Privacy, Security, and Confidentiality
PRIVACY STATEMENT
The maintenance and exchange of information within the healthcare system is integral to providing optimal patient care.
At the same time, custodians of personal medical information, such as Caremark, have a duty to protect and secure private healthcare records from unauthorized inspection or use.
Caremark’s policies and procedures and the structure of the iScribe system are designed to protect the confidentiality of patient medical information.
This privacy statement explains these policies regarding the collection, storage, use and disclosure of information that we learn about you and your patients when you register for or use our products or visit our Web site.
In order to keep pace with legal and industry developments, Caremark modifies its privacy and security policies and practices from time to time.
Any such modifications are reflected in updates to this statement.
Caremark reserves the right to change, modify, add or remove portions of this statement at any time.
We encourage you to visit this web page frequently so that you will always know what information we collect; how we use that information; and whether and to whom we disclose it.
Review Security Guidelines for your iScribe PDA
(Adobe Acrobat required)
PRIVACY AND CONFIDENTIALITY DEFINITIONS
The following definitions are used throughout this privacy statement:
- “Personally Identifiable Information” — any information that identifies you or could be used to identify you as an individual, as well as any additional data tied to such information.
- “Individually Identifiable Patient Information” — information that
(i) relates to the mental or physical health or condition of one of your patients, the provision of healthcare to such patient, or payment for the provision of healthcare to such patient and
(ii) identifies the individual patient or could be used to identify him or her.
- “Registration Information” — certain Personally Identifiable Information that you provide to Caremark when you register to use one of our software applications.
- “Transaction Data” — all information and data input by you on your handheld device or desktop computer while generating prescriptions or documenting healthcare services using iScribe’s products.
WHAT INFORMATION DO WE COLLECT AND HOW DO WE USE IT?
Registration for Product(s)
Caremark collects all Registration Information that you provide to us when you complete our on-line registration form to download and use any of our products.
This information includes contact information, such as your name, address and telephone number, as well as demographic information, such as your specialty, state license number and type of practice management system you use.
We utilize the required fields of Registration Information to verify your prescribing authority and, upon such verification, to customize our application for you; e.g., to create a conduit to pharmacies in order to receive online renewal requests.
We may use your contact and demographic information to alert you to developments about pharmaceuticals.
For example, we may contact you by e-mail or via a PDA-based message about an U.S Food and Drug Administration (FDA) drug recall or to apprise you of a newly reported severe drug interaction.
We may also use this information to contact you about our products and services, and we may e-mail you to inform you that we have released an updated version of one or more of our products, or to ask you to complete a survey rating our products and services.
Use of Product(s)
In providing services to you, Caremark collects Transaction Data generated by your use of our products, including the following:
- Patient: name, address, phone number(s), date of birth, gender, office practice number
- Prescriber: name, address, phone and fax numbers, e-mail address, state license number, specialty (and, if provided, DEA number)
- Practice: name, address, phone and fax numbers (and, if provided, contact name and title)
- Patient’s Insurance: health plan name(s), address, phone number (if provided)
- Prescription: date, drug or medical supply prescribed (and if applicable, other drugs selected but not ultimately prescribed), form, route, strength, dose, directions for use, quantity, number of refills and generic substitution instructions
As further discussed, below, we supply some, but not all, of the Transaction Data to one or more of our third party partners such as manufacturers and health plans, in aggregate form, but exclusive of any Individually Identifiable Patient Information.
The iScribe system uses the Individually Identifiable Patient Information contained in any Transaction Data solely for the purposes of medical treatment, obtaining payment for such treatment and health care operations (e.g., performing drug use evaluation and assessing formulary status) as permitted under the HIPPA Privacy Rule.
Correcting or Updating Your Information
You can utilize the iScribe application to correct or update the following Registration Information: your street address, phone number and fax number.
You can also add, correct or delete the names of ancillary prescribers that you have designated for inclusion on your prescription header.
By utilizing our Practice Management System Interface (PMi), you can update and/or add to the list of patients on your handheld device.
(Note that the PMi does not permit the transfer of medical information, only patient demographic information.)
Opting Out of E-mail Communications
If you no longer wish to receive email messages from us related to the iScribe product, you may remove yourself from the iScribe e-mailing list by sending an email to info@iscribe.com with “Remove” as the subject line. Upon receiving such a request from you, Caremark will promptly remove you from our e-mail contact list.
