Yahoo, Local, Bing, or other places which list businesses. Some of these sites include forums in which users rate their providers and add reviews. Many of these sites comb search engines for business listings and automatically add listings regardless of whether the business has added itself to the site. If you should find your therapist or Thrive listed on any of these sites, please know that this listing is NOT a request for a testimonial, rating, or endorsement from you as a client. Of course, you have the right to express yourself on any site you wish. But due to confidentiality, Thrive cannot respond to any review on any of these sites, whether it is positive or negative. You are urged to take your own privacy as seriously as Thrive takes its commitment of confidentiality to you. 

You should also be aware that if you are using these sites to communicate indirectly with a therapist about your feelings regarding their work, there is a good possibility that your review, rating, or other comment may never be seen. Thrive and our team of therapists hope that you will bring your feelings and reactions to our work directly into the therapy process. This can be an important part of therapy, even if you decide we are not a good fit. None of this is meant to keep you from sharing that you are in therapy or seeing a Thrive therapist whenever and with whomever you like. 

If you do choose to write something on a business review site, we hope you will keep in mind that you may be sharing personally revealing information in a public forum. We urge you to create a pseudonym that is not linked to your regular email address or a friend’s network for your own privacy and protection. 

CONCLUSION: 

Thank you for taking the time to review Thrive’s Client Social Media Communication Policy. If you have any question or concerns about any of these policies and procedures, or regarding your potential interactions with your therapist on the Internet, do bring them to your therapist’s attention so that you may discuss them.