Privacy

Last Updated: April 12, 2021

This Privacy Policy explains how information about you is collected, used and disclosed by Lorraine McKenzie, LCSW, dba Comprehensive Therapy, (“Comprehensive Therapy,” “we,” “us” or “our”). This Privacy Policy applies to information we collect when you use our Site, mobile applications and the services, content and materials made available through our websites or mobile applications (collectively, the “Services”), or when you otherwise interact with us.

Additional definitions, terms and conditions are stipulated in the Terms of Service, which is hereby expressly incorporated into this document by reference.

HIPAA Notice of Privacy Practices

If you are an established client of Lorraine McKenzie, LCSW, dba Comprehensive Therapy, who is receiving mental health treatment in the context of a client-therapist relationship in the State of Oregon, please refer to the CDC HIPAA Notice of Privacy Practices for the specific terms and rights that apply to you. For any client receiving therapy from any independently practicing clinician, they are required by U.S. Federal law to present you with a notice of privacy policies similar to that presented in this document; please be sure that you receive and sign such a document prior to proceeding with therapy.

How We Use Your Information

As you use the Site, your personal information may be collected directly from you and automatically from your web browser’s information. Primarily, we use and collect the following information:

When you sign up for our newsletter, we store your name and email in order to be able to send you future email newsletters. You can opt out of receiving these newsletters by using the unsubscribe link contained in the email.
We store any comments or feedback you provide us for the purpose of improving the content of the Site.
We collect analytics with Google Analytics to measure site traffic and usage. You may opt out of Google Analytics.

How We Share and Disclose Your Information

We may share your Personal Information in the following circumstances:

We may share your Personal Information publicly, but only with your permission. For example, with your permission, we may publicly post your photograph, your name, professional titles, and comments on the “Reviews” section of our websites.
We may share your Personal Information with companies that provide services for us, such as hosting, marketing and communication services, and payment processing (“Service Providers”). Our policy is to authorize these Service Providers to use your Personal Information only as necessary to provide services for us, and require that they not use or disclose your Personal Information for any other purpose.
From time to time, we may be required to provide Personal Information to a third party in order to comply with a subpoena, court order, government investigation, or similar legal process.

We do not sell your Personal Information.

How we use Cookies

A cookie is a small piece of text sent to your browser by a website you visit. It helps the website to remember information about your visit, like your preferred language and other settings. That can make your next visit easier and the site more useful to you. Cookies play an important role. Without them, using the internet would be a much more frustrating experience.

We use cookies for many purposes. We use them, for example, to remember your preferences, to make any ads you see more relevant to you, to count how many visitors we receive to a page, to help you sign up for our services, or to protect your data.

Security

The Site has security measures in place to protect against the loss, misuse or alteration of information under our control. We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it. For example, when you enter sensitive information (such as your login credentials), we encrypt the transmission of that information using secure socket layer technology (SSL). However, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

California Consumer Privacy Act (CCPA)

In general, within the preceding 12 months:

We have collected the categories of Personal Information listed above.
We have collected these categories of Personal Information directly from you, when you use the Site, and from third parties for the purposes described above.
We have disclosed the following categories of Personal Information for business purposes: Identifiers and contact information; professional and employment-related information; commercial information; transactional information; and internet and network activity information.
We have not sold your Personal Information.

Certain California residents are entitled to privacy rights under the CCPA. Customers who wish to exercise these rights should direct their requests to the registered member who controls their Personal Information.

The right to know. You have the right to request to know (i) the specific pieces of Personal Information we have about you; (ii) the categories of Personal Information we have collected about you in the last 12 months; (iii) the categories of sources from which that Personal Information was collected; (iv) the categories of your Personal Information that we sold or disclosed in the last 12 months; (v) the categories of third parties to whom your Personal Information was sold or disclosed in the last 12 months; and (vi) the purpose for collecting and selling your Personal Information.
The right to deletion. You have the right to request that we delete the Personal Information that we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to comply with legal obligations or complete a transaction for which your Personal Information was collected. If we deny your request for deletion, we will let you know the reason why.
The right to equal service. If you choose to exercise any of these rights, we will not discriminate against you in anyway. If you exercise certain rights, understand that you may be unable to use or access certain features of our Services.

