Effective Date: June 30th 2025
Last Updated: June 30th 2025
1. Purpose
This Privacy Policy describes how BCBA Teachers Ltd. collects, uses, protects, and discloses your health and personal information in compliance with the Health Insurance Portability and Accountability Act (HIPAA) and the Behavior Analyst Certification Board (BACB) Ethics Code for Behavior Analysts.
We are committed to protecting your Protected Health Information (PHI) and maintaining the highest standards of professional confidentiality.
2. Your Protected Health Information (PHI)
PHI includes information that identifies you and relates to your health condition, services you receive, and payment for services. This includes:
- Name, contact info, and date of birth
- Diagnosis and treatment data
- Notes, records, and reports
- Session recordings (if consented)
3. How We Collect and Use PHI
We collect PHI directly from you or your authorized representatives during:
- Intake and registration
- Assessments and treatment
- Phone, email, or Zoom conversations
- Billing and payment processing
We use PHI only for purposes of treatment, payment, healthcare operations, and supervision, unless you authorize otherwise.
4. Communication Methods & Safeguards
We use HIPAA-compliant practices for all forms of communication:
✅ Phone
- Only authorized personnel will make or receive client calls.
- We will verify your identity before discussing sensitive information.
- We use secure, encrypted email when sending PHI.
- If you prefer unencrypted email, you must provide written consent acknowledging the risks.
✅ Zoom (Telehealth)
- All virtual sessions are conducted through HIPAA-compliant Zoom accounts.
- Sessions are not recorded unless you give prior written consent.
- A private and secure environment is used on both ends.
5. Your Rights Under HIPAA
You have the right to:
- Access your records
- Request corrections
- Request confidential communication
- Receive a list of disclosures
- File a complaint with us or the U.S. Department of Health & Human Services
6. Disclosures
We may disclose your PHI without your authorization only:
- To comply with laws and legal proceedings
- To prevent a serious threat to health or safety
- For supervision or consultation (anonymized where possible)
- For billing, quality assurance, or required audits
- As required by the BACB Ethics Code and supervision guidelines
No other disclosures will be made without your written authorization.
7. Data Security Measures
We take administrative, technical, and physical measures to protect your data:
- Password-protected devices and secure platforms
- Encrypted communication tools
- Confidentiality training for all staff
- Limited access to records based on role
- Breach notification procedures in compliance with HIPAA
8. BCBA Ethics Compliance
Our providers are bound by the BACB Ethics Code for Behavior Analysts, which requires:
- Maintaining confidentiality
- Informed consent for services and data use
- Secure storage and handling of all records
- Ethical communication and professional boundaries
9. Changes to This Policy
We may update this policy from time to time to reflect legal, technical, or procedural changes. The updated policy will be posted with the new effective date.
10. Contact Information
If you have any questions, requests, or complaints regarding this policy, please contact:
BCBA Teacher Ltd.
250-597-4313
amandabroadway@bcbateacher.com
Amanda Broadway HIPAA Privacy Officer