Notice of Privacy Practices
This notice describes how health information may be used and disclosed under the Health Insurance Portability and Accountability Act, as well as The Holding Place (THP)'s additional policies regarding your confidentiality. Please review it carefully and speak with your therapist if you have any questions or concerns about your confidentiality.
I. CONFIDENTIALITY
As a rule, The Holding Place (THP) will not disclose information about you, including the fact that you (or your child) are a client of the practice, without your written permission, except in the circumstances described below. HIPAA permits healthcare providers to use and disclose Protected Health Information (PHI) for treatment, payment, and healthcare operations without obtaining a separate authorization. THP is committed to protecting your privacy and limits these disclosures to what is reasonably necessary to provide your care, operate the practice, or comply with applicable law. In most other circumstances, if THP wishes to disclose your information to a third party, we will request your permission in advance, either through your written consent at the beginning of our professional relationship or through a written authorization obtained at the time the need for disclosure arises. You may revoke your authorization, in writing, at any time by contacting your THP therapist, except to the extent that THP has already relied on your authorization to disclose information.
II. LIMITS OF CONFIDENTIALITY
There are some important exceptions to this rule of confidentiality, which are required by law. You have the right to ask any questions you may have about this policy, and to re-visit this conversation at any point in your treatment with your THP therapist.There are some situations in which your therapist is legally obligated to take actions which they believe are necessary to protect you or others from harm. In these situations your clinician may have to reveal some information about your treatment. These situations are unusual and your therapist will make every attempt to 1) fully discuss the situation with you before taking any action, unless doing so would further endanger you or someone else and 2) maintain your privacy to the greatest extent possible.
Risk of serious harm to yourself: If there is evidence that you are a danger to yourself and your therapist believes that you are likely to kill yourself unless protective measure are taken, your therapist may be obligated to seek hospitalization for you, or to contact family members, emergency contacts, and/or emergency services.
Risk of serious harm to another: If you communicate a specific and immediate threat of serious physical harm to an identifiable victim, and by your therapist's judgment demonstrate apparent intent and ability to carry out the threat immediately or imminently, THP may be required to take protective actions. These actions may include 1) notifying the potential victim and/or the potential victim's parent or guardian (if under 18), 2) contacting the police, and/or 3) seeking hospitalization for you.
Abuse or neglect of a child: If THP has reasonable cause to believe that a child under age 18 is suffering physical or emotional injury resulting from abuse or neglect which causes harm or substantial risk of harm to the child's health or welfare, THP is required by law to file a report with the Department of Children and Family Services. Once such a report is filed, THP may be required to provide additional information.
Abuse or neglect of a vulnerable adult: If THP has reasonable cause to believe that an elderly individual is suffering from or has died as a result of abuse, THP is required by law to report to the Department of Elder Affairs. If THP has reasonable cause to believe that a mentally or physically disabled individual is suffering from or has died as a result of a reportable condition (which is defined as a serious physical or emotional injury resulting from abuse and includes non-consensual sexual activity), THP is required by law to report to the Disabled Persons Protection Commission and/or other appropriate agencies. Once such a report is filed, THP may be required to provide additional information. THP does not need to report abuse if a disabled person who has been deemed competent invokes the psychotherapist-patient privilege to maintain confidential communications.
There are some additional situations where THP may be permitted or required to disclose information about you.
Court order: If you become involved in a legal proceeding and information about your diagnosis or treatment is requested, your communications with THP are generally protected by the Massachusetts psychotherapist-patient privilege and applicable confidentiality laws. However, there are circumstances in which a court may order the disclosure of treatment information. If THP receives a subpoena requesting records or testimony, THP will, when legally permitted, notify you promptly so that you have the opportunity to consult with an attorney and, if appropriate, object to or seek to quash the subpoena. THP will assert applicable legal protections and privileges on your behalf unless you authorize the disclosure or disclosure is otherwise required by law or court order. In some legal proceedings, including certain child protection matters or cases in which a person's mental health is directly at issue, a court may determine that some or all treatment information must be disclosed. If a court orders THP to provide records for judicial review or disclosure, THP must comply with the applicable legal requirements.
Health oversight: THP may be required by law to disclose protected health information to authorized federal or state agencies for health oversight activities, such as audits, investigations, inspections, licensing, or disciplinary proceedings related to the healthcare system or compliance with applicable laws.
Complaints or legal actions involving THP: If you file a complaint, grievance, or legal action against THP, THP may disclose protected health information that is relevant and reasonably necessary to respond to the complaint or defend against the claim, as permitted or required by law.
Worker's compensation claims: If you file a workers' compensation claim, THP may be required by applicable workers' compensation laws to disclose information related to your claim to the workers' compensation insurer, the Department of Industrial Accidents, or other persons or entities authorized by law.
III. YOUR RIGHTS
Under HIPAA, you have the following rights regarding your Protected Health Information (PHI):
Right to a copy of this notice: You have the right to receive a copy of this Notice of Privacy Practices at any time. THP reserves the right to revise this notice as permitted by law. Any revised notice will apply to the protected health information THP already maintains, as well as information created or received in the future. The most current version will be available upon request and on THP's website.
Right to request restrictions: You have the right to request restrictions on certain uses and disclosures of your PHI. You also have the right to request a limit on the medical information THP discloses about you to someone who is involved in your care or the payment for your care. If you ask THP to disclose information to another party, you may request that THP limit the information it discloses. However, THP is not required to agree to a restriction you request. To request restrictions, you must make your request in writing, and tell your THP therapist: 1) what information you want to limit; 2) whether you want to limit our use, disclosure or both; and 3) to whom you want the limits to apply.
Right to access your PHI: You have the right to inspect and obtain a copy of your clinical record, with limited exceptions permitted by law. If your record is maintained electronically, you may request an electronic copy. THP will respond to your request within the time required by applicable law and may charge a reasonable, cost-based fee for copies as permitted by law. If access is denied, you will receive a written explanation of the reason for the denial and information about any review rights available to you.
Right to request an amendment: If you believe your clinical record contains incorrect or incomplete information, you may request that THP amend the record or add a written statement to it. Requests must be made in writing and include the reason for the request. THP may deny the request in certain circumstances permitted by law, such as when the record was not created by THP or when the existing information is believed to be accurate and complete. If your request is denied, you will receive a written explanation and information about your right to submit a statement of disagreement for inclusion in your record.
Right to an accounting of disclosures: You have the right to request an accounting of certain disclosures of your PHI made by THP, as provided under HIPAA. This accounting does not include disclosures made for treatment, payment, healthcare operations, or certain other disclosures that are exempt under federal law.
Right to receive confidential communications by alternative means and at alternative locations: You have the right to request