Privacy Policy

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

Effective April 10, 2023

When you use the wRight Insight platform, mobile app, and/or website, certain pieces of data will be
electronically collected, processed, and stored as part of the user experience. As such, that information is
governed by federal, state, and professional standards to protect your privacy. wRight Insight will adhere to
those laws and regulations including the Health Insurance Portability and Accountability Act of
1996 (HIPAA), Health Information Technology for Economic and Clinical Health (HITECH) act of 2009, the
current state of Texas laws and regulations governing medical records and disclosure (Texas Health and
Safety Code, Chapter 611), and the Texas Licensed Professional Counselor Act. For your protection,
information collected about you will only be disclosed in compliance with the previously mentioned laws
and regulations. This policy details and explains how your mental healthcare information will be used
and disclosed. To the extent required by laws and regulations, these policies will apply to the provision
of services including therapy, clinical supervision, training, consultation, and expert testimony, as well as
the collection of payments and scheduling

“Use and disclosure of protected health information for the purposes of providing services.
Providing
treatment services, collecting payment and conducting healthcare operations are necessary activities for
quality care. State and federal laws allow us [wRight Insight] to use and disclose your health information
for these purposes.” (American Counseling Association)

THERAPY

Your electronically obtained confidential health information will be used to provide, manage, and
coordinate your mental health care during the delivery of your treatment. Also, as part of your
treatment, your clinician may coordinate and consult with other professionals to optimize your
treatment. Additionally, there may be occasions when it is necessary to refer you to other professionals
or organizations for continuation of care or necessary services.

Electronic Communication

According to the Substance Abuse and Mental Health Services Administration (SAMHSA), telehealth is
the use of telecommunication technologies and electronic information to provide care and facilitate
client-provider interactions. It is comprised of two forms:

1. Two-way, synchronous, interactive client provider communication through audio
   and video equipment (also referred to as telemedicine)
2. Asynchronous client-provider interactions using various forms of technology

While rigorous precautions have been taken to enhance the security of this electronic communication,
wRight Insight cannot absolutely ensure the confidentiality of any form of communication through
electronic media, including email and text messages. If you prefer to communicate via email or text
messaging for issues regarding scheduling or cancellations, you are doing so understanding that there is
risk involved.

Healthcare Operations

Your electronically gathered health data may be used for the purpose of scheduling appointments,
reviewing treatment procedures, reviewing business activities, processing payments, and any other
administrative activities essential to the provision of your treatment or other services. Occasionally, tech
support personnel, webmasters, and other essential support will have access to your personally
identifying information in order to provide smooth and seamless delivery of services. Support stall and
contractors will have the same confidentiality protection responsibilities as the therapist and wRight
Insight in this regard. Otherwise, this information will not be disclosed without your express writen
consent unless mandated or allowed by law.

Telehealth

wRight Insight provides therapy only in a virtual video format on the wRight Insight platform. If you
choose to use telehealth for your treatment, it is important to understand that:

1. You retain the option to withhold or withdraw consent at any time without affecting the right to
   future care or treatment to the extent that it is feasible given that in-person sessions are not
   offered
2. All existing confidentiality protections that apply to an in-person seting are equally applicable to
   the telehealth format.
3. Your access to your therapy records is guaranteed, and copies of this information are available
   for a reasonable fee.
4. Dissemination of any of your identifiable images or information from the telehealth interaction
   to researchers or other entities shall not occur without your writen consent.
5. There are potential risks, consequences, and benefits of telehealth. These risks are specified and
   discussed in the Telehealth Informed Consent form. By using telehealth therapy on the wRight
   Insight platform, you are agreeing that:

