Legal & privacy

Notice of Privacy Practices

This Notice describes how medical information about you may be used and disclosed and how you can access this information. Please review it carefully.

1. Our duties

Pasadena Clinical Group is required by law to:

  • Maintain the privacy of your protected health information ("PHI");
  • Provide you with this Notice of our legal duties and privacy practices with respect to your PHI;
  • Notify you in the event of a breach of unsecured PHI; and
  • Follow the terms of the Notice currently in effect.

We are required to comply with the federal HIPAA Privacy and Security Rules (45 CFR Parts 160 and 164) and the California Medical Information Act ("CMIA," Civil Code §56 et seq.). California law provides protections that, in several respects, are stricter than HIPAA, particularly regarding mental-health records, marketing, and authorized uses. Where state and federal law differ, we apply whichever standard is more protective of your information.

2. How we may use and disclose your protected health information without your authorization

We may use and disclose PHI for the following purposes without separate authorization:

  • Treatment — to provide, coordinate, or manage your care and any related services. For example, we may share PHI with another health-care provider treating you, with your authorization where required by California law.
  • Payment — to obtain reimbursement, verify benefits, and bill insurance carriers, third-party payers, or you directly.
  • Health-care operations — including quality assessment, training, accreditation, licensing, and business management.
  • Required by law — when disclosure is required by federal, state, or local law.
  • Public-health activities — including disease prevention and reporting required by the California Department of Public Health.
  • Abuse, neglect, or domestic violence reporting — including mandatory child-abuse reporting under the California Child Abuse and Neglect Reporting Act (CANRA, Penal Code §11164 et seq.) and elder/dependent-adult abuse reporting under Welf. & Inst. Code §15630.
  • Health oversight activities — such as audits, investigations, and licensure inspections.
  • Judicial and administrative proceedings — pursuant to a court order, subpoena, or other lawful process, with notice to you where required.
  • Law enforcement — under specific, limited circumstances permitted by law.
  • To avert a serious threat to health or safety — including the duty to warn or protect under Tarasoff v. Regents (Civil Code §43.92) when a patient communicates a serious threat of physical violence against a reasonably identifiable victim.
  • Workers' compensation — to the extent authorized by and necessary to comply with workers'-compensation laws.
  • Coroners, medical examiners, funeral directors — as authorized by law.
  • Research — only with appropriate Institutional Review Board approval and, where required, with your authorization.

3. Uses and disclosures requiring your written authorization

The following uses and disclosures require your prior written authorization, which you may revoke at any time:

  • Most uses and disclosures of psychotherapy notes (45 CFR §164.508).
  • Uses or disclosures for marketing, except for face-to-face communications and small promotional gifts.
  • Disclosures that constitute a sale of PHI under HIPAA or that constitute remuneration under CMIA.
  • Disclosures of mental-health records beyond the minimum necessary for treatment, payment, or operations, except where law permits otherwise.

California's CMIA imposes additional authorization requirements; we follow those requirements where they exceed federal HIPAA requirements.

4. Your rights with respect to your PHI

  • Right to inspect and copy your records (HIPAA; Cal. Health & Safety Code §123100 et seq.) — you may inspect and obtain a copy of your records, in the form and format you request where readily producible. Reasonable cost-based fees may apply, consistent with California law.
  • Right to amend — you may request that we amend PHI we maintain about you for as long as the information is kept by or for us. We may deny your request under certain conditions (for example, if we did not create the record), and we will provide you with a written explanation if we deny it.
  • Right to an accounting of disclosures — you may request an accounting of certain disclosures we have made of your PHI, with the limits set out under HIPAA.
  • Right to request restrictions — you may request that we restrict certain uses and disclosures. We are not required to agree to all requests, but where we do agree, we will honor the restriction. Under HIPAA, we must agree to restrict disclosures to a health plan if you have paid for the service in full out of pocket and the disclosure is for payment or operations.
  • Right to confidential communications — you may request that we contact you only at certain locations or by certain means (for example, only by phone, not by email).
  • Right to a paper copy — you have the right to obtain a paper copy of this Notice on request, even if you have agreed to receive it electronically.
  • Right to be notified of a breach of unsecured PHI as required by federal and California law.

5. Special California protections for mental-health records

California law treats mental-health information as particularly sensitive and provides additional protections, including:

  • Specific authorization requirements for disclosure of psychotherapy notes (Civil Code §56.10).
  • Confidentiality protections under the Lanterman-Petris-Short Act (Welf. & Inst. Code §5328) where applicable to information collected in the course of mental-health treatment.
  • Heightened patient consent requirements for the release of substance use disorder treatment records under federal 42 CFR Part 2. Pasadena Clinical Group's substance use programs hold themselves out as providing substance use disorder services, so 42 CFR Part 2 applies to those records. Disclosure of Part 2-protected records generally requires specific written patient consent or compliance with one of the regulation's narrow exceptions, and unauthorized disclosure carries criminal penalties (42 USC §290dd-2). Re-disclosure of Part 2 records by a recipient requires the same consent.

6. Records retention

Adult patient records are retained for a minimum of seven (7) years from the date of last service. Records of patients who are minors are retained for at least seven years from the last date of service or until one year after the patient reaches the age of majority (whichever is later). Records may be retained longer at our discretion.

7. Complaints

If you believe your privacy rights have been violated, you may file a complaint with:

  • Pasadena Clinical Group's Privacy Officer (see contact below).
  • The Secretary of the U.S. Department of Health & Human Services, Office for Civil Rights — https://www.hhs.gov/ocr/.
  • The California Attorney General's Office.

We will not retaliate against you for filing a complaint.

8. Changes to this Notice

We reserve the right to change this Notice at any time and to make the revised Notice effective for all PHI we maintain. Revised Notices will be posted in our office and on our website. You may request a paper copy at any time.

9. Contact

Pasadena Clinical Group
Attn: HIPAA Privacy Officer
301 N. Lake Ave, STE 600
Pasadena, CA 91101
Phone: (626) 354-6440
Email: office@pasadenaclinicalgroup.com