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Privacy and Multichannel Health Information Policy

Health Connect Wounds Solutions

Version 1.0 | Proposed effective date: [INSERT DATE]

Legal entity: Health Connect Wounds Solutions
EIN: 39-3511785
Applies to: Patients, prospective patients, providers, referral sources, facilities, business partners, prospective medical partners, and users of our approved communication and connected-service channels.

Important: This public-facing policy explains how information is handled across our clinical, connected-care, and communication systems. It supplements, but does not replace, our HIPAA Notice of Privacy Practices (NPP). The NPP governs uses and disclosures of protected health information (PHI) and explains patients' HIPAA rights. If this policy conflicts with the NPP or applicable law, the NPP and applicable law control.

1. Our privacy commitment

Health Connect Wounds Solutions (“Health Connect,” “we,” “us,” or “our”) provides and coordinates medical services, including wound care, podiatry, primary and specialty care support, telehealth, remote patient monitoring (RPM), chronic care management (CCM), scheduling, eligibility verification, care coordination, billing support, and patient notifications.

We protect information according to the sensitivity of the information, the purpose for which it was collected, the channel through which it was received, and applicable federal and California law. We use administrative, physical, and technical safeguards intended to preserve confidentiality, integrity, and availability.

2. Information we collect

Depending on the relationship and service, we may collect:

  • Identity and contact information, including name, date of birth, address, telephone number, email, preferred language, communication preferences, and authorized representative details.
  • Health and clinical information, including diagnoses, symptoms, medications, allergies, treatment plans, wounds and clinical images, orders, progress notes, device readings, care-management information, and communications with the care team.
  • Insurance, eligibility, authorization, billing, claims, and payment information.
  • Referral and professional information, including provider identifiers, facility details, credentials, licenses, contracts, and network or partnership inquiries.
  • Scheduling and engagement information, including appointment status, reminders, telephone interactions, portal messages, consent and opt-out choices.
  • Technical and security information, such as account activity, authentication events, audit logs, device/browser information, and information needed to protect our systems.
  • Website or social-media information that a person chooses to submit. Public social-media channels should not be used to send medical information.

We seek to collect only information reasonably necessary for care, payment, operations, legal compliance, security, or the purpose described at collection.

3. How we use information

We may use information to:

  • Provide, coordinate, document, and improve patient care.
  • Schedule visits; verify eligibility; obtain authorizations; send reminders; and coordinate with patients, providers, facilities, pharmacies, laboratories, health plans, and authorized representatives.
  • Support RPM, CCM, RTM, telehealth, device onboarding, clinical alerts, follow-up, and care-plan activities.
  • Submit claims, collect payment, reconcile accounts, and perform lawful health care operations.
  • Respond to questions, requests, complaints, records requests, and partnership inquiries.
  • Maintain quality, safety, compliance, training, auditing, business continuity, and fraud-prevention programs.
  • Establish and manage provider, facility, vendor, or medical-group partnerships.
  • Meet legal, regulatory, payer, accreditation, reporting, and contractual duties.

We do not sell PHI. We do not use PHI for unrelated advertising or permit vendors to use PHI to train general-purpose artificial-intelligence models unless the use is legally permitted, contractually authorized, appropriately safeguarded, and approved through our privacy process.

4. Our systems and information flow

4.1 Office Ally electronic health record

Office Ally, including its applicable practice-management or EHR functions, is our primary approved repository for the medical and practice record. Information stored there may include patient demographics, appointments, encounters, progress notes, orders, eligibility, claims-related information, and clinically important communications.

Material information received through another channel is entered, attached, or summarized in the EHR when necessary for treatment, continuity of care, the designated record set, billing, or compliance. Communication tools are not substitutes for the official medical record.

4.2 Health Connect ONE connected-services platform

Health Connect ONE supports approved connected-care services such as RPM, CCM, RTM, care coordination, device onboarding, monitoring, alerts, patient engagement, and reporting. We limit information exchanged between Health Connect ONE and other systems to information reasonably needed for the service.

Clinically significant readings, alerts, interventions, and care-plan communications are reviewed by authorized personnel and documented or summarized in Office Ally when required for continuity of care or the official record. Connections are expected to use authenticated and encrypted methods, logging, access controls, and monitoring for failed transmissions.

4.3 CRM, scheduling, and operational systems

Approved customer-relationship-management (CRM), intake, scheduling, and operational tools may contain limited information needed to manage referrals, appointments, reminders, outreach, authorizations, partnership discussions, and service coordination. Detailed clinical records should remain in Office Ally or an approved clinical platform unless a documented workflow requires otherwise.

Access is based on job responsibilities. Free-text fields must not be used as an uncontrolled medical record, and exports or bulk downloads require a legitimate business purpose and authorization.

5. Communication channels

Channel How information is handled
Amazon Connect, telephone, and voicemail We may use approved call-center functions for scheduling, notifications, intake, service coordination, and quality. We verify identity before discussing sensitive information. Calls may be recorded or transcribed only when configured and permitted, with legally required notice. Voicemail content is limited according to patient preferences and the minimum necessary principle.
Text messages and automated reminders We may send appointment, care-coordination, device, or service messages through approved systems. Standard SMS may not be fully secure. We keep messages limited and neutral when feasible, avoid sensitive diagnoses or detailed results, and honor applicable opt-out choices. Patients should call 911 for emergencies and should not use automated channels for urgent symptoms.
Email We use managed business accounts and approved secure-message or encryption methods when appropriate. Sensitive information should not be sent to personal or unapproved accounts. We verify recipients and attachments before sending.
Patient portal and secure chat These are preferred for sensitive electronic communications when available. Access requires authentication, and clinically important content is maintained or summarized in the official record.
CRM systems CRM data is limited to the operational purpose, protected with role-based access and audit capabilities, and linked to the authoritative record when feasible. CRM information is not used for unrelated marketing.
Social media and online reviews We do not provide medical advice, confirm patient status, or discuss PHI in public posts, comments, reviews, groups, or direct messages. If someone contacts us through social media, we may provide a general response and direct the person to an approved private channel. For privacy reasons, our response to a review will not confirm that the reviewer is or was a patient.
Website forms and chat functions We collect only information needed for the stated purpose and use secure transmission where appropriate. Medical emergencies and detailed clinical information should not be submitted through general contact forms. We evaluate analytics, pixels, and tracking technologies to prevent impermissible disclosure of PHI.
Fax Approved fax services may be used for referrals, orders, records, and care coordination. We verify fax numbers, use appropriate confidentiality notices, and investigate misdirected transmissions.
Telehealth, photographs, and video We use approved platforms and obtain required consent. Clinical images or recordings are created only when appropriate, protected as part of the medical record, and not stored on personal devices. Routine recording is disabled unless authorized and necessary.
Paper and in-person communication We take reasonable steps to prevent public conversations and unauthorized viewing. Paper records, schedules, labels, and notes are secured, transported appropriately, and destroyed through approved methods.

We do not authorize use of personal email, consumer file-sharing accounts, unapproved messaging applications, public AI tools, or unmanaged devices to handle PHI.

6. Information sharing

We may share information as permitted or required by law, including with:

  • Treating and consulting providers, pharmacies, laboratories, facilities, home health agencies, hospices, and other participants in care.
  • Health plans, clearinghouses, billing partners, and parties involved in payment or authorization.
  • Service providers that support EHR, connected care, communications, CRM, hosting, security, analytics, records, scheduling, or operations.
  • Medical partners, MSO personnel, and contractors performing authorized functions for Health Connect.
  • Public health, oversight, law-enforcement, judicial, workers' compensation, or other authorities when legally permitted or required.
  • A patient's authorized representative or another recipient authorized by the patient.

When a vendor or partner is a HIPAA business associate, we require an appropriate Business Associate Agreement (BAA). Contracts are expected to restrict use, require safeguards, address subcontractors and incidents, and govern return or destruction of information. We apply the minimum necessary standard when it is required.

Information subject to heightened protection—including certain behavioral-health, psychotherapy, substance-use-disorder, HIV, genetic, reproductive-health, or minor records—is handled according to the additional requirements that apply.

7. Patient choices and communication preferences

Patients may tell us their preferred telephone number, email, language, communication method, whether a detailed voicemail may be left, and who may receive information on their behalf. We may ask for written authorization or identity documentation before acting on certain requests.

Opting out of promotional messages does not prevent treatment, payment, safety, or other service communications that the law permits us to send. Message and data rates may apply to text messages. Because ordinary email and SMS can carry privacy risk, patients may request a more confidential method when reasonably available.

8. Patient privacy rights

Subject to applicable law and the procedures in our Notice of Privacy Practices, patients may have the right to:

  • Receive our Notice of Privacy Practices.
  • Inspect or obtain a copy of records in a designated record set.
  • Request correction or amendment of information.
  • Request confidential communications or certain restrictions.
  • Receive an accounting of certain disclosures.
  • Authorize or revoke authorization for uses or disclosures that require authorization.
  • Submit a privacy complaint without retaliation.

We verify identity and authority before fulfilling a request. Requests may be subject to legal limitations, required forms, and permitted fees. Please use the contact information in Section 15 to obtain the current NPP or submit a request.

9. Provider and medical-partner information

Providers, referral sources, facilities, and prospective medical partners may give us professional contact details, credentials, licensure and enrollment information, tax and payment details, contracts, referral information, and operational communications. We use this information to evaluate and manage relationships, verify qualifications, coordinate patient services, establish system access, administer agreements, and meet legal or payer requirements.

Access to PHI is not granted merely because an organization is considering a partnership. Before PHI is shared, Health Connect confirms the purpose and legal basis, establishes required agreements (including a BAA when applicable), approves system access, and applies role-based and minimum-necessary controls.

10. Security safeguards

Our safeguards are designed around the HIPAA principles of confidentiality, integrity, and availability and may include:

  • Unique user identification, role-based access, least privilege, and periodic access review.
  • Multifactor authentication where supported, managed passwords, automatic screen locks, and timely removal of access.
  • Encryption in transit and at rest where reasonable and appropriate.
  • Audit logs, monitoring, secure configurations, endpoint protection, patching, backup, recovery, and downtime procedures.
  • Workforce privacy and security training, confidentiality obligations, sanctions, and phishing awareness.
  • Vendor review, BAAs, secure integration standards, incident duties, and return or destruction requirements.
  • Physical access controls, secure work areas, clean-desk practices, and controlled disposal.

No system is completely secure. We continuously evaluate risk and improve safeguards based on law, technology, operations, and identified threats.

11. Incident and breach response

We maintain procedures to identify, report, contain, investigate, mitigate, and document suspected privacy or security incidents. This includes lost devices, misdirected messages, wrong-patient information, unauthorized access, malware, credential compromise, improper social-media contact, and failed system interfaces.

When an event involves PHI, we perform the assessment required by applicable law, coordinate with relevant vendors or partners, take corrective action, and provide legally required notice to affected individuals, government agencies, or others. Patients and partners should immediately report suspected incidents through the contact in Section 15.

12. Data quality, correction, and system reconciliation

We take reasonable steps to keep information accurate and complete. When information arrives through multiple channels, authorized staff reconcile duplicates or conflicts and route clinically important information to the appropriate provider. We do not silently overwrite material clinical history. Corrections, amendments, late entries, and interface errors are handled through controlled procedures that preserve required audit history.

13. Retention and secure disposal

We retain medical, billing, operational, communication, call-recording, consent, audit, and partnership records according to applicable law, payer and contractual duties, approved retention schedules, and any legal hold. Different record types may have different retention periods.

At the end of the applicable period, paper and electronic information is securely destroyed or rendered unreadable and unrecoverable using approved methods. Backup copies remain protected and age out according to validated backup schedules. A relationship ending does not automatically require deletion when retention is required for medical, legal, billing, audit, or security purposes.

14. Children and personal representatives

We handle information about minors and individuals with personal representatives according to applicable consent, custody, authority, confidentiality, and access rules. We may request documentation establishing a representative's authority. In some circumstances, the law may limit a representative's access or give a minor specific privacy rights.

15. Contact us

Health Connect Wounds Solutions
EIN: 39-3511785
Privacy Officer: David Cepeda
Mailing address: 1660 W Shaw Ave. Suite 256, Fresno, CA
Telephone: (833) 516-9993
Secure email or request portal: admin@healthconnectmso.com

Please do not send urgent medical information or detailed PHI through a public social-media page or a general website contact form. For a medical emergency, call 911.

Patients may also submit a complaint to the U.S. Department of Health and Human Services Office for Civil Rights. We will not retaliate for a good-faith privacy complaint.

16. Changes to this policy

We may update this policy to reflect changes in law, technology, services, vendors, or information practices. The current version will identify its effective date. Material changes will be communicated through an appropriate channel. Changes do not reduce rights already provided by applicable law.

17. Policy governance and required review

Before publication, Health Connect should complete the following:

  • Insert the effective date.
  • Confirm that the legal entity name and EIN match the entity delivering care and issuing the NPP.
  • Confirm all Office Ally, Health Connect ONE, Amazon Connect, CRM, SMS, email, fax, website, telehealth, analytics, and social-media vendors and data flows.
  • Verify that required BAAs and service agreements are fully executed.
  • Approve call-recording, transcription, retention, and sensitive-data suppression settings.
  • Approve patient consent and opt-out language for voicemail, SMS, email, remote monitoring, telehealth, photography, and recording.
  • Validate that websites and authenticated pages do not impermissibly transmit PHI to pixels, advertising platforms, session-replay tools, or analytics providers.
  • Align this document with the HIPAA Notice of Privacy Practices, patient authorizations, information-security policies, retention schedule, and incident-response plan.
  • Obtain review by qualified health care privacy counsel before adoption and publication.

References

  • U.S. Department of Health and Human Services, HIPAA Security Rule, 45 C.F.R. Parts 160 and 164, Subparts A and C: https://www.hhs.gov/hipaa/for-professionals/security/index.html
  • U.S. Department of Health and Human Services, HIPAA Breach Notification Rule, 45 C.F.R. Part 164, Subpart D: https://www.hhs.gov/hipaa/for-professionals/breach-notification/index.html
  • U.S. Department of Health and Human Services, Model Business Associate Agreement: https://www.hhs.gov/sites/default/files/model-business-associate-agreement.pdf
  • California Confidentiality of Medical Information Act, California Civil Code sections 56 et seq.: https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?division=1.&chapter=1.&part=2.6.&lawCode=CIV&title=

Document owner: Health Connect Wounds Solutions
Version: 1.0
Approved: May 31, 2026
Next review: May 31, 2027