• • Although absolute confidentiality cannot be guaranteed, you understand that the site is
    HIPAA compliant, and strenuous efforts have been made to ensure security of all
    communication and data.
  • You understand that virtual therapy does not provide all the same benefits as an in-person
    visit because you will not be in the same room as your therapist.
  • You understand that virtual therapy has potential benefits including convenient and easier
    access to care, reduced patient wait time for an appointment, and reduced client travel time
    and travel-related expense.
  • You understand there are potential risks to this technology, including internet or power
    interruptions, unauthorized access, technical difficulties, and inability of therapist to notice
    various sensory cues that might otherwise be discerned in an in-person visit.
  • You understand that either you or your therapist can discontinue the telehealth consult/visit
    if it is determined that the video therapy sessions are not ideally suited for your situation
  • You have had a consultation with your therapist, during which you had the opportunity to ask
    questions related to the pros and cons of using telehealth. Your questions have been
    answered and the risks, benefits and any practical alternatives have been discussed with you
    in a language in which you understand.
  • BY SIGNING THIS DOCUMENT, YOU ACKNOWLEDGE:

TELEHEALTH IS NOT AN EMERGENCY SERVICE AND IN THE EVENT OF AN EMERGENCY,
YOU WILL USE A PHONE TO CALL 911 OR 988.

TO MAINTAIN CONFIDENTIALITY, YOU WILL NOT SHARE YOUR TELEHEALTH
APPOINTMENT LINK WITH ANYONE UNAUTHORIZED TO ATTEND THE APPOINTMENT.

Exceptions to Confidentiality

wRight Insight will ensure your rights to confidentiality to the fullest extent possible. The session content
and all relevant materials to your treatment will be held confidential unless you request in writing to have
all, or portions of such content released to a specifically named person/persons. An Authorization to
Release Information must be fully and accurately completed before your information can or will be
released. wRight Insight will not disclose information about you with any person including your family
members without a specific and time-limited written consent from you unless authorized or allowed by
law.

Mandated Reporting: There are legal limitations to confidentiality. wRight Insight adheres to the
laws regulating Licensed Professional Counselors and as such is mandated by Texas law to report
the following:

• Reasonable suspicion of physical, emotional, or sexual abuse of a child(ren) under the age of
  18 years. (Texas Family Code Chapter 261, Subchapter B)
• Suspicions of abuse, neglect, or exploitation in the case of an elderly (over 65) or disabled
  person who may be subjected to these abuses. (Texas Human Resources Code Chapter 48,
  Subchapter B)
• The disclosure of abuse, neglect, and unprofessional or unethical conduct that occurred in
  health care facilities (Texas Health and Safety Code Chapter 161, Subchapter L)
• The disclosure of sexual exploitation by a mental health provider will be reported to the
  District Attorney and to the agency that regulates the licensed health care provider. (Texas
  Civil Practice and Remedies Code, $81.006)

Additionally, your confidential information MAY be disclosed for the following reasons:

• If you threaten or attempt to commit suicide or otherwise conduct yourself in a manner in
  which there is a substantial risk of incurring serious bodily harm and the threat is credible
  and/or imminent wRight Insight is allowed to report this to medical or law enforcement
  personnel.
• If you threaten grave bodily harm or death to another person and the threat is credible
  and/or imminent wRight Insight is allowed to report it to law enforcement personnel.
• If a court of law issues a legitimate subpoena for information stated on the subpoena
  related to your therapy or therapy records.
• If you are in therapy or being treated by order of a court of law, or if information is obtained
  for the purpose of rendering an expert’s report to an attorney.
• Occasionally wRight Insight may need to consult with other professionals in their areas of
  expertise in order to provide the best treatment for you. In this case, all effort will be made
  to share this information without using your name or identifying details
• In the event that you file a lawsuit or a complaint with a regulatory board, your confidential
  information may be used as part of the defense.
• In the event that you become incapacitated during a treatment session, wRight Insight will
  call 911 and notify your emergency contact.
• In the instance of therapist death, incapacity, or the termination of wRight Insight
  counseling practice, your records will be in the custody and control of Sarah Garay who can
  be reached at sgaray@fbwc.org

PAYMENT

All services provided by wRight Insight require advance payment using the online payment system
incorporated within the app/website unless other arrangements have been made in advance. While
wRight Insight currently does not accept third party payors, this is subject to change and all clients will
be notified if and when this change is made. In order to process your payment, certain banking
information including your name and debit or credit card information is collected. This information will
be encrypted and stored only for as long as you are an active client or regular trainee of wRight Insight
and will be used solely for the purpose of processing and collecting fees. This information will not be
disclosed in any circumstance without your writen consent.

