Privacy Policy

We recognize that your privacy is important. This document outlines the types of personal and Health information we receive and collect when you use The Possibility as well as some of the steps we take to safeguard information. We hope this will help you make an informed decision about sharing personal information with us.

The Possibility strives to maintain the highest standards of decency, fairness and integrity in all our operations. Likewise, we are dedicated to protecting our customers', consumers' and online visitors' privacy on our website.

Personal Information

The Possibility collects personally identifiable information from the visitors to our website only on a voluntary basis. Personal information collected on a voluntary basis may include name, postal address, email address, company name, employment history, employment challenges and successes, and telephone number.

This information is collected if you request information or services from TPP, and sign up to join our email list. The information collected is internally reviewed, used to improve the content of our website, notify our visitors of updates, respond to visitor inquiries, and match potential job seekers to Employers and service agencies.

Once information is reviewed, it is discarded or stored in our files. If we make material changes in the collection of personally identifiable information we will inform you by placing a notice on our site. Personal information received from any visitor will be used only for internal purposes and will not be sold or provided to third parties.

Protected Health Information

THIS NOTICE DESCRIBES HOW PROTECTED HEALTH INFORMATION (PHI) ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY. PRIVACY NOTICE (Effective Date: December 20, 2017) This page describes the type of information we gather about you, with whom that information may be shared and the safeguards we have in place to protect it. You have the right to the confidentiality of your protected health information and the right to approve or refuse the release of specific information except when the release is required by law. If the practices described in this Notice meet your expectations, there is nothing you need to do. If you prefer that we not share information we may honor your written request in certain circumstances described below. If you have any questions about this notice, please contact our Privacy Officer at the address on the last page. WHO WILL FOLLOW THIS NOTICE This notice describes The Possibility Pool’s practices regarding the use of your protected health information and that of: • Any case management professional authorized to enter information into your master record. • All programs and services of The Possibility Pool that you may visit. • All employees, staff and other personnel who may need access to your information. • All entities, sites and locations of The Possibility Pool follow the terms of this notice. In addition, these entities, sites and locations may share protected health information with each other for service delivery, payment or health care purposes described in this notice. OUR PLEDGE REGARDING PROTECTED HEALTH INFORMATION We understand that protected health information about you and your health is personal. Protecting protected health information about you is important. We create a record of the requested services that you receive through The Possibility Pool. We need this record to provide you with quality services and supports, and to comply with certain legal requirements. This notice applies to all of records generated or maintained by The Possibility Pool. This notice will tell you about the ways in which we may use and disclose protected health information about you. We also describe your rights and certain obligations we have regarding the use and disclosure of protected health information. We are required by law to: • Keep your protected health information private; • Give you this notice of our legal duties and privacy practices with respect to protected health information about you; and • Follow the terms of the notice that is currently in effect. HOW WE MAY USE AND DISCLOSE PROTECTED HEALTH INFORMATION (PHI) ABOUT YOU The following categories describe different ways that we may use and disclose protected health information. For each category of uses or disclosures we will try to give some examples. Not every use or disclosure in a category will be listed, or applicable, depending on program or services. For Services and Supports. We may use and disclose protected health information about you to qualified professional personnel of TPP, and Human Rights committee members to the extent necessary for the acquisition, provision, oversight, or referral for services and supports. For Payment. We may use and disclose protected health information about you in order to bill for monthly case management, comprehensive and support services, and to provide employment connection services. Protection and Advocacy. We may disclose confidential information about you to the entity designated as the protection and advocacy system for Colorado, pursuant to 42 U.S.C. 604, when a complaint has been received on your behalf, or if you do not have a legal guardian, or if the state or the designee of the state is your legal guardian. Research. Under certain circumstances, we may use and disclose protected health information about you for research purposes. For example, a research project may involve comparing the success of certain employment based techniques provided to consumers who received one practice to those who received another, for the same employment challenges. As Required By Law. We will disclose protected health information about you when required to do so by federal, state or local law. To Avert a Serious Threat to Health or Safety. We may use and disclose protected health information about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. Any disclosure, however, would only be to someone able to help prevent the threat. Fundraising Activities. We may use protected health information about you in an effort to raise money for The Possibility Pool and its operations. We may disclose protected health information to a foundation or consultant related to The Possibility Pool so that they may raise money for The Possibility Pool and/or its operations. We only would release contact information, such as your name, address and phone number. If you do not want The Possibility Pool to contact you for fundraising efforts, you must notify our Privacy Officer in writing at the address listed on the last page. SPECIAL SITUATIONS Military and Veterans. If you are a member of the armed forces, we may release protected health information about you as required by military command authorities. Workers' Compensation. We may release protected health information about you for workers' compensation or similar programs. These programs provide benefits for work-related injuries or illness. Public Health Risks. We may disclose protected health information about you for public health activities. These activities generally include the following: • To prevent or control disease, injury or disability; • To report births and deaths; • To report child abuse or neglect; Notice of Privacy Practices (NPP) Page 3 of 4 TPP, Created 12, 2017) • To notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition; • To notify the appropriate government authority if we believe a consumer has been the victim of abuse, neglect or domestic violence. Health Oversight Activities. We may disclose protected health information to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws. Lawsuits and Disputes. We may disclose protected health information about you in response to a subpoena, discovery request, or other lawful order from a court. Law Enforcement. We may release protected health information if asked to do so by a law enforcement official as part of law enforcement activities; in investigations of criminal conduct or of victims of crime; in response to court orders; in emergency circumstances; or when required to do so by law. Coroners, Medical Examiners and Funeral Directors. We may release protected health information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death. We may also release