Abacus Management Technologies, doing business as The Abacus Group and Abacus Health Solutions and My Medication Advisor (collectively referred to as "Abacus" in this Policy), has created this privacy statement in order to demonstrate a firm commitment to maintaining the privacy and security of information you provide to us. We want you to have confidence and comfort about the security or use of any information that you provide to us.
Abacus develops and maintains a number of web sites (which include Good
Health Gateway®, Good Health Gateway® eBP web site, myMedicationAdvisor®,My
Health Maximizer®, myHealthAdvocate®,
HeartAge®, Lifespan Healthy Rewards and Keep It OffSM), understands that health is a personal and private matter, and values and respects your right to keep certain Personal Information private. At the same time, Abacus has a need to collect and use Personal Information which will enable us to provide services, including safety related tools (e.g., Medication Record), cell phone numbers in order to send timely messages, assistance in ordering certain medications, administration of special incentive or prize programs, and evaluation of the effectiveness of the Abacus web sites. In order to meet the goals of collecting such service-related and evaluation data while protecting the privacy of your personal and individually identifiable health information (Protected Health Information), all such information will be maintained in a manner consistent with the rules and regulations of the Health Insurance Portability and Accountability Act of 1996 (HIPAA).
The following discloses our policies for the gathering and use of information for the Abacus developed and/or supported web sites (which include Good Health Gateway, Good Health Gateway® eBP web site, myMedicationAdvisor, My Health Maximizer, myHealthAdvocate, HeartAge, Lifespan Healthy Rewards and Keep It Off)
1. Definition of Terms
- Personal Information is "Demographic Information" and/or "Protected Health Information" that identifies you with a minimal degree of effort.
- Demographic Information includes your name, address, city, e-mail address, and other similar information.
- Protected Health Information
is individually identifiable information regarding your health (or the health of family members/covered dependents), including but not limited to information on medical conditions, treatments, medications, eligibility and claims data, lifestyle behaviors, and family history that has been entered in the web site by you or someone you authorized to use your account, or received from a pharmacy plan.
- Transactional Information is data collected about you based on your interactions with Abacus.
- Aggregate Information is information in summary form, which does not contain data that would permit identifying you. Aggregate Information is collected for evaluation purposes.
2. Policy for Information Collection and its Use
Abacus will collect Personal Information and Protected Health Information (PHI) on you when you provide the information to Abacus. As a business associate of your health plan, Abacus will on occasion collect Personal Information, Protected Health Information, and Aggregate Information for research and/or program and service provision and evaluation purposes. Abacus will collect Personal and Transactional Information on the web site from you solely for the purposes of: (a) providing health information to you (e.g., medication reviews, tailored feedback from survey responses, and/or feedback on progress in changing lifestyle behaviors); and/or (b) conducting incentive and reward programs; and/or (c) research (with prior written informed consent); and/or (d) to obtain your feedback on programs and services we offer on these web sites (response to these questionnaires is entirely voluntary); and/or (e) to support our program functions including analysis of aggregated data for reporting and evaluation purposes. For example, we may use your Personal Information to provide you with information about the medication buying programs sponsored by your employer or educational information on health care issues.
In some cases, as a part of our services, Abacus offers a variety of incentive or reward programs in which members are offered the opportunity to receive money, cash or gift cards, and/or other awards when they meet the requirements of a reward program. In most cases these programs are voluntary and require that you indicate a desire to participate by enrolling for that program. Some of these programs require that we have information about medication purchasing decisions you and/or your covered dependents have made. We use the minimum amount of information necessary to accomplish the task, and do not use that information for any other purpose.
In the case that you choose to share your PHI with Abacus and you have a WebMD Personal Health Record through your employer, Abacus may send the PHI to your WebMD Personal Health Record.
The use of your Personal Health Information is governed by the privacy policies of the organization providing your health benefits and in compliance with HIPAA regulations. Your rights are outlined in these policies which include your right to inspect and copy, your right to amend, your right to accounting, your right to a restriction, and your right to confidential communication.
3. Specific Requirements
- Administrative Requirements
The information collected will be kept in a secure environment and will be completely confidential. Access to Personal Information will be restricted to only those personnel with a legitimate business or research purpose. When you provide Protected Health Information to Abacus, we will ensure that this information will be used according to the standards outlined in this policy.
