You are a valued customer of Kalypsys (“Kalypsys,” “us” or “we”) and we take your
and/or health-related information that Kalypsys collects about you as part of
providing services to facilitate your search for healthcare providers and to book
medical appointments (collectively, the “Services”) to you may be considered
“protected health information” or “PHI” under the Health Insurance Portability and
Accountability Act (“HIPAA”).
We share a commitment with Covered Entities to protect the privacy and confidentiality
of Protected Health Information (PHI) that we obtain subject to the terms of a
Business Associate Agreement.
This policy is provided to help you better understand how we use, disclose, and
protect PHI in accordance with the terms of Business Associate Agreements.
Business Associate Agreement (the “BA Agreement”). A formal written
contract between Kalypsys and a Covered Entity that requires Kalypsys to comply
with specific requirements related to PHI.
Covered Entity. A health plan, healthcare provider, or healthcare
clearinghouse that must comply with the HIPAA Privacy Rule.
Protected Health Information (PHI). PHI includes all “individually
identifiable health information” that is transmitted or maintained in any form or
medium by a Covered Entity. Individually identifiable health information is any
information that can be used to identify an individual and that was created, used,
or disclosed in (a) the course of providing a health care service such as
diagnosis or treatment, or (b) in relation to the payment for the provision of
health care services.
Use and Disclosure of PHI
We may use PHI for our management, administration, data aggregation and legal
obligations to the extent such use of PHI is permitted or required by the BA Agreement
and not prohibited by law. We may use or disclose PHI on behalf of, or to provide
services to, Covered Entities for purposes of fulfilling our service obligations to
them, if such use or disclosure of PHI is permitted or required by the BA Agreement
and would not violate the
Standards for Privacy of Individually Identifiable Health Information (the Privacy
In the event that PHI must be disclosed to a subcontractor or agent, we will ensure
that the subcontractor or agent agrees to abide by the same restrictions and
conditions that apply to us under the BA Agreement with respect to PHI, including the
implementation of reasonable and appropriate safeguards.
We may also use PHI to report violations of law to appropriate federal and state
We use appropriate safeguards to prevent the use or disclosure of PHI other than as
provided for in the BA Agreement. We have implemented administrative, physical, and
technical safeguards that reasonably and appropriately protect the confidentiality,
integrity, and availability of the electronic protected health information that we
create, receive, maintain, or transmit on behalf of a Covered Entity. Such safeguards
Maintaining appropriate clearance procedures and providing supervision to assure
that our workforce follows appropriate security procedures;
Providing appropriate training for our staff to assure that our staff complies
with our security policies;
Making use of appropriate encryption when transmitting PHI over the Internet;
Utilizing appropriate storage, backup, disposal and reuse procedures to protect
- Utilizing appropriate authentication and access controls to safeguard PHI;
Utilizing appropriate security incident procedures and providing training to our
staff sufficient to detect and analyze security incidents; and
Maintaining a current contingency plan and emergency access plan in case of an
emergency to assure that the PHI we hold on behalf of a Covered Entity is
available when needed.
Mitigation of Harm
In the event of a use or disclosure of PHI that is in violation of the requirements of
the BA Agreement, we will mitigate, to the extent practicable, any harmful effect
resulting from the violation. Such mitigation will include:
Reporting any use or disclosure of PHI not provided for by the BA Agreement and
any security incident of which we become aware to the Covered Entity; and
Documenting such disclosures of PHI and information related to such disclosures as
would be required for Covered Entity to respond to a request for an accounting of
disclosure of PHI in accordance with HIPAA.
Access to PHI
As provided in the BA Agreement, we will make available to Covered Entities,
information necessary for Covered Entity to give individuals their rights of access,
amendment, and accounting in accordance with HIPAA regulations.
Upon request, we will make our internal practices, books, and records including
policies and procedures, relating to the use and disclosure of PHI received from, or
created or received by us on behalf of a Covered Entity available to the Covered
Entity or the Secretary of the U.S. Department of Health and Human Services for the
purpose of determining compliance with the terms of the BA Agreement and HIPAA