The Counseling Center staff provides confidential services. Professional ethics and laws protect one's privacy, although there are a few exceptions. These exceptions include a court order, imminent danger to oneself or others, and child or elder abuse. Otherwise, any information disclosed from the Counseling Center will only be released with the student's written permission.

Exceptions
There are some exceptions, although they are rare. A court of law can order us to release counseling records and we must comply. And if we believe there is imminent danger to your life or the life of another person we will do what is necessary to reduce that danger, even if that requires us to contact someone else.

Notice of privacy practices
Counseling records are kept separate from all other academic files to ensure that students' privacy and confidentiality are maintained. No information is released without the knowledge and written consent of the student except for those rare instances where clinicians are required by law or by court order to reveal particular information. This notice describes how mental health information about you may be used and disclosed by the St. Norbert College Counseling Center and how you can get access to this information. Please review this notice carefully.

Understanding your protected health information (PHI)

When you visit the Counseling Center, a record is made which consists of your mental health information. Your record is the physical property of the medical health care provider, the information within belongs to you. Being aware of what is in your record will help you to make more informed decisions when authorizing disclosure to others. In using and disclosing your protected health information (PHI), it is our objective to follow the privacy standards of the Federal Health Insurance Portability and Accountability Act (HIPAA) and requirements of Wisconsin law.

Your mental health and/or medical record serve as:

• A basis for planning your care and treatment.
• A means of communication among the mental health professionals who may contribute to your care.
• A legal document describing the care you received.
• A tool with which we can assess and continually work to improve the care we render and the outcomes we achieve.

Responsibilities of the Counseling Center concerning your PHI

The Counseling Center will:

• Maintain the privacy of your PHI as required by law and provide you with notice of our legal duties and privacy practices.
• Abide by the terms of this notice currently in effect. We have the right to change our notice of privacy practices and to make the new provisions effective for all protected health information that we maintain, including that obtained prior to the change. Should our information practices change, we will post new changes and provide you with a copy.
• Notify you if we are unable to agree to a requested restriction.
• Accommodate reasonable requests to communicate with you about your PHI by alternative means or at alternative locations.
• Use or disclose your health information only with your authorization except as described in this notice.

Your PHI rights

You have the right to:

• Review and obtain a paper copy of the notice of information practices upon request. You may also be informed about what is contained in your PHI. Reviewing material in a Counseling Center record needs to be requested in writing and needs the approval of the director of the Counseling Center. PHI will usually be given in summary form and if possible should include the presence of the treating therapist.
• Request and provide written authorization and permission to release information (both verbally and/or in writing) for purposes of outside treatment and health care operations.
• Revoke your authorization in writing at any time to use, disclose or restrict health information except to the extent that action has already been taken.
• Request a restriction on certain uses and disclosures of your PHI. The Counseling Center may not be required to agree to the restriction request. You should address restriction requests, in writing, to the director of the Counseling Center.
• Request that we amend your health information. This request must be submitted in writing, with the reasons supporting the amendment.
• Obtain an accounting of disclosures of your health information for purposes other than treatment and care operation and certain other activities for the last six years, but not before April 14, 2003.

Disclosures for treatment and health operations

The Counseling Center will use your PHI, with your consent, in the following circumstances:

• Disclosure to others outside of the Counseling Center
  If you give the Counseling Center written authorization, we will discuss (verbally and/or in writing) information that is mutually agreed upon between you and your therapist with an outside party. You may revoke a written authorization permitting a release of your PHI at any time. However, the revocation will not affect any use or disclosures permitted by your authorization while it was in effect. The Counseling Center will not use or disclose your PHI without your authorization except as described below:

• For health care operations: With your permission, members of the Counseling Center may use information in your health record to assess the performance, operations and outcome of services.
• General contact: With your permission, the Counseling Center may contact you to provide appointment reminders, information about treatment alternatives, other health-related benefits and services that may be of interest to you. You will be asked how you would like the Counseling Center staff to contact you, e.g. phone (with the type of information that may be conveyed) and/or letter. The Counseling Center does NOT use e-mail as a form of communication with students receiving therapeutic services.

The Counseling Center will use your PHI, without your consent or authorization, in the following circumstances:

• Child abuse
  If the Counseling Center has reasonable cause to suspect that a child has been, or is in danger of abuse, neglect or threatened with abuse or neglect, a report must be make to a relevant county department, child welfare agency, police or sheriff's department.
• Adult and domestic abuse
  If the Counseling Center has reasonable cause to suspect that an elder person is the victim of abuse, neglect, domestic violence or other crimes, a report may be filed with the relevant county department or state official.
• Serious threat to health or safety
  If the Counseling Center has reasonable cause to suspect, exercising best judgment and professional care and skill, that you may cause harm to yourself or another person, steps may be taken to notify or assist in notifying a family member, personal representative, College official(s), police and/or anyone else who may help maintain your or another's physical safety. A plan may be developed which requires an assessment for commitment proceedings.
• Judicial or administrative proceedings
  If you are involved in a court proceeding and a request is made for information about your diagnosis, treatment and/or mental health records, such information is privileged under state law and will NOT be released without written authorization from you or your personal or legally-appointed representative. The privilege does not apply when a third party is evaluating you or where the evaluation is court ordered. A court order may also require, without your consent, the release of Counseling Center records.
• As required by law for national security and law enforcement
  We may disclose your health information, under certain circumstances, to military authorities. The Counseling Center may disclose to authorized federal officials health information required for lawful intelligence, counterintelligence and other national security activities. The Counseling Center may also disclose health information for law enforcement purposes as required by law or in response to a valid subpoena.
• Law/health oversight
  As required by law, we may disclose your health information for investigative purposes. For example, if the Wisconsin Department of Regulation and Licensing requests that we release records to them in order for the Psychology Examining Board to investigate a complaint against a provider, we must comply with the request.
• As required by law for purposes of public health
  The Counseling Center may disclose your health information to public health or legal authorities charged with preventing or controlling disease, injury or disability.
• Consultation/office management
  Therapists may consult with other Counseling Center therapists to help mange and coordinate your treatment. Administrative staff (e.g. office manager/receptionist) may also have limited access to your PHI.
• Business associates
  There are some services the Counseling Center provides that may require contacts with business associates. Examples include: computer support for scheduling, note-taking and scoring of diagnostic tests. When these services are contracted, we may disclose your health information to our business associates. Business associates will safeguard your information.

If you have questions and would like additional information, please ask your clinician who will provide you with more information or help you schedule an appointment with the director of the Counseling Center.

If you are concerned that your privacy rights have been violated, or if you disagree with a decision the Counseling Center has made about access to your health information, or if you would like to make a request to amend or restrict the use or disclosure of your health information, you may discuss these issues with your therapist or you may contact the director of the Counseling Center.

If you believe that your privacy rights have been violated, you may also file a complaint with the Secretary of the U.S. Department of Health and Human Services. The director of the Counseling Center will provide you with the address for filing a complaint upon request.

The Counseling Center respects your right to the privacy of your health information. There will be no retaliation in any way for filing a complaint with the U.S. Department of Health and Human Services or any other appropriate agency, department or person.