My Health My Data

CONSUMER HEALTH DATA PRIVACY POLICY

Effective Date: March 31, 2024

This Consumer Health Data Privacy Policy (“Policy”) supplements Adventist Health’s Notice of Privacy Practice and applies to (i) residents of the State of Washington and/or (ii) individuals whose consumer health data is collected in the State of Washington (collectively, “you” or “consumers”), and explains how Adventist Health and its subsidiaries and affiliates (“Adventist Health” “we,” “us,” or “our”) Process the Consumer Health Data from or about these consumers pursuant to the Washington My Health My Data Act (“MHMDA”). The capitalized terms used in this Policy have the same meaning given to them in the MHMDA.

 

Under the MHMDA, consumers have the right to receive certain disclosures regarding our processing of “Consumer Health Data,” as defined under the MHMDA, and their rights with respect to such processing. 

In this Policy, “Consumer Health Data” means personal information that is linked or reasonably linkable to a Washington consumer and that identifies the Washington Consumer’s past, present, or future physical or mental health status. Washington Consumer Health Data does not include information that (a) is lawfully made available through federal, state, or municipal government records or widely distributed media, and (b) a regulated entity or a small business has a reasonable basis to believe a consumer has lawfully made available to the general public (“Publicly Available Information”); or data that cannot reasonably be used to infer information about, or otherwise be linked to, an identified or identifiable consumer, or a device linked to such consumer, if the regulated entity or the small business that possesses such data (a) takes reasonable measures to ensure that such data cannot be associated with a consumer; (b) publicly commits to process such data only in a deidentified fashion and not attempt to reidentify such data; and (c) contractually obligates any recipients of such data to satisfy the criteria set forth in the foregoing.(“Deidentified Data”).

This Policy does not apply to (i) Adventist Health’s health care services, such as pharmacy, medical and health plan services or information that would be considered “Protected Health Information” under the Health Insurance Portability and Accountability Act of 1996; and (ii) Adventist Health customers that are not residents of the State of Washington or individuals whose consumer health data is not collected in the State of Washington. Please see our Patient Notice of Privacy Practices for a description of how we use and safeguard Protected Health Information that we collect and use for any health care service.

TABLE OF CONTENTS

  1. Consumer Health Data we collect
  2. Sources we Collect consumer Health Data from
  3. How we use Consumer Health Data
  4. Our disclosure Consumer Health Data
  5. Your rights under state law

1. Consumer Health Data We Collect

We may collect the following categories of personal information from you (which may be Consumer Health Data, if not excluded from the MHMDA), when you browse or engage in transactions through our services. Examples of Consumer Health Data we may collect include:

  • Health-Related Information. When you browse or interact with health-related products or services, we may collect information about your health-related conditions, symptoms, status, diagnoses, testing, or treatments. 
  • Browsing Data. When you browse or interact with our consumer health products or services, we collect information related to your browsing activities, such as the search parameters you use and the consumer health products and services you engage with, which could identify your attempt to seek health care services or information, including services that allow you to assess, measure, improve, or learn about your or another person’s health.
  • Location Information. When you browse or interact with our consumer health products or services, we may collect location information that could reasonably indicate your attempt to acquire or receive health services or supplier. For example, we may collect this information when you click on a certain clinic or put in your zip code on our website to locate a clinic. 

2. Sources of Consumer Health Data 

Adventist Health does not collect your Consumer Health Data unless you voluntarily provide it to us. We collect Consumer Health Data, from the following categories of sources: 

3. How we use Consumer Health Data

We use the Consumer Health Data we collect to address your requests for information or services or respond to your inquiries, send you administrative communications, and for any other purpose for which you provide consent, or as otherwise permitted under applicable law. 

We may use Consumer Health Data for the following purposes:

  • To communicate with you. We use your consumer health data to respond to your requests and otherwise communicate with you about information your request. For instance, we may use your Consumer Health Data to fulfill your requests, contact you with information about your requests, send you email alerts, send you newsletters and provide you with related customer service. We may use your Consumer Health Data to send marketing communications and administrative information. 
  • To provide you with the medical or research services you have requested or authorized, 
  • To tailor content we may send or display on our websites or online content, including to offer location customization and personalized help and instructions, and to otherwise personalize your experiences;
  • Ensuring the secure and reliable operation of the services and the systems that support them, including troubleshooting and improving the services, 
  • Essential business operations that support the provision of the services such as analyzing our performance, meeting our legal obligations, developing our workforce, and conducting research and development, and  
  • Other purposes for which we give you choices or obtain your consent as required by law for example, for advertising or marketing purposes.

Adventist Health will not sell, rent, license, or trade your personal information to third parties for their own direct marketing use unless we receive your express consent.

4. Our Disclosure of Consumer Health Data

While personal information that is not Consumer Health Data may be disclosed as provided in the “Our Disclosure of Personal Information” section of our Notice of Privacy Practice, our disclosure of Consumer Health Data is limited to the following situations:

  • Affiliates. We enable access to data across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access helps us to provide our services and operate our business.
  • Service Providers. Vendors or agents (also known as “processors”) working on our behalf may access Consumer Health Data for the purposes described above. 
  • Business Partners. We may share Consumer Health Data with other companies, for example, where you use a service that is cobranded and jointly operated with another company, or where you use our services to interact with another company. 
  • Legal. We share information where necessary to comply with applicable law, regulation, legal process or to respond to requests from law enforcement agencies or other government authorities, public agencies, parties to litigation or other related third parties, as permitted by law and without your consent when it is necessary to protect our patients, employees, or property; in emergency situations; or to enforce our rights under our terms of service and policies.

5. Your Rights Under the MHMDA

If you are a consumer, as defined under MHMDA, and we collect, use or share your Consumer Health Data subject to MHMDA, you may have certain rights with respect to such Consumer Health Data, including the right to access, delete, or withdraw consent relating to your Consumer Health Data, subject to certain applicable exceptions.

If you are a consumer, you may exercise these rights by contacting us directly via e-mail at: DigitalPrivacy@ah.org. For your security and to ensure unauthorized third parties do not access your Consumer Health Data, we will verify your identity and ability to exercise these rights. Your written request to exercise these rights should include sufficient information to verify your identity and specify the right you wish to exercise. For requests to make changes to inaccurate information, we may ask you to provide documentation that demonstrates why or how the existing information is inaccurate. For any questions or assistance, you may also reach out using the contact information below. 

If your request to exercise a right under the MHMDA is denied, you may appeal that decision by contacting DigitalPrivacy@ah.org and specifying that your request is related to an appeal.

Changes to this Policy

This Policy may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve. When changes to this Policy are significant, we will inform you through this policy page.

How to Contact Us

If you have a privacy concern, complaint, or a question, please contact our Corporate Privacy Officer at (916) 406-0000, or write to us the following postal address: 

Adventist Health
ATTN: Compliance Department
ONE Adventist Health Way
Roseville, CA 95661

Questions?

If you have any questions about this Policy or about Adventist Health’s handling of your information, please contact us.

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