CLINICAL SUPERVISION, TRAINING, CONSULTATION, AND EXPERT TESTIMONY

In addition to therapy, wRight Insight also provides clinical supervision, training, consultation, and expert
testimony. Your data will be collected and used solely in order to provide these services, schedule,
create certificates of atendance, and collect and process payments.

• If you are an LPC-Associate, your privately collected data will be protected along with any verbal
  or written personally identifying or confidential data provided about your clients discussed
  during the course of clinical supervision. All relevant HIPAA and Texas laws and regulations
  pertaining to client rights and confidentiality, as well as supervision, will apply.
• If you are a client seeking consultation or expert testimony for a protective order, custody, or
  divorce case, you will be afforded the same rights and protections as therapy clients.
• If you are an attendee of a training, your personally identifying information will be collected,
  stored, and processed solely for the purpose of scheduling, attending, evaluating, receiving a
  certificate, processing payments, and marketing future trainings. Your personal information will
  be encrypted for payment processing as with all other clients but may not be encrypted for the
  other purposes listed above.
• If you are an attorney or prosecutor seeking consultation or testimony for a court case, your
  payment information will be encrypted. Information regarding clients of wRight Insight will not
  be disclosed without their express written consent. Information regarding clients/victims who
  are not clients of wRight Insight will only be disclosed as permitted by law and in keeping with
  relevant agency/organization policy. If you share information regarding your clients which is
  confidential, a written notice of such confidentiality shall be submitted to wRight Insight
  informing wRight Insight of the parameters of confidentiality. Failure to produce such notice
  may result in confusion and inadvertent disclosure.

CLIENT RIGHTS:

In compliance with state laws governing Licensed Professional Counselors, all mental health records are
kept for seven years or five years post the age of majority or whichever is greater.

As a client of wRight Insight:

• You have a right to request where and how you are contacted (home, work, cell, text, email,
  etc.) and whether it is safe to leave a message
• You have a right to request the release your medical records to yourself or another individual
  provided you have signed a time-limited written authorization.
• You have a right to revoke the release authorization provided it is in writing and only to the
  extent that the information has not already been released.
• You have the right to inspect and copy your clinical records, however, wRight Insight/therapist
  may limit or deny this request if it is determined that emotional harm will result from the
  inspection of such clinical records. A $25.00 fee will be charged for either electronic or paper
  copies to compensate for time and/or paper and ink. If you wish to receive paper copies,
  postage will also be charged
• You have a right to add information or amend your mental health records if you believe they are
  incorrect. Any changes you request must be signed and dated and will be noted in a separate
  addendum attached to your file unless the changes are solely grammatical or spelling errors.
  Any changes must be requested and submitted in writing electronically within 14 days. wRight
  Insight/therapist has the final say in clinical impressions. If your changes are denied, you have
  the right to file a disagreement statement which will also be filed with the record.
• You have the right to know to whom any disclosures have been made and for what purpose.
  Exceptions to confidentiality laws include disclosure for treatment, payment, or healthcare
  operations, disclosures pursuant to a signed release, disclosures made to client or minor client’s
  parent or legal guardian, disclosures for national security or law enforcement, disclosures
  pursuant to a subpoena, compliance with regulatory investigations and mandatory or safety
  disclosures
• You have the right to request restrictions on uses and disclosures of your healthcare
  information, however, wRight Insight is not obligated to agree. This request must be made in
  writing, signed, and dated.
• You have the right to receive changes in policy and be notified of these changes.

The goal of wRight Insight is to provide high quality professional services in an atmosphere of
confidentiality and care. However, wRight Insight acknowledges that clients may have grievances and, as
such, every effort will be made to resolve your grievances in a mutually satisfactory manner. Your rights,
in this regard, include:

• • The right to question and discuss with wRight Insight any aspect of the counseling process that
    concerns you. wRight Insight may be reached at 281-247-0877 or wrightinsight@info.pro
  • The right to seek services elsewhere if not satisfied with wRight Insight service.
  • You have the right to request and receive referrals for other qualified mental health professionals.
  • If still dissatisfied, you may file a complaint with:

• • For violations of HIPAA, you may file a complaint with: