Consumer Health Data Privacy Policy
Introduction
This Consumer Health Data Privacy Policy applies to consumer health data collected, used, or shared by Concierge Care, Inc., doing business as Concierge Care Advisors ("Concierge Care," "we," "us," or "our"). It is a standalone policy provided in accordance with Washington's My Health My Data Act (RCW 19.373).
"Consumer health data" means personal information that is linked or reasonably linkable to a consumer and that identifies the consumer's past, present, or future physical or mental health status.
This policy is specific to consumer health data. Our general Privacy Policy describes how we handle other categories of personal information. Where the two overlap, this Consumer Health Data Privacy Policy governs our handling of consumer health data.
1. Categories of Consumer Health Data We Collect, and Why
We collect consumer health data in order to understand a consumer's care needs, generate care recommendations and cost estimates, match consumers with appropriate care providers, and arrange referrals and placement. Depending on the services a consumer uses, the categories of consumer health data we may collect include:
- Health conditions and diagnoses;
- Medications and medication-management needs;
- Functional limitations and the assistance a person needs with activities of daily living;
- Behaviors or symptoms that require special or specialized care;
- Mental illness, dementia, or developmental disability status;
- Care preferences;
- Cultural and language needs;
- Financial information relating to how care will be funded, including long-term care insurance and Medicaid status.
Purpose of collection and use. We use the consumer health data described above to assess the level and type of care a person needs; to generate personalized care recommendations, cost estimates, and summaries; to match consumers with care providers and communities that fit their needs; to arrange and support referrals, tours, and placement; to communicate with the consumer and their authorized representatives; and to comply with our legal and recordkeeping obligations. We do not use consumer health data for purposes other than those described in this policy.
2. Categories of Sources
We collect consumer health data from the following categories of sources:
- Directly from the consumer;
- From the consumer's authorized caregivers or legal representatives;
- From care communities and care providers;
- From healthcare providers, where applicable;
- Automatically through our application, based on information the consumer or their representative enters.
3. Categories of Consumer Health Data We Share
The categories of consumer health data we may share include health conditions and diagnoses; functional limitations and assistance needs; behaviors or symptoms requiring special care; mental illness, dementia, or developmental disability status; care preferences; cultural and language needs; and information relating to how care will be funded. We share these categories only as necessary to evaluate the suitability of a care provider or community, to arrange a referral or placement the consumer has requested, or with service providers that process data on our behalf as described in Section 4.
We do not sell consumer health data, and we do not offer consumer health data for sale. Under the My Health My Data Act, "sale" means the exchange of consumer health data for monetary or other valuable consideration. If this ever changed, we would first obtain a separate, valid authorization from the consumer as required by law.
4. Categories of Third Parties and Affiliates With Whom We Share Consumer Health Data
We may share consumer health data with the following categories of third parties:
- Care providers and communities. Assisted living, memory care, adult family homes, in-home care, independent living, continuing care, and skilled nursing providers to whom a referral is made. Health information is shared as necessary to evaluate suitability and arrange placement.
- Cloud infrastructure and hosting providers. Data is stored and processed on infrastructure operated by our hosting provider.
- Artificial intelligence and automated processing providers. Information entered into our tools may be processed by third-party AI services to generate care recommendations, cost estimates, and summaries.
- Document and speech processing providers. Uploaded documents and recorded calls may be processed by third-party services to extract text.
- Communications providers. Email, SMS, and messaging services used to correspond with consumers and their representatives.
- Analytics and application monitoring providers. Services used to understand usage and maintain reliability.
- Referral partners. Organizations participating in our partner or employer programs that receive referral information.
Affiliates. Concierge Care, Inc. does not share consumer health data with any affiliates.
5. Your Rights and How to Exercise Them
If you are a Washington consumer, the My Health My Data Act gives you the following rights with respect to your consumer health data:
- Right to confirm. To confirm whether we are collecting, sharing, or selling your consumer health data, and to access that data.
- Right to a list of recipients. To obtain a list of all third parties and affiliates with whom we have shared your consumer health data, along with a way to contact each recipient.
- Right to withdraw consent. To withdraw your consent to our collection and sharing of your consumer health data.
- Right to delete. To have your consumer health data deleted.
How to submit a request. You, or an authorized agent acting on your behalf, may submit a request by emailing privacy@conciergecareadvisors.com, calling (855) 444-7364, or writing to us at the address in the Contact section below. We may need to verify your identity before acting on a request, to protect your information.
Our response. We will respond to your request within 45 days of receipt. When reasonably necessary, we may extend that period by an additional 45 days and will notify you of the extension and the reason for it. Deletion requests are honored within 30 days, subject to data we are legally required to retain (see Section 6). If we decline to act on your request, we will tell you why, and you may appeal that decision by replying to our response or contacting us using the details above.
6. Data Retention and Deletion
We retain consumer health data only as long as necessary for the purposes described in this policy, except where a longer retention period is required by law.
As a licensed Washington senior placement and referral agency, we are required by RCW 18.330.040(3) to retain referral records — including a copy of the consumer's disclosure and intake forms — for a minimum of six years. Consumer health data contained in those referral records is retained for that period as required by law.
When we delete consumer health data in response to a request, we delete it from all parts of our system, including archived and backup systems, and we notify our affiliates, processors, and contractors of the deletion request so that they can delete the data they hold on our behalf. Deletion is subject to data we are legally required to retain, such as the referral records described above; where we cannot delete data because the law requires us to keep it, we will tell you.
7. Consent
Using our website or application, or accepting our Terms of Service or general Privacy Policy, does not constitute your consent to the collection or sharing of your consumer health data. We do not treat continued use of our services as consent for consumer health data.
Where collecting consumer health data is necessary to provide a product or service you have requested, the My Health My Data Act permits that collection without separate consent. We collect and use consumer health data only for that purpose — to provide the products and services you request — and not for secondary purposes.
We do not rely on implied consent for consumer health data.
8. Contact Information
Concierge Care, Inc.
2608 2nd Avenue, Suite 224
Seattle, WA 98121
privacy@conciergecareadvisors.com
(855) 444-7364