- Scientific Research Requirements
Any research conducted by Abacus that involves human participants (e.g., information collected on individuals) must be endorsed by the sponsoring institution's Institutional Review Board or other appropriate body and conform ethically to the guidelines prescribed by the American Psychological Association and the National Institutes of Health, which includes obtaining written informed consent from each individual involved in such research.
- Clinical Requirements
Where applicable and allowable under HIPAA and the HITECH clause of the American Reinvestment and Recovery ACT or ARRA law, your personal health information collected by Abacus through a program offered by a clinical institution may be provided to personnel at that sponsoring clinical institution, including biometric values (i.e., blood pressure values, weight and BMI, blood glucose readings, etc…), prescription information, or demographic information. Also, Abacus may coordinate information with appropriate health and pharmacy plan administrator(s), prescription fulfillment companies or services, providers, and designated care managers/health coaches in the course of operating the program(s) and Abacus may send and receive this information in order to facilitate your participation in an offered program. You may be contacted by clinical personnel (including, but not limited to, pharmacists, case workers, social workers, nurse advocates, etc…), in regard to your participation in the Good Health Gateway program. You must also agree to the terms in the Microsoft Windows Live Service Agreement, the Microsoft HealthVault Account Service Agreement, the Microsoft HealthVault Account Privacy Statement, where relevant, the Good Health Gateway Terms of Service, and the Good Health Gateway Privacy Policy. The terms of this agreement remain in effect while you are a participant in an offered program or until you revoke such authorization through written notification to Abacus.
- Third Party Disclosure Requirements
Information collected will not be shared, sold, or rented to other entities. We do not disclose your Personal Health Information to your employer who is sponsoring these programs. We do provide aggregate enrollment information or de-identified information for the program sponsor to perform administrative functions and quality review of the program. We may disclose information which summarizes program enrollment and activity. The summary information will be stripped of identifying and demographic information about specific enrollees in the group health plan.
Personal Information and Protected Health Information will not be disclosed to other parties unless you have given permission to do so. Only with your permission may we disclose to a family member, a friend, or to other persons you indicate who are involved in your care, your protected health information that is directly relevant to their involvement. Informed Consent is required before Abacus can disclose Protected Health Information to a third party. Informed Consent occurs when you have sufficient facts about the disclosure, comprehend those facts, and voluntarily consent to the disclosure. No permission is necessary for disclosure of Aggregate Information since Aggregate Information does not specifically identify you.
We will disclose your Personal Information and Protected Health Information to an individual who has been designated by you as your personal representative and who has qualified for such designation in accordance with relevant state law. However, before we will disclose Personal Information and Protected Health Information to such a person, you must submit a written notice of his/her designation, along with an Authorization Form. You may fax the completed form to us at the number indicated on the Authorization Form. Even if you designate a personal representative, the HIPAA Privacy Regulations permit us to elect not to treat a person as your personal representative if we have a reasonable belief that: (i) you have been, or may be, subjected to domestic violence, abuse, or neglect by such a person; or (ii) treating such a person as your personal representative could endanger you.
Other uses and disclosures of your Personal Information and Protected Health Information that are not described above will be made only with your written authorization. If you provide us with such an authorization, you may revoke the authorization in writing, and this revocation will be effective for future uses and disclosures of personal information. However, the revocation will not be effective for information that we already have used or disclosed, relying on the authorization.
4. Registration
When you register with Abacus on any of our web sites, the registration form requires you to give us Personal Information such as your name and e-mail address. This information may be used by Abacus to contact a user when necessary, including to obtain your feedback on how you like our web sites, programs, and services. Registration of a participant is required to be part of any research studies offered through Abacus; however, registration for one of the Abacus web sites does not constitute enrollment in any research study. Such enrollment requires that you be given informed consent regarding the study.
In some cases, we may ask for additional information after you register. For example, we may ask for the names of one or more of your current medications or your weight and height for our online health tools and calculators. We may also ask questions about your health and lifestyle in surveys. This information is used to provide guidance to you as well as to provide information on your medication use or progress in changing health behaviors. You may also be given an electronic weight scale or blood pressure cuff for self-monitoring and the readings from those devices may be made available to Abacus in order to help you improve your health. Information you provide for these purposes will not be used for any other reason and will not be disclosed to a third party without your informed consent and written authorization.
In the course of providing products or services to Abacus, technical and maintenance technicians from Abacus may have limited access to the information you provide. The technicians provide Abacus with technology, services, and/or content related to enhancing the operation and maintenance of the Abacus web sites. These technicians also may have access to your e-mail address so that they can send e-mails to you on our behalf regarding the Abacus web sites. Access to your Personal Information by these technicians is limited to the information reasonably necessary for the technicians to perform their limited functions for Abacus. We contractually require these technicians to protect the privacy of your information consistent with this Privacy Policy.
5. Cookies
"Cookies" are small text files on your computer system. They are
used to deliver and store certain kinds of information that you voluntarily enter
online. Cookies are not linked to personally identifiable information on the Abacus
web sites. Once the participant closes the Abacus web site window, the cookie is
eliminated.
6. IP Addresses and Administrative Modules
An IP address is a number that is automatically assigned to your computer whenever you access the Internet. All computer identification on the Internet is conducted with IP addresses. They allow computers and servers to communicate with each other. Abacus collects IP addresses and uses an Administrative Module in order to administer the web site, gather Transactional Information, and conduct web site analysis. IP Addresses are not personally linked to your Personal Information. However, Abacus will use IP addresses to identify any users who refuse to comply with the Abacus web site Terms and Conditions of Use policy.
7. Ask-a-Pharmacist and Public Forums
This web site makes an Ask-a-Pharmacist feature available to you as part of
myMedicationAdvisor. Your questions and the answers to them will only be available to qualified Abacus staff for processing purposes and for you to read. At some point in the future, your question(s) and answer(s) may appear as one of our Frequently Asked Questions (Faqs) in order to help educate other users. If this is done, the question and answer will be stripped of all information that could reveal or relate to your identity.
For more information on both the Ask-a-Pharmacist and public forum policies, please refer to the Terms and Conditions of Use policy.
8. Links to other Web sites
Abacus web sites may contain links to other web sites. We are not responsible for the sharing of knowledge, statements, or any information provided on other web sites, nor are we in any way, shape, or form responsible for the privacy practices of these web sites. You should make note when you are leaving the Abacus web site domain and be aware the other web sites you visit have different privacy policies and practices. The Abacus Privacy Policy applies only to the Abacus web site inclusive of Good Health Gateway, Good Health Gateway® eBP web site, myMedicationAdvisor, My Health Maximizer, myHealthAdvocate, HeartAge, Lifespan Healthy Rewards and Keep It Off.
9. Security
The sites have security measures in place to protect from the loss, misuse, and/or alteration of information under our control. Certain areas of the web sites, including any areas where you enter Personal Information or Protected Health Information, are secured with encryption technology. With the exception of eligibility and dependent information used in the registration and eligibility confirmation process, none of the Protected Health Information obtained from any source other than you, or any individual to whom you provide your user name and password, will be placed on this web site. Any employee of Abacus requiring access to technology relating to your information must be given password access by Abacus management. This access is reviewed on a regular basis. Parties granted such access are instructed in Abacus privacy and security policies. In order to prevent loss of information, all data is backed up on a real-time basis. You can help protect your Personal Information and Protected Health Information by not sharing your username and password with anyone.
10. Updating Personal Information
This web site gives you the following options for changing and modifying information
that was previously provided by a user:
- Log on to the web site and change any information you provided during
Registration and/or use of other sections of the web site
- Call our Abacus Helpline at (401) 467-3113 (within Rhode Island) or (800) 643-8028
-
For Keep It Off call the Helpline at 855-461-2969
-
For Good Health Gateway® eBP web site call the Helpline at (800) 643-8028
11. Changes to this Privacy Policy
Changes or additions to the Privacy Policy will be posted on the Abacus web sites. The terms of the change(s) will be immediate and binding when the notification of these changes is posted on the web site. Each time that you use the web site, you agree to review the Privacy Policy in order to be aware of any changes to the policy. Your subsequent and continuous use of the Abacus web sites including the Good Health Gateway web site, Good Health Gateway® eBP web site, myMedicationAdvisor
web site, My Health Maximizer web site, myHealthAdvocate
web site, HeartAge web site and Keep It Off web site will be your acceptance
of the amended Agreement.
12. Contact Information
Users who have questions about this privacy statement, the privacy practices of the web site, and their dealings with this web site insofar as their privacy and confidentiality are concerned should contact us by one of the following means:
Last reviewed and updated on 04/21/2014.
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