You may exercise your right to know and your right to deletion twice a year free of charge. To exercise your right to know or your right to deletion, please contact us using the address information provided in this document.

We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to verify you are the individual about whom we collected Personal Information. If you have an Account with us, we will use our existing Account authentication practices to verify your identity. If you do not have an Account with us, we may request additional information about you to verify your identity. We will only use the Personal Information provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose.

You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.

California’s “Shine the Light”

California customers are also entitled to request and obtain from us once per calendar year information about any of your Personal Information shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information, please contact us in writing using the address information provided in this document.

Children’s Privacy (COPPA)

The Site is not directed at children under the age of 18. We comply with the Children’s Online Privacy Protection Act and do not knowingly permit submission of Personal Information by anyone under 18 years of age.

Non-US Visitors

We are committed to complying with this Privacy Policy and the data protection laws that apply to our collection and use of your Personal Information. We are located in the United States, where the laws may be different and, in some cases, less protective than the laws of other countries. By providing us with your Personal Information and using the Services, you acknowledge that your Personal Information will be transferred to and processed in the United States and other countries where we and our vendors operate.

Links to Other Sites

The Site may contain links to other sites that are not owned or controlled by me. Please be aware that we am not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave the Site and to read the privacy statements of each and every site that collects Personal Information. This Privacy Policy applies only to information collected by the Site.

Social Media

This Site may include social media features, such as the Facebook Like button, and widgets, such as the “Share this” button, or interactive mini-programs that run on our websites (collectively referred to as “Features”). These Features may collect your IP address, which page you are visiting, and may set a cookie to enable the Feature to function properly. The Features are either hosted by a third party or hosted directly on this Site. Your interactions with these Features on a third-party site are governed by the privacy policy of the company providing it.

Practice Privacy Policy

I abide by the laws and ethical principles that govern privilege and confidentiality. I will not discuss any information about you with anyone without your written permission by way of a signed Authorization to Disclose Medical Records.

There are some exceptions to this standard which are also noted in the Notice of Privacy Practices:

I am legally required to act so as to prevent physical harm to yourself or others when there is “clear and imminent” danger of that happening.  
I am legally required to report cases of child, elder and disabled person abuse. This could include past abuse, if there is any current risk to children or others that fall under the mandatory reporting requirement. I am a Mandatory Reporter and am ethically bound to uphold this duty.
I may have to release your records when ordered to do so by court subpoena. However, I will discuss this with you beforehand and request a written release of information from you, if I judge this to be in your best interest.  
I may release information, upon request to the non-custodial parent of children under   the age of 18.  
I may release information to parents, if the client is a minor under the age of 14.  
I consult with colleagues about my work. This is kept confidential, without using your  name or identifying information.
If at some point in our therapeutic relationship, I bill your insurance, I may have to release clinical information regarding you to your insurance carrier as required for authorization, payment of your claim, or quality assurance review.

It is important that you discuss any question or concerns that you may have now or in the future regarding exceptions to confidentiality. The laws governing confidentiality can be quite complex, and I am not an attorney. In situations where specific advice is required, formal legal advice may be needed.

NOTICE OF PRIVACY PRACTICES

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY

By law, I am required to protect the privacy of your personal health information. I am also required to give you this notice to tell you how I may use and give out ("disclose" or "release") your personal health information held by me.

"Personal health information" includes any record of services you received from me, including, and not limited to:

Dates, times, and lengths of your counseling sessions;
Information you shared during counseling sessions or at other times;
Your counselor's observations of you;
Your counselor's assessment of your mental health concerns;
Results of psychological tests and diagnostic interviews;
Treatment plans and homework suggestions;
Medication records; and
Billing and insurance information.

