Privacy Policy

Last modified: September, 2022

This policy describes the types of information that Care Coordination Systems, LLC (“CCS” or “We”) may collect from you or that you may provide when you use the Community Health Record applications (“the CHR Applications”) and associated software in the course of your employment, and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy applies to information we collect when you use any of the CHR Applications, and in email, text, and other electronic messages between you and your employer and CCS.

This policy does not apply to client information entered by you into the CHR Applications. That information is protected by law and by Business Associate Agreements between CCS, your employer, and the Community Hub with which your employer is affiliated (“the Community Hub”).

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using the CHR Applications, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy below). Your continued use of the CHR Applications after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Information We Collect About You and How We Collect It

CCS collects several types of information from and about users of the CHR Applications, including:

  • information by which you may be personally identified such as name, e-mail address, or any other identifier by which you may be contacted online or offline (“personal
  • information”);information that is about you but individually does not identify you, such as the name of your employer and the information which you enter into the CHR
  • Applications; and information about your internet connection, the equipment you use to access the CHR Applications, and usage details.

We collect some information directly from you when you or your employer provides it to us, and other information (such as information about your computer and internet connection, including your IP address, operating system, and browser or tablet type)

automatically as you use the CHR Applications. The information we collect automatically is statistical and technical data and not personal information, but we may tie this information to personal information about you that you or your employer provide to us.

How We Use Your Information

  • We use information that we collect about you or that you provide to us, including any personal information:
  • to verify that you are a “Licensed User” of the CHR Applications;
  • so that you, your employer, and the Community Hub may store data in and make use of the CHR Applications to provide care coordination services;
  • to provide technical support to you, your employer, and the Community Hub;
  • in any other way we may describe when you provide the information; and,
  • for any other purpose with your consent.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this privacy policy:

  • to your employer, the Community Hub, and entities with which they have contracted to provide care coordination services;
  • to contractors, service providers, and other parties we use to support our business, and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them; and
  • to fulfill the purpose for which you provide it;
  • for any other purpose disclosed by us when you provide the information; and,
  • with your consent.

We may also disclose your personal information:

  • to comply with any court order, law, or legal process, including to respond to any government or regulatory request.

  • to enforce or apply the terms of our license of the CHR Applications; and

  • if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of CCS, our customers, care coordination clients, or others.

CCS does not provide personal information to third parties for marketing purposes.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. You are responsible for keeping the password you use for access to the CHR Applications confidential. Do not share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of personal information transmitted to our system in the course of using the CHR Applications. Any transmission of personal information is at your own risk. We are not responsible for circumvention of the security measures contained within the CHR Applications.

Contact Information

Our General Counsel and Chief Information Security Officer, Michael P. Morley, is our senior privacy officer. To ask questions or comment about this privacy policy, or for any other questions regarding our privacy policies and practices, contact him at general.counsel@ccs.health.