RECOVERY SERVICES OF GREATER DAYTON LLC 
DBA: HARMONY WOMEN’S RECOVERY 
POLICY AND PROCEDURE 

TITLE: Privacy and Confidentiality Policy 

POLICY NUMBER: OP.11 

POLICY OWNER: CEO 

POLICY TYPE: Operations 

APPROVED BY: Clinical Leadership 

EFFECTIVE DATE: March 2023 (Revised February 2025) 

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POLICY STATEMENT 

Recovery Services of Greater Dayton LLC, DBA Harmony Women’s Recovery, is committed to protecting the confidentiality, integrity, and security of clients' protected health information (PHI) in compliance with the Health Insurance Portability and Accountability Act (HIPAA), Title 42 of the Code of Federal Regulations (CFR) Part 2, and applicable state laws. 

REFERENCES 

- Health Information Portability and Accountability Act of 1996 (HIPAA) 
- Title 42, Part 2 of the Code of Federal Regulations (CFR) 
- Ohio Revised Code Section 5119.36 

APPLICABILITY 

This policy applies to all staff, interns, contractors, and clients receiving care through Recovery Services of Greater Dayton LLC, DBA Harmony Women’s Recovery. 

DEFINITIONS 

- HIPAA: Federal law ensuring the privacy and security of PHI. 
- PHI (Protected Health Information): Any individually identifiable health information related to a client's past, present, or future physical or mental health condition. 

PURPOSE 

This policy outlines the procedures for protecting client confidentiality and the conditions under which PHI may be used and disclosed. 

USE AND DISCLOSURE OF PHI 

Recovery Services of Greater Dayton LLC, DBA Harmony Women’s Recovery, will only use or disclose PHI with client authorization, except in the following situations: 
 
1. Medical Emergencies: PHI may be disclosed when necessary to provide emergency medical care. 
2. Threats to Safety: If a client poses an imminent danger to themselves or others, PHI may be shared with appropriate authorities. 
3. Mandated Reporting: Reports of suspected child abuse, elder abuse, or other legal reporting obligations. 
4. Court Orders: PHI may be disclosed if legally compelled by a valid subpoena or court order. 
5. Public Health and Oversight Agencies: PHI may be shared with governmental authorities for compliance with health regulations. 
 
Clients are informed about these exceptions upon admission. 

INDIVIDUAL RIGHTS 

Clients have the following rights regarding their PHI: 
 
1. Right to Access: Clients may request access to their records in writing. If a request is denied, the decision will be reviewed by the Executive Director, with documentation of the reason. 
2. Right to Amend: Clients may request corrections to their PHI if they believe it is inaccurate. 
3. Right to Restrict Disclosure: Clients may request restrictions on certain disclosures, though Recovery Services of Greater Dayton LLC, DBA Harmony Women’s Recovery, may not always be able to comply. 
4. Right to Confidential Communication: Clients can request communication through specific channels (e.g., phone, mail, or email preferences). 
5. Right to File a Complaint: Clients may file complaints if they believe their PHI rights have been violated. Complaints can be submitted to: 
   - Privacy Officer: Taylor Roustio 
   - Contact Information: Taylor@recoverydayton.com 
 
Clients are not required to waive their rights as a condition of receiving services, and filing a complaint will not result in retaliation. 

LEGAL DUTIES OF RECOVERY SERVICES OF GREATER DAYTON LLC, DBA HARMONY WOMEN’S RECOVERY 

Recovery Services of Greater Dayton LLC, DBA Harmony Women’s Recovery, is legally obligated to: 
- Maintain the privacy of PHI. 
- Provide clients with this Notice of Privacy Practices. 
- Abide by the terms outlined in this policy. 
- Notify clients in case of a PHI breach. 

RECORD RETENTION AND SECURITY 

- Client records will be retained for at least seven (7) years post-discharge. 
- All records are stored securely in electronic medical records (EMR) systems. 
- Staff receive training on proper handling and security measures for PHI. 

CONTACT FOR PRIVACY CONCERNS 

For further information regarding this policy, clients may contact: 
 
Privacy Officer: Taylor Roustio 
Phone: (937)247-4717 
Email: Taylor@recoverydayton.com 

REVISION HISTORY 

- March 2023: Initial Policy Creation   
- February 2025: Revised for HIPAA and LegitScript Compliance 

APPROVED BY 

Taylor Roustio   
Privacy Officer 
Recovery Services of Greater Dayton LLC, DBA Harmony Women’s Recovery