This page was last updated on 8/12/2022.
This notice describes how your information as a user of services from the UI Wellness and UI Employee Assistance Program (EAP) may be used and disclosed and how you may access this information. Throughout this notice we will refer to your confidential health information, which includes data that identifies you and describes the services you receive from these two offices. This notice applies to all the records, including electronic and paper, created by these offices about you.
UI Wellness and UI EAP collect confidential health information about you and store it in a confidential file and on a secure computer. This is your client file. The client file is the property of UI Wellness or UI EAP, but selected information in the file belongs to you. The following describes the uses and disclosures of your confidential health information by these two offices and gives you some examples of each category. Not every use or disclosure will be listed.
Your Rights Regarding Confidential Health Information
For clients of UI Wellness: Your confidential health information is considered part of the personal and confidential information in a personnel record about you. Iowa law protects this information as confidential, subject to other laws governing the University. In certain cases, we are obligated to report this information. An example is if while providing health coach services, we become aware of sexual harassment, sexual misconduct, dating/domestic violence, or stalking. Consistent with federal law and per UI policy, UI Wellness is required to report that to the Office of Institutional Equity’s (OIE’s) Title IX & Gender Equity Office (TIX-GE). Link to University policy on sexual misconduct.
For UI EAP clients: Your confidential health information provided to the University’s Employee Assistance Program is subject to a heightened level of confidentiality. UI EAP counselors are not required to report disclosures regarding sexual misconduct to TIX-GE. UI EAP counselors will seek your written permission for disclosure of confidential health information except in situations involving child or dependent adult abuse or neglect, imminent danger to self or others, or due to a valid subpoena or other court order.
Right to Request Confidential Communications
You have the right to request where and how we communicate with you about your confidential health information. For example, you may wish to have your appointment reminders sent to a different email address. We must approve your request to ensure that we are able to provide communications in the format requested. To make such a request, let your provider of services know of the alternate address. EAP intake information will indicate where and how you prefer to receive messages. You will not need to provide a reason for your request.
Right to Inspect and Copy
You may request a copy of your client record with any of the UI Health and Well-Being units. To request a copy, please send a written request to your service provider in the respective area or the director in the Health and Well-Being unit from which you receive services.
For UI EAP: Your consent will be required for release of your confidential health information from EAP, even for release of information to yourself. This includes disclosures related to referral or treatment services, disclosures for which you have signed a release, and/or emergency disclosures for which you did not consent. You may submit your request to your counselor or to the director of the UI EAP firstname.lastname@example.org .
In the event there is a data breach involving your confidential health information, we will notify you at the last address we have on record. We will inform you of the nature of the breach and corrective action taken to prevent a recurrence.
Revocation of Permission
If you provide us with permission to use or disclose health information about you, you may revoke that permission, at any time by writing or emailing from your authorized email account the following individuals in the order provided:
- Your service provider in the respective area (UI Wellness or UI EAP); and then
- Director in the respective area (UI Wellness or UI EAP) Bronwynemail@example.com; firstname.lastname@example.org
Once you revoke your permission, we will no longer use or disclose confidential health information about you for the reasons covered by your written revocation. Your revocation does not apply to any disclosures already made with your permission. In addition, your revocation does not apply to the UI’s records of the services that we provided to you.
Concerns or Questions
If you believe your privacy rights have been violated, you may file a complaint with your service provider or the director of the respective service. If you are not satisfied with the resolution offered, you may file a complaint with the Senior Assistant Vice President, University Human Resources, The University of Iowa (Attn. email@example.com) There will be no retaliation or penalty for filing a complaint.
Uses of Confidential Health Information
For UI Wellness and UI EAP clients: We use confidential health information while providing services. Disclosure would only be with your written permission except in certain circumstances as described below.
UI Wellness may disclose confidential health information when a law requires that we report information to government agencies, including federal officials or special investigative officers, and law enforcement personnel about victims of abuse, neglect, or domestic violence, and when required to do so in judicial or administrative proceedings.
UI EAP will only disclose information related to child or dependent adult abuse or neglect to the Department of Human Services. In the event there is evidence of clear and imminent danger to self or others, we may contact a family member or law enforcement, or give information when required to do so in judicial or administrative proceedings.
Should you participate in a research study, a privacy board or Institutional Review Board (IRB) will determine the measures in place to protect your identity from disclosure to organizations outside the University of Iowa. You may be asked to participate in a research study, and if you agree, you will need to give special authorization to disclose your confidential health information.
UI Wellness or UI EAP may gather information to determine the effectiveness of an intervention or program. Such information is only disclosed in aggregate with the goal being to help improve our services.
Uses and Disclosures for Which Your Written Permission is Required
For UI Wellness and UI EAP clients: Individually identifiable disclosure would only be with your written permission or when required by law as noted above.
Federal and state law imposes special privacy protections on the use and disclosure of certain confidential information about you. We must obtain your written permission to share sensitive medical information, including the following:
- Psychotherapy notes written by your therapist
- Other mental health information
- Substance (drug and alcohol) abuse treatment information
- HIV/AIDS testing, diagnosis, and treatment information