Casual Web site Use
Caremark does not collect information about you via our Web site (http://www.iscribe.com/) unless you affirmatively provide it to us.
In other words, if you visit our Web site merely to browse, to view a demonstration of our products, or to learn more about our company, Caremark does not monitor your Web site navigation or collect any information about you through the use of “cookies” or other covert means.
(If you do decide to use our Web Formulary tool, accessible from http://www.iscribe.com/, and accept the terms of the User Agreement, we do use a cookie to indicate your acceptance upon return visits, but not to collect information about you.)
Caremark does collect and store information that you provide to us by filling out surveys that we may post from time to time on our Web site.
We use these surveys solely to solicit feedback and suggestions regarding our current or proposed products, so that we can continue to deliver the most useful and accessible functionality to our customers.
We will not disclose to any third party any Personally Identifiable Information about you that we may gather from such surveys except as may be required by law.
What Information Do We Disclose?
During the registration process, you agree to the terms of our standard User Agreement.
As set forth in the User Agreement, by registering for and using our application(s), you consent to Caremark’ use of all Transaction Data generated by your use of our application(s) and, in addition, certain of your Registration Information, for all lawful purposes.
Caremark reserves the right to sell, transfer and license the Transaction Data, including data that identifies you from your Registration Information, to pharmaceutical manufacturers, healthcare clearinghouses and data analysis companies, but only to the extent the data does not contain Individually Identifiable Patient Information.
The iScribe system uses the Individually Identifiable Patient Information contained in any Transaction Data solely for the purposes of medical treatment and obtaining payment for such treatment and health care operations (e.g., performing drug use evaluation and assessing formulary status) (as further described, below).
Caremark is committed to protecting the confidentiality of Individually Identifiable Health Information and, as specified in the Caremark iScribe User Agreement - Caremark does not provide Individually Identifiable Patient Information to any third party other than for purposes of providing our services to you (e.g., submitting a prescription to a pharmacy for fulfillment or submitting a claim to a health plan or PBM for processing) and as permitted by the HIPAA Privacy Rule and the iScribe User Agreement.
Any patient medical information that is provided to a third party for other purposes is anonymous, aggregated, and not reasonably traceable to or capable of identifying the individual patient.
DATA SECURITY
Data security means that data that is considered private and confidential is maintained under conditions designed to prevent unauthorized access.
At Caremark, electronic data security involves controlling transmission and storage of, and access to, information that is maintained on Caremark’ central servers.
In the sections that follow, we discuss two components of data security-User Authentication and Data Transmission and Storage.
USER AUTHENTICATION
Caremark has implemented processes to verify that the hardware and software used to create, store and transmit Individually Identifiable Patient Information is accessible only to those who are authorized to see it.
Before becoming iScribe system users, individuals must first undergo a standardized credentialing process that verifies their authority to prescribe in the state in which they are practicing.
Once Caremark verifies a user’s prescribing authority, he or she can log into the system using an individually selected user name and personal password.
Licensed prescribers and authorized medical office staff who use the iScribe system may activate the applications only after entering their unique user name and password.
The initial credentialing process provides access to formulary search, electronic prescribing, and other iScribe tools that do not provide Individually Identifiable Patient Information (physicians, however, can enter patient names into the ePrescribing tool).
Upon prescriber verification, Caremark will mail to a physician (within five to seven days) a PIN code.
The physician must log in to the iScribe Web site and enter that PIN code to enable access to the advanced iScribe functionality that accesses Individually Identifiable Patient Information, such as the online renewals tool.
TRANSMISSION AND STORAGE OF DATA
The iScribe system employs advanced levels of security and encryption of electronic data in order to ensure that data transmitted to or maintained by Caremark is protected from unauthorized access.
Caremark has implemented stringent policies to ensure the security of information once it reaches Caremark’ central server.
Caremark’ data storage infrastructure includes locked-door protection of the data servers and storage media.
In addition, all external entrances to the Caremark facility are key-code protected twenty-four hours per day, seven days per week.
Individually Identifiable Patient Information stored on Caremark’ servers is accessible only by authorized Caremark employees with proper security clearance.
Last updated: 09/29/04
|
