Washington Consumer Health Data Privacy Policy

This Washington Consumer Health Data Privacy Policy (“Policy”) applies to personal data defined as “Consumer Health Data” by the Washington My Health My Data Act (“MHMD”) that is collected from you by ComPsych Corporation and/or FMLASource and their affiliates (referred to as “Company”, “we,” “us,” or “our” in this Policy). This Policy supplements our U.S. Privacy Notice. In the event of a conflict between any other policy, statement, or notice and this Policy, this Policy will prevail as to Consumer Health Data Collected under MHMD.

Consumer Health Data under MHMD 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 does not apply where an exception or exemption applies, such as for Protected Health Information (“PHI”) under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). See our HIPAA Privacy Notice and U.S. Privacy Notice for our notices related to personal information that is not Consumer Health Data subject to the MHMD. Consumer Health Data does not include de-identified or aggregated consumer information. De-identified Consumer Health Data may be used to report aggregate utilization of services to your employer or group health plan. Such reporting is anonymous, meaning that your name or other personally identifying information will never be disclosed to your employer or group health plan in these reports.

Consumer Health Data We Collect

As described in our U.S. Privacy Notice and HIPAA Privacy Notice, the personal data we collect depends on the services you request and/or receive from Company.

We may collect the following categories of personal information, which may be Consumer Health Data if not excluded from the MHMD:

Information about your health and mental-related conditions, symptoms, status, diagnoses, testing, or treatments;
Internet or Network Activity Information essential to running our website such as login data, time zone setting and location, and internet browser type and version which could identify your attempt to seek services or information, including services that allow you to assess, measure, improve, or learn about your health; and
Other information that may be used to infer or derive data related to the above or other health information.

Company only collects your Consumer Health Data to provide requested or authorized services to you. We collect personal information, including Consumer Health Data, from the following categories of sources:

Directly from you when you use our services and any other way that you may be able to interact with us.
From third-party service providers and business associates as defined under HIPAA.
From devices you use to connect to our Services.

Use of Your Consumer Health Data

To the extent we collect personal information, including Consumer Health Data, as described above, we may use it for the following purposes:

To provide you with services you have requested or authorized,
Delivering the services and their features, including personalization of certain features,
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
Where we require your consent to collect personal information for a specified purpose, a description of those purposes is provided to you at the time of collection.

Sharing Consumer Health Data with Third Parties

Except as set forth below, Company will only share your Consumer Health Data with Company’s employees and third-party service providers the extent necessary to provide services and comply with applicable law. All third-party providers are prohibited from using your Consumer Health Data except to provide these services and they are required to maintain the confidentiality of your Consumer Health Data.

For absence management services, FMLASource may disclose to your employer any Consumer Health Data you disclose to FMLASource in connection with the administration of your leave of absence.

Company will disclose data to law enforcement or other government agencies when we believe doing so is necessary to comply with applicable law or respond to valid legal process. In certain circumstances, it may be necessary to provide data to other third parties, for example, to comply with the law or to protect our rights or those of our customers.

How to Exercise Your Rights

You have certain rights with respect to Consumer Health Data, including the right to access, delete, or withdraw consent relating to your Consumer Health Data, subject to certain exceptions. You may exercise any of your rights by contacting us directly using the contact details found in this Policy. The written request should include sufficient information to verify your identity and specify the right you wish to exercise. For any questions or assistance, you may also reach out using the contact information below.

If your request to exercise a right under the MHMD is denied, you may appeal that decision by contacting Company’s Legal Department. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.

Changes to This Policy

Company reserves the right to change our privacy practices at any time and any such change shall apply to all Consumer Health Data we maintain, including Consumer Health Data created or received by Company prior to issuing a new Notice. If Company materially changes this Notice, this Notice shall be amended and posted on Company’s website.

Contact Information

All notices and requests should be in writing and sent to [email protected]. You may also call us at 312- 660-1076.

Washington Consumer Health Data Privacy Policy