Romi Cumes Somatic Therapy, P.C. is committed to protecting the privacy of our website visitors and clients. These Privacy Policies explain how we collect, use, and share information about you.
Privacy Policy – Updated 6/14/2023
Romi Cumes Somatic Therapy, P.C. is committed to protecting the privacy of our website visitors and clients. This Privacy Policy explains how we collect, use, and share information about you.
Information We Collect
We collect information about you when you visit our website, sign up for our newsletter, or contact us. The information we collect may include your name, email address, phone number, and other submitted information. We may also collect information about your computer, such as your IP address and browser type.
How We Use Your Information
We use the information we collect to provide you with the services you request, such as scheduling appointments, sending newsletters, and responding to your inquiries. We may also use your information to improve our website and services.
Cookies and Other Tracking Technologies
The service providers we use to manage our website and services use cookies and other tracking technologies to collect information about visitors’ usage of our website. Our intention for any cookies or tracking technologies used by our site to only track activity while on our site. This information may include the pages you visit, the links you click, and the time you spend on our website. We use this information to improve our website and services, and to respond to your requests.
You can opt-out of cookies and other tracking technologies by changing your browser settings. However, if you do this, you may not be able to use all of the features of our website.
Sharing Your Information
We do not ever intend to sell any of the information we collect. However, we may share relevant elements of your information with our third-party service providers who help us provide you with our services. For example, we use third-party service providers to send our newsletters and manage our appointment scheduling. We also use various WordPress and Google Analytics services to manage and improve our website. We do not intend at any time to share your personal information with third parties without your consent.
We may also share your information with law enforcement or other government agencies if required to do so by law or in the good faith belief that such action is necessary to:
- Comply with the law or a legal process served on us;
- Protect the rights, property, or safety of our users, our website, or others; or
- Investigate, prevent, or take action regarding potential violations of our policies, or as otherwise reasonably necessary.
California Online Privacy Protection Act (CalOPPA)
We strive to comply with the California Online Privacy Protection Act (CalOPPA) requirements, which provides California residents with specific rights regarding their personal information:
- Third-Party Tracking
We do not intend to authorize the collection of personally identifiable information about your online activities over time and across different websites and online services when you use our website or services. The only purpose we have for any sort of tracking that may be enabled at any time on our site is for management and improvement of the site, and in order to respond to requests made by visitors of our site. - Do Not Track Signals
We currently do not respond to “Do Not Track” signals or similar mechanisms. As there is no industry-standard practice for recognizing and honoring these signals, we do not alter our data collection and usage practices in response to them. However, you have the option to manage your cookie preferences as outlined in the “Cookies and Other Tracking Technologies” section of this Privacy Policy. - California Shine the Light Law Under California’s “Shine the Light” law, California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the information provided in the “Contact Us” section below.
- Minors
Our website and services are not intended for individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have collected personal information from a minor without parental consent, we will take steps to delete that information. If you believe we may have collected personal information from a minor, please contact us using the information provided in the “Contact Us” section below.
Your Rights
You have the right to access the information we collect about you. You also have the right to request that we correct or delete your information. To exercise these rights, please contact us using the information provided in the “Contact Us” section below.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time. If and when we do make material changes to our policy, we will post the updated version on our website. We encourage visitors to check this page periodically and reference the date at the top of this policy.
Contact Us
If you have any questions about this Privacy Policy, please contact us using the general contact form at https://romicumes.com/contact/
This notice for psychotherapy clients under the care of Romi Cumes Somatic Therapy, P.C. describes how health information may be used and disclosed and how clients can get access to this information. This policy document is one of the forms that will be issued for acknowledgement as part of the psychotherapy client intake process, but we are making it available here on the website as well in the interest of transparency. The terms and conditions of this policy do not apply to general website visitors and service inquiries, only actual psychotherapy clients under the care of Romi Cumes Somatic Therapy, P.C. who go through the official client intake process.
The text of this policy document is as follows:
THIS NOTICE DESCRIBES HOW HEALTH INFORMATION MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
I. OUR PLEDGE REGARDING HEALTH INFORMATION:
We understand that health information about you and your health care is personal. We are committed to protecting health information about you. We create records of the care and services you receive from us. We need these records to provide you with quality care and to comply with certain legal requirements. This notice applies to all of the records of your care generated by this mental health care practice. This notice will tell you about the ways in which we may use and disclose health information about you. We also describe your rights to the health information we keep about you and describe certain obligations we have regarding the use and disclosure of your health information. We are required by law to:
Make sure that protected health information (“PHI”) that identifies you is kept private.
Give you this notice of our legal duties and privacy practices with respect to health information.
Follow the terms of the notice that is currently in effect.
We can change the terms of this Notice, and such changes will apply to all information we have about you. The new Notice will be available upon request, in our office, and on our website.
II. HOW WE MAY USE AND DISCLOSE HEALTH INFORMATION ABOUT YOU:
The following categories describe different ways that we use and disclose health information. For each category of uses or disclosures, we will explain what we mean and try to give some examples. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will fall within one of the categories.
For Treatment Payment or Health Care Operations: Federal privacy rules (regulations) allow health care providers who have a direct treatment relationship with the patient/client to use or disclose the patient/client’s personal health information without the patient’s written authorization to carry out the health care provider’s own treatment, payment, or health care operations. We may also disclose your protected health information for the treatment activities of any health care provider. This too can be done without your written authorization. For example, if a clinician were to consult with another licensed health care provider about your condition, we would be permitted to use and disclose your personal health information, which is otherwise confidential, to assist the clinician in the diagnosis and treatment of your mental health condition.
Disclosures for treatment purposes are not limited to the minimum necessary standard. Because therapists and other health care providers need access to the full record and/or full and complete information in order to provide quality care. The word “treatment” includes, among other things, the coordination and management of health care providers with a third party, consultations between health care providers, and referrals of a patient for health care from one health care provider to another.
Lawsuits and Disputes: If you are involved in a lawsuit, we may disclose health information in response to a court or administrative order. We may also disclose health information about your child in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute, but only if efforts have been made to tell you about the request or to obtain an order protecting the information requested.
III. CERTAIN USES AND DISCLOSURES REQUIRE YOUR AUTHORIZATION:
Psychotherapy Notes. We do keep “psychotherapy notes” as that term is defined in 45 CFR § 164.501, and any use or disclosure of such notes requires your Authorization unless the use or disclosure is: a. For our use in treating you. b. For our use in training or supervising mental health practitioners to help them improve their skills in group, joint, family, or individual counseling or therapy. c. For our use in defending ourselves in legal proceedings instituted by you. d. For use by the Secretary of Health and Human Services to investigate our compliance with HIPAA. e. Required by law and the use or disclosure is limited to the requirements of such law. f. Required by law for certain health oversight activities pertaining to the originator of the psychotherapy notes. g. Required by a coroner who is performing duties authorized by law. h. Required to help avert a serious threat to the health and safety of others.
Marketing Purposes. As psychotherapists, we will not use or disclose your PHI for marketing purposes.
Sale of PHI. As psychotherapists, we will not sell your PHI in the regular course of our business.
IV. CERTAIN USES AND DISCLOSURES DO NOT REQUIRE YOUR AUTHORIZATION:
Subject to certain limitations in the law, we can use and disclose your PHI without your Authorization for the following reasons:
When disclosure is required by state or federal law, and the use or disclosure complies with and is limited to the relevant requirements of such law.
For public health activities, including reporting suspected child, elder, or dependent adult abuse or preventing or reducing a serious threat to anyone’s health or safety.
For health oversight activities, including audits and investigations.
For judicial and administrative proceedings, including responding to a court or administrative order, although our preference is to obtain an Authorization from you before doing so.
For law enforcement purposes, including reporting crimes occurring on our premises.
To coroners or medical examiners when such individuals are performing duties authorized by law.
For research purposes, including studying and comparing the mental health of patients who received one form of therapy versus those who received another form of therapy for the same condition.