protected health information about consumers to funeral directors as necessary to carry out their duties. Protective Services for the President, National Security and Intelligence Activities. We may release protected health information about you to authorized federal officials so they may provide protection to the President, other authorized persons or foreign heads of state or conduct special investigations, or for intelligence, counterintelligence, and other national security activities authorized by law. Inmates. If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release protected health information about you to the correctional institution or law enforcement official. This release would be necessary (1) for the institution to provide you with health care; (2) to protect your health and safety or the health and safety of others; or (3) for the safety and security of the correctional institution. OTHER USES AND DISCLOSURES OF PROT EC T ED HEALTH INFORMATION We will not use or disclose your health information for any purpose other than those identified in the previous sections without your specific, written Authorization. Examples of disclosures requiring your authorization include disclosures to your partner, your spouse, your children and your legal counsel. We also will not use or disclose your health information for the following purposes without your specific, written Authorization: YOUR RIGHTS REGARDING PROTECTED HEALTH INFORMATION ABOUT YOU. You have the following rights regarding protected health information we maintain about you: Right to Inspect and Copy. You have the right to inspect and copy protected health information that may be used to make decisions about your care. Usually, this includes information from your master record, but will not include psychotherapy notes. If we use or maintain the requested information electronically, you may request that information in electronic format To inspect and copy protected health information that may be used to make decisions about you, you must contact our Privacy Officer listed on the last page. You are entitled by law to one free copy of any information contained in your record. If you or other authorized persons request additional copies of this information, we may charge a fee for the costs of copying, mailing or other supplies associated with your request. We may deny your request to inspect and copy in certain very limited circumstances. If you are denied access to protected health information, you may request that the denial be reviewed. Another individual chosen by The Possibility Pool will review your request and the denial. The person conducting the review will not be the person who denied your request. We will comply with the outcome of the review. Right to Amend. If you feel that protected health information we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept. This counter-information is appended to the original documentation and whenever the original documentation is used or disclosed, your amendment will accompany any released copies. To request an amendment, your request must be made in writing and submitted to our Privacy Officer. In addition, you must provide a reason that supports your request. We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to amend information that: • Was not created by us, unless the person or entity that created the information is no longer available to make the amendment; • Is not part of the protected health information kept by The Possibility Pool; • Is not part of the information which you would be permitted to inspect and copy; or • Is accurate and complete. Right to an Accounting of Disclosures. You have the right to request an "accounting of disclosures." This is a list of certain Notice of Privacy Practices (NPP) Page 4 of 4 TPP, Created 4-2003, (Rev. 07-2016) ) disclosures we made of protected health information about you. To request an accounting of disclosures, you must submit your request in writing to our Privacy Officer. Right to Request Restrictions. You have the right to request a restriction or limitation on the protected health information we use or disclose about you for TPP Services, payment or case management operations. You also have the right to request a limit on the protected health information we disclose about you to someone who is involved in your care, like a service provider, family member, guardian, authorized representative, or friend. We are not required to agree to your request. If we do agree, we will comply with your request unless the information is needed to provide you emergency TPP Services, or; (any Opt Out). If we agree to all or part of your request, we will put our agreement in writing and obey it except in emergency situations. We cannot limit uses or disclosures that are required by law To request restrictions, you must make your request in writing to our Privacy Officer at the address below. In your request, you must tell us (1) what information you want to limit; (2) whether you want to limit our use, disclosure or both; and (3) to whom you want the limits to apply. Right to Request Confidential Communications. You have the right to request that we communicate with you about medical matters in a certain way or at a certain location. For example, you can ask that we only contact you at your residential facility or by mail, or through electronic means (example: e-mail). To request confidential communications, you must make your request in writing to our Privacy Officer. We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted. To find out what disclosures have been made. You may get a list describing when, to whom, why, and what of your Protected Health Information has been disclosed during the past six years. We must respond to your request within sixty days of receiving it. We will only charge you for the list if you request more than one list per year. The list will not include disclosures made to you or for purposes of TPP Services, payment, health care operations if we do not use electronic health records, or it involves national security, law enforcement, and certain health oversight activities. To receive notice if your records have been breached. TPP will notify you if there has been an acquisition, access, use or disclosure of your Protected Health Information in a manner not allowed under the law and which we are required by law to report to you. We will review any suspected breach to determine the appropriate response under the circumstances Right to a Paper Copy of This Notice. You have the right to a paper copy of this notice at any time. Even if you have agreed to receive this notice electronically, you are still entitled to a paper copy of this notice. You may obtain a copy of this notice at our website: To obtain a paper copy of this notice, please request one in writing from our Privacy Officer at the address below. CHANGES TO THIS NOTICE We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for protected health information we already have about you as well as any information we receive in the future. We will post a copy of the current notice. The effective date is found on the first page of the Notice. COMPLAINTS If you believe your privacy rights have been violated, you may file a complaint with The Possibility Pool, or with the Office of Civil Rights. To file a complaint with The Possibility Pool, contact our Privacy Officer at the address and phone number listed below. All complaints must be submitted in writing. If The Possibility Pool cannot resolve your concern, you also have the right to file a written complaint with the Secretary of the Department of Human Services at the address below. You will not be penalized for filing a complaint. OTHER USES OF PROTECTED HEALTH INFORMATION Other uses and disclosures of protected health information not covered by this notice or the laws that apply to us will be made only with your written permission. If you provide us permission to use or disclose protected health information about you, you may revoke that permission, in writing, at any time. If you revoke your permission, thereafter, we will no longer use or disclose protected health information about you for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain our records of the care that we provided to you.

