NOTICE OF PRIVACY PRACTICES

EFFECTIVE NOVEMBER 2020

YOUR INFORMATION. YOUR RIGHTS. OUR RESPONSIBILITIES.
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.

YOUR RIGHTS
When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you.

Exercising Your Rights: You may exercise any of your below rights by visiting the Patient Rights page or completing the
Member Complaint/Grievance Form, or calling Member Services at 800.877.7195.

YOUR RIGHTS
YOUR RIGHTS
Get a copy of your health and claims records	You can ask to see or get a copy of your health and claims records and other health information we have about you. We will provide a copy of your health and claims records, usually 10 business days from receipt of your request.
Ask us to correct health and claims records	You can ask us to correct your health and claims records if you think they are incorrect or incomplete. We may say "no" to your request, but we'll tell you why in writing 10 business days from receipt of your request.
Request confidential communications	You can ask us to send your protected health information directly to you at an alternative address. We will consider all reasonable requests and must say "yes" if you submit legal documentation that shows us you would be in danger if we do not.
Ask us to limit what we use or share	You can ask us not to use or share certain health information for treatment, payment, or our operations. We are not required to agree to your request, and we may say "no" if it would affect payment or your health care services.
Get a copy of this privacy Notice	You can ask for a paper copy of this Notice at any time, even if you have agreed to receive the Notice electronically. We will provide you with a paper copy promptly.
Get a list of those with whom we've shared information	You can ask for a list (accounting) of the times we’ve shared your health information for six years (non-electronic PHI) or three years (electronic PHI) prior to the date you ask, who we shared it with, and why. We will include all the disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make). We’ll provide one accounting a year for free but may charge a reasonable, cost-based fee if you ask for another one within 12 months.
Choose someone to act for you	If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information. We will make sure the person has this authority and can act for you before we take any action.
File a complaint if you feel your rights are violated	You can complain if you feel we have violated your rights by submitting a written complaint using the contact information included in this Notice or by completing the Member Complaint/Grievance Form. You can file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 877.696.6775, or visiting Filing a Complaint. We will not retaliate against you for filing a complaint.

YOUR CHOICES
For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in situations described below, talk to us. Tell us what you want us to do, and we will follow your instructions.

YOUR CHOICES
YOUR CHOICES
In these cases, you have both the right and choice to tell us to:	Share information with your family, close friends, or others involved in payment for your care. Share information in a disaster relief situation. If you are not able to tell us your preference, we may share your information when needed to lessen a serious and imminent threat to health or safety.
In these cases, we never share your information unless you give us written permission:	Marketing purposes. Sale of your information.

OUR USES AND DISCLOSURES
How do we typically use or share your health information? We typically use or share your health information in the following ways:

OUR USES AND DISCLOSURES
OUR USES AND DISCLOSURES
Help manage the health care treatment you receive	We can use your health information and share it with professionals who are treating you.	Example: We may share information about your eye condition to another health care professional to assist in their treatment of you.
Run our organization	We can use and disclose your health information to run our organization and contact you when necessary. VSP does not collect genetic information.	Example: We use health information about you to conduct quality assessment and improvement activities or audits (e.g. fraud and abuse detection and compliance programs).
Pay for your health services	We can use and disclose your health information as we pay for your health services.	Example: We share health information about you with your health plan to determine eligibility, process claims or coordinate payment for covered services you receive under your benefit plan.
Communicate with you	We can use your health information to communicate with you for treatment and healthcare operations purposes.	Example: We use health information about you to communicate refill reminders or contact you to remind you of appointments or to communicate with you about our health-related products or services, or recommend alternative treatments.

How else can we use or share your health information? We are allowed or required to share your information in other ways – usually in ways that contribute to the public good, such as for public health and research purposes. We have to meet many conditions in the law before we can share your information for these purposes. For more information visit the Department of Health & Human Services Your Rights Under HIPAA.

INFORMATION
INFORMATION
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	VSP does not use or collect protected health information for research purposes.
Comply with 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’re complying with federal privacy law.
Respond to organ and tissue donation requests and work with medical examiner or funeral director	We can share health information about you with organ procurement organizations. We can share health information with a coroner, medical examiner, or funeral director when an individual dies.
Address 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, legal actions or complaints	We can share health information about you in response to a court or administrative order, in response to a subpoena or for the limited purpose of investigation and resolution of a complaint or inquiry related to our product.

ADDITIONAL APPLICABLE LAW REQUIREMENTS:
VSP will abide by more stringent state and federal laws where applicable.

OUR RESPONSIBILITIES

We are required by law to maintain the privacy and security of your protected health information.
Breach Notification: We will let you know promptly 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.
Right to Revoke: If you tell us we can share your information other than as described in this Notice, you may change your mind at any time. Let us know in writing if you change your mind.
For more information see Department of Health & Human Services Notice of Privacy Practices.

SPECIAL NOTES

VSP does not collect genetic information and is prohibited from using or disclosing genetic information for underwriting purposes.
VSP does not collect substance abuse treatment records and will never share any substance abuse treatment records without your written permission.
Nondiscrimination Statement: VSP complies with applicable Federal civil rights laws and does not discriminate on the basis of race, color, national origin, age, disability, or sex.
Notice Revisions: 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, on our website, and we will notify you by mail or email.

CONTACT INFORMATION
Contact VSP if you have questions about your privacy rights, believe that we may have violated your privacy rights, or disagree with a decision that we made about access to your PHI, you may contact us at the following address or email:

Contact VSP
VSP Global
Attention: Privacy Office
3333 Quality Drive
MS-163
Rancho Cordova CA 95670
HIPAA@vsp.com