Notice of Privacy Practices
As a health care provider and educational institution, we keep a record of the services we provide you. This notice of privacy practices is being provided to you as required by law. It describes how we may use or disclose your personal health information (PHI) and it explains your rights to access and control your records under certain circumstances. PHI includes written and verbal health information that relates to your past, present, or future mental health condition as well as demographic data that can be used to identify you.
Please review this information carefully.
If the Counseling and Wellness Center (CWC) creates health related records while you are a Western Washington University student, these records are considered “treatment” records when used and shared for the purpose of treatment and limited healthcare operations and are protected under privacy laws. When used or shared for reasons other than treatment and limited healthcare operations, including when you request access to them, they are considered “educational” records protected under the Family Educational and Privacy Act (FERPA) under most circumstances. See WAC 516.26 – Student Records. Western is committed to safeguarding access to student records as well as maintaining individual student privacy.
Other than those stated below, we will not disclose your health information other than with your written authorization. You may revoke your authorization in writing at any time except to the extent that we have taken action in reliance upon that authorization.
Typical Use
How we typically use or share your health information without your written authorization:
- We use your health information and share it with other professionals who are or will treat you.
Example: Your therapist at the CWC reviews your treatment plan with a psychiatrist in a specialty to whom you have agreed to be referred.
- On a limited basis, we use and share your health information to run our practice only when necessary.
Example: The CWC staff shares information about you to coordinate your treatment and related services.
Non-typical Use
We may also use and/or share your health information without your written authorization for the following non-typical situations and with only the minimum amount of information necessary for the intended purpose:
- For oversight activities authorized by law such as audits, inspections, or for the purpose of accreditation to ensure quality of care.
- In compliance with legal processes such as a subpoena.
- Litigation situations between the University and the student.
- If we, in good faith, provide personal health information to appropriate parties when it is believed you pose an articulable and significant threat to yourself or the health and safety of other individuals.
- In rare circumstances such as for national security and intelligence activities.
- Even if you are deceased your personal health information still warrants protection and will be sensitively cared for.
- Only under special circumstances will a limited disclosure be made such as to a medical examiner, or parent.
The CWC will disclose treatment records without client consent regarding sexually transmitted diseases and/or mental health records only when mandated by law (RCW Chapter 70). All other instances, even when permitted by law, we will obtain your written authorization in advance of the disclosure.
In certain circumstances, a minor (under 18 years of age) client’s health information may receive additional protections.
- Generally, you have the right to request to inspect, review and obtain copies of your educational records except as provided in WAC 516-26.
- Such requests require a completed Authorization to Disclose/Release Protected Health Information Form submitted to CWC. The form is available on the CWC’s website or can be requested from the front desk.
- You have the right to reasonably request the CWC provide an explanation or interpretation of the content of your record.
- You may ask the response to be provided to you verbally or in writing.
- You have the right to request the correction or deletion of content in your record if you believe it is inaccurate, misleading, or otherwise is inappropriate data.
- You have the right to challenge a decision to deny your request.
- Requests for corrections and deletions and challenges must be made in accordance with University requirements under WAC 516-26.
- You have the right to challenge the release of your record to specific persons as contrary to the provisions of WAC 516-26 or challenge a decision by the University to deny you access to particular types of records.
- Challenges must be made in accordance with University requirements under WAC 516-26.
- You have the right to request to receive communications from us in a specific way or location. For example, you can ask us to restrict communications with you to phone calls only at a specific number.
- We will accommodate reasonable requests permitted by law.
- Please provide this information on the Client Information Form or in writing to front office staff if your preference changes.
You can request a paper or electronic copy of this notice any time or you may access it on our website or in our reception and waiting areas.
- You can request that we not use or share certain health information.
- We are not required to agree to your request, and we may say “no” if, for example, it would threaten your health or violate a law.
- We will honor your request to not disclose to your health plan information or services for which you paid out of pocket prior to the performance of such services.
- You may make your request by submitting the Request to Limit Information form.
- You can ask for a list (an accounting) of disclosures we’ve made with your health information for as long as we are legally required to maintain those records.
- Exceptions to record keeping of disclosures may apply as required or permitted by law.
- To make such a request, submit a Request for an Accounting of Non-Routine Disclosures Form to the CWC.
- You can complain if you feel we have violated your rights by filing a complaint with one or all of the following:
- The CWC Director
- Western Washington University’s FERPA Officer
- Western Washington University’s HIPAA Privacy Officer
- The Washington State Department of Health
- U.S. Department of Education
- We take your concerns and complaints seriously and will not retaliate against you for filing a complaint.
- Procedure: See the “Contact Information” section of this web page.
- We are required by law to maintain the privacy and security of your protected health information.
- We will only share the minimum necessary information with others.
- 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.
- We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.
Changes to the Terms of This Notice
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, in our office, and on our web site. The effective date of this notice is stated at the bottom left of the document.
WWU Counseling and Wellness Center Director
Dr. CJ Swanlund
swanluc@wwu.edu
360-650-3164
Washington State Department of Health
Customer Service
hsqa.csc@doh.wa.gov
360-236-4700
WWU FERPA Compliance Officer/Registrar
Shelli Soto
Shelli.Soto@wwu.edu
360-650-3432
WWU HIPAA Privacy Officer/ University Compliance Manager
Nicole Goodman
nicole.goodman@wwu.edu
360-650-2477
U.S. Dept. of Education/Office for Civil Rights
OCR@ed.gov
800-421-3481
400 Maryland Avenue, SW
Washington, DC 20202-1100