Use of Cookies and Web Beacons

We may use cookies to help you personalize your online experience. Cookies are identifiers that are transferred to your computer's hard drive through your Web browser to enable our systems to recognize your browser. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize the sites pages, or register with any of our site's services, a cookie enables The Possibility to recall your specific information on subsequent visits.

You have the ability to accept or decline cookies by modifying your Web browser; however, if you choose to decline cookies, you may not be able to fully experience the interactive features of the site. A web beacon is a transparent image file used to monitor your journey around a single website or collection of sites.

They are also referred to as web bugs and are commonly used by sites that hire third-party services to monitor traffic. They may be used in association with cookies to understand how visitors interact with the pages and content on the pages of a web site.

We may serve third-party advertisements that use cookies and web beacons in the course of ads being served on our web site to ascertain how many times you've seen an advertisement. No personally identifiable information you give us is provided to them for cookie or web beacon use, so they cannot personally identify you with that information on our web site.

Some third-party advertisements may be provided by Google, which uses cookies to serve ads on this site. Google uses the DART cookie, which enables it to serve ads to our users based on their visits to this site and other sites on the Web. You may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy.

Browsers can be set to accept or reject cookies or notify you when a cookie is being sent. Privacy software can be used to override web beacons. Taking either of these actions shouldn't cause a problem with our site, should you so choose.

Children's Online Privacy Protection Act

This website is directed to adults; it is not directed to children under the age of 13. We operate our site in compliance with the Children's Online Privacy Protection Act, and will not knowingly collect or use personal information from anyone under 13 years of age.

Non-Personal Information

In some cases, we may collect information about you that is not personally identifiable. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users' movements around the site and to gather demographic information about our user base as a whole. The information collected is used solely for internal review and not shared with other organizations for commercial purposes

How You Can Correct or Remove Information

We provide this privacy policy as a statement to you of our commitment to protect your personal information. If you have submitted personal information through our website and would like that information deleted from our records or would like to update or correct that information, use our Contact page.

Updates and Effective Date

The Possibility reserves the right to make changes in this policy. If there is a material change in our privacy practices, we will indicate on our site that our privacy practices have changed and provide a link to the new privacy policy. We encourage you to periodically review this policy so that you will know what information we collect and how we use it.

Agreeing to Terms

If you do not agree to Privacy Policy as posted here on this website, please do not use this site or any services offered by this site.

Your use of this site indicates acceptance of this privacy policy.

PRIVACY OFFICER: Jenn Lyon Privacy Officer The Possibility Pool 445 Broadway Denver, CO. 80203 P: (303) 827-4218 Email:

Office for Civil Rights US Dept of Health & Human Services 1961 Stout St., Room 1185 FOB, Denver, CO 80294-3538 P: (303) 844-2024 | F: (303) 844-2025 | TDD: (303) 844-3439

You will be asked on a separate form to acknowledge that you have received this (your) copy of The Possibility Pool Notice of Privacy Practices (NPP) regarding my right to privacy. I understand that I may contact The Possibility Pool’s Privacy Officer in the event that I have any questions about the Notice or if I have any concerns regarding the use or disclosure of my personal health information.