Introduction/General Principles
In order to ensure the safety and privacy of clients accessing counseling, psychiatric, and substance use recovery services, it is the policy of the SIMS Foundation to protect the confidentiality and privacy of those who seek services and to hold confidential all personally identifying or individual information, communications, observations, and information made by, between, or about clients, including the identity of clients. SIMS Volunteers are charged with maintaining the confidentiality of clients as outlined in the SIMS Foundation policies and in federal and state law. The SIMS Foundation shall not disclose any personally identifying information or individual information collected in connection with services requested, utilized, or denied through its programs or reveal any individual client information without the informed, written, reasonably time-limited consent of the person about whom information is sought. The SIMS Foundation will avoid any inadvertent release of personally identifying information or individual information about any client. The obligation to maintain confidentiality does not end when the service to a client is concluded. Confidentiality extends to all current and former clients, including those who were denied services.
Volunteers must understand that their volunteer position is contingent on adherence to confidentiality. Clients who interact with other clients must understand that their receipt of services is contingent on rigid adherence to confidentiality.
Confidential information can be released only in accordance with the guidelines set out below and in accordance with federal and state law.
Written Agreement to Maintain Confidentiality
All volunteer must sign a written agreement to maintain confidentiality. This agreement will be placed in the volunteer files maintained by SIMS staff.
Personally identifying or individual information will be shared within the SIMS Foundation on a need-to-know basis. Generally, only the clinical staff and designated providers will have access to personally identifying or individual information. However, volunteers may meet clients or come across personally identifying or individual information through the course of their participation or duties, and so will be bound by the standards outlined in this policy.
Definitions
Confidential information includes any written or spoken information shared in confidence between a client and staff in the course of that relationship, which includes any information that might identify the identity of someone who has sought services. Confidential communication includes all information received by the client and any advice, report, or information given or made by the staff. Any and all knowledge, advice, records, logs, client and organizational records, or information (including electronically maintained records relating to a client) are confidential and are not to be shared with a third party. Communications are confidential even if the client shares the information with third parties, who are working to further the interest of the client, in the presence of the staff. Confidential documents received from other agencies (for which a client had to execute a written release) are confidential and part of the scope of confidential communications.
‘Personally identifying information’ or ‘personal information’ is individually identifying information about an individual. This information can include—
Client is any person, including any adult, youth, child, or family who contacts the SIMS Foundation or receives any services from the SIMS Foundation, whether those services are received by telephone, fax, electronically, or in person and whether those services are sought for themselves or for someone else.
Staff includes all paid and unpaid staff, volunteers, providers, consultants, board members, and student interns of the SIMS Foundation.
SIMS Photo Release Agreement
By agreeing to the SIMS Photo Release Form, you are allowing SIMS Foundation to copyright, use, and publish any of the images in any format taken of you as a SIMS Volunteer. These images may be used in subsequent years for a variety of purposes and may appear on the website, social media channels, promotional materials, or any other media now known or to be invented. The SIMS Foundation will use the images exclusively for SIMS-related purposes and not for any commercial gain.
SIMS Foundation’s Commitment to Privacy At SIMS Foundation (“SIMS”), we know that you care about how your information is used and shared. This Privacy Policy (“Policy”) explains our privacy practices and the choices you can make about the way your information is collected and used by SIMS. We appreciate you trusting us with your information and strive to process your information carefully and sensibly.
By continuing to use the services of SIMS, you agree to let us use your information in the ways discussed in this Policy. For this reason, it is very important that you read this entire Policy.
Services This Policy Covers This Policy applies to the online services owned by SIMS, including our website and any future online services we develop. This Policy also covers our privacy practices when it comes to processing donations made to SIMS both online and offline.
This Policy does not cover the practices of companies that SIMS does not own. Sometimes, we may display a link to a partner organization’s services. When you click on this link, you are leaving SIMS and are no longer covered by this Policy. Always be sure to read the other organization’s privacy policy as well, so that you can understand what they are doing with your information.
This Policy also does not cover how SIMS collects, stores or processes sensitive information that may be provided to SIMS when you contact us to access our offline health services. SIMS adheres to the Health Insurance Portability and Accountability Act (HIPAA) when collecting such sensitive information, uses secure encryption software to protect this information and only allows for licensed clinical staff at SIMS to access this information. However, the full extent of the privacy practices that we have in place regarding this information is beyond the scope of this Policy. For more information regarding the way we process sensitive information, you may contact SIMS using the methods explained at the end of this Policy.
What Information is Collected by SIMS? Personal Information: Personal information is any information that allows for an individual to be personally identified. For example, your name, email address, phone number, residential address and credit card details are all considered personal information. Other information, such as your interests, economic status, education and job title, may also be considered personal information if that information, when combined with other information, can reveal your identity.
SIMS only collects personal information from you when you voluntarily consent for us to use it. You voluntarily consent for us to use your personal information by reaching out to us via email, signing up to receive information from us, or by making a donation. For example, a donor may be required to provide us with their name, address, payment details, email address, and/or telephone numbers so that we can successfully process their donation. SIMS does not collect or store any credit card information. Instead, we use Stripe, a PCI compliant third-party vendor to process credit card donations. You can access Stripes’s own privacy policy at https://stripe.com/us/privacy.
Non-Personal Information: Non-personal information is information that can be processed in a way that does not allow for your identity to be revealed. This may include information such as your IP address, browser type, device type, frequency of visits to a website, referring websites and network connection type. We collect such non-personal information by using Web Server Logs. This information is used by us to monitor and improve our services. SIMS does not use any cookies to collect this type of information.
How Does SIMS Use Information Collected? There are a number of reasons we collect your information – selling or renting it is not one of them! We primarily use your information to enable us to accept donations and to allow us to communicate with you about our programs, projects, and activities. We also use your information for some internal and analytical purposes. For example, we may use your information to better understand our supporter network, to respond to requests for information, to screen for misuse of our services, or to improve and assess our services, donor base and outreach. SIMS Foundation is based in the United States, and any information transmitted to us is stored, accessed and processed in the United States.
Does SIMS Share My Information with Third Parties? We do not trade, share, or sell the personal information that you provide to us with other organizations or entities. We only share your information with third parties in the following ways:
Will I Receive Emails from SIMS?
Information Retention and Your Rights SIMS only keeps your information for as long as necessary to provide our services. Under the law, you also have the right to request at any time for us to:
If you would like for us to do any of the above, you can contact us using the information provided at the end of this Policy. We will always try to fulfill your requests. However, sometimes we may be required to retain your information, even if you have made one of the above requests, in order to comply with our legal and regulatory obligations. For example, we may be required to keep a history of transactions to report our taxes or may need to retain some information for law enforcement purposes such as fraud monitoring, detection and prevention.
Keeping Your Data Safe We are committed to protecting your personal information and have physical, electronic and managerial systems and procedures in place to help safeguard your information. Unfortunately, no system can guarantee complete security. Third-party viruses or security failures may result in your personal information being compromised. You can help prevent unauthorized access to your information by using antivirus software and limiting access to your personal computer. In the unlikely event that your personal information is compromised, we will notify you within a reasonable time of such breach coming to our attention.
Protection of Children Our online services are not directed, or intended, for children under the age of 13 years. We do not knowingly collect personal information from anyone under this age limit and delete this information as soon as we become aware of it. If you live outside of the U.S., your country may apply stricter age limits. In some cases, even if you are older than 13, we may not be able to allow you access to our services. If you are under the age of 18 and wish to make a donation to SIMS by credit or debit card, then we may require a parent or legal guardian to consent to the donation being made.
Changes Made to This Policy We may modify this privacy policy from time to time. The date at the top of this Policy lets you know when this Policy was last revised. If we make a change to this Policy that we believe materially affects the way we use your information, we will attempt to contact you and obtain your consent to the change. It is important to check back here occasionally to make sure you have read the latest policy. By continuing to access or use our services after the policy changes, you allow for us to use your information in the way we describe in our updated policy.
Contact Us In this Policy, we have tried our best to lay all our privacy practices out on the table for you. However, if you ever have any questions, concerns, requests, or comments about how we use your information, you can contact us by email, telephone, or mail at:
info@simsfoundation.org 512-472-1008 P.O. Box 2152 Austin, TX 78768
SIMS is not a 24-Hour crisis line. If you are in crisis, please call 512-472-HELP or 911.