Specialized government functions, including ensuring the proper execution of military missions, protecting the President of the United States, conducting intelligence or counter-intelligence operations, or helping to ensure the safety of those working within or housed in correctional institutions.
For workers’ compensation purposes. Although our preference is to obtain an Authorization from you, we may provide your PHI to comply with workers’ compensation laws.
Appointment reminders and health-related benefits or services. We may use and disclose your PHI to contact you to remind you that you have an appointment with us. We may also use and disclose your PHI to tell you about treatment alternatives or other health care services or benefits that we offer.
V. CERTAIN USES AND DISCLOSURES REQUIRE YOU TO HAVE THE OPPORTUNITY TO OBJECT:
Disclosures to family, friends, or others. We may provide your PHI to a family member, friend, or other person that you indicate is involved in your care or the payment for your health care unless you object in whole or in part. The opportunity to consent may be obtained retroactively in emergency situations.
VI. YOU HAVE THE FOLLOWING RIGHTS WITH RESPECT TO YOUR PHI:
The Right to Request Limits on Uses and Disclosures of Your PHI. You have the right to ask us not to use or disclose certain PHI for treatment, payment, or health care operations purposes. We are not required to agree to your request, and we may say “no” if we believe it would affect your health care.
The Right to Request Restrictions for Out-of-Pocket Expenses Paid for In Full. You have the right to request restrictions on disclosures of your PHI to health plans for payment or health care operations purposes if the PHI pertains solely to a health care item or a health care service that you have paid for out-of-pocket in full.
The Right to Choose How We Send PHI to You. You have the right to ask us to contact you in a specific way (for example, home or office phone) or to send mail to a different address, and we will agree to all reasonable requests.
The Right to See and Get Copies of Your PHI. Other than “psychotherapy notes,” you have the right to get an electronic or paper copy of your medical record and other information that we have about you. We will provide you with a copy of your record, or a summary of it, if you agree to receive a summary, within 30 days of receiving your written request, and we may charge a reasonable, cost-based fee for doing so.
The Right to Get a List of the Disclosures We Have Made. You have the right to request a list of instances in which we have disclosed your PHI for purposes other than treatment, payment, or health care operations or for which you provided us with an Authorization. We will respond to your request for an accounting of disclosures within 60 days of receiving your request. The list we will give you will include disclosures made in the last six years unless you request a shorter time. We will provide the list to you at no charge, but if you make more than one request in the same year, we will charge you a reasonable, cost-based fee for each additional request.
The Right to Correct or Update Your PHI. If you believe that there is a mistake in your PHI or that a piece of important information is missing from your PHI, you have the right to request that we correct the existing information or add the missing information. We may say “no” to your request, but we will tell you why in writing within 60 days of receiving your request.
The Right to Get a Paper or Electronic Copy of this Notice. You have the right to get a paper copy of this Notice, and you have the right to get a copy of this notice by email. And, even if you have agreed to receive this Notice via email, you also have the right to request a paper copy of it.
EFFECTIVE DATE OF THIS NOTICE
This notice went into effect on July 1st, 2018.
ACKNOWLEDGEMENT OF RECEIPT OF PRIVACY NOTICE:
Under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), you have certain rights regarding the use and disclosure of your protected health information. By checking the box below, you are acknowledging that you have received a copy of HIPAA Notice of Privacy Practices.
This Notice of Privacy Practices form applies to all clinicians employed by Romi Cumes Somatic Therapy, P.C. who may be involved in your care, including (but not limited to):
Romi Cumes Licensed Marriage and Family Therapist #107614
Sara Murdoch Registered Associate Marriage and Family Therapist #139719, Supervised by Romi Cumes, LMFT #107614
To ensure quality care, our Registered Associate Marriage and Family Therapists receive regular supervision. This supervision may take place in person or via technology. Where technology is used, safeguards are applied to ensure your privacy. However, no security protocol provides absolute protection from data loss.
BY CLICKING ON THE CHECKBOX BELOW, I AM AGREEING THAT I HAVE READ, UNDERSTOOD, AND AGREE TO THE ITEMS CONTAINED IN THIS DOCUMENT.