Most of your personal health information is in written form. Information about you that is not written down, but is remembered by me, is also considered part of your personal health information, and is protected by law the same way written information is protected.

Information that cannot be traced back to you is not considered part of your personal health information.

Examples include:

Information about an experience you had that many people also had, and Information that is changed or made vague so that you cannot be associated with it.

I must use and give out your personal health information to provide information:

To you or someone who has the legal right to act for you (your personal representative),
To the Secretary of the Department of Health and Human Services, when the degree to which your privacy is protected is being examined, and
Where required by law.

I have the right to use and give out your personal health information to be paid for services provided to you, and to operate my business. For example:
Insurance companies may ask for your personal health information as a condition for paying for services you received with me.
If your account is referred to a collection agency, the collection agency may ask for parts of your personal health information relevant to their task, such as dates of sessions.
I may use your personal health information to make sure you and other clients get quality care, to provide customer services to you, to resolve any complaints you have, or to contact you about research studies.

I may use or give out your personal health information for the following purposes under limited circumstances:
To State and Federal agencies that have the legal right to obtain such information (such as a licensing board investigating an ethics complaint),
For public health activities (such as reporting disease outbreaks),
For government health care oversight activities (such as insurance fraud investigations),
For judicial and administrative proceedings (such as in response to a court order),
For law enforcement purposes (such as providing limited information to locate a missing person),
For research studies that meet all privacy law requirements (such as research on effectiveness of a counseling technique),
To avoid a serious and imminent threat to health or safety,
For the purpose of supervision, consultation, and training, and
To create a collection of information that can no longer be traced back to you.

By law, I must have your written permission (an "authorization") to use or give out your personal health information for any purpose that isn't set out in this notice, such as marketing or sale of your personal health information. You may take back (revoke) your written permission at any time, except if I have already acted based on your permission.

By law, you have the right to:

See and get a copy of your personal health information held by me;
Have your personal health information amended if you believe that it is wrong or if information

is missing, and I agree. If I disagree, you may have a statement of your disagreement added

to your personal health information;
Get a listing of those getting your personal health information from me. The listing won't cover

your personal health information that was given to you or your personal representative, that was given out to be paid for the services your received or for my operating my business, or that was given out for law enforcement purposes;
Ask me to communicate with you in a different manner or at a different place (for example, by sending materials to a P.O. Box instead of your home address);
Ask me to limit how your personal health information is used and given out in order to be paid for services you received or to operate my business. Please note that I may not be able to agree to your request; and
Get a separate paper copy of this notice.

If you believe I have violated these privacy rights, you can file a complaint with:

The Secretary of the Department of Health and Human Services Contact the Office for Civil Rights
1-866-627-7748, 1-800-537-7697 (TTY)

Filing a complaint will not affect the services you receive from me.

By law, I am required to follow the terms in this privacy notice. I have the right to change the way your personal health information is used and given out. If I make any changes to the way your personal health information is used and given out while you are a current client, you will get a new notice, directly or by mail, within 60 days of the change.

Contact Information for the Comprehensive Therapy:

Lorraine McKenzie, L.M.S.W., L.C.S.W. dba Comprehensive Therapy

lorraine@comprehensivetherapy.online (E-mail)
https://www.comprehensivetherapy.online (business website)

https://www.lorrainemckenzie.com (business website)

E-mail Privacy Notice

Please note that, in order to keep my e-mail address public, the spam filter has been set to the highest possible setting. Some e-mail messages may be lost, even if it is not a spam. If there is no reply to your e-mail message for three business days, please contact me by phone.

E-mail messages may be checked from an unsecured computer, and e-mail messages are often stored on multiple locations. Please do not use e-mail for communication that needs to remain confidential.

Changes to This Policy

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the “Last Updated” date at the top of this policy and, in some cases, we may provide you with additional notice (such as by adding a statement to our website or by sending you a notification). We encourage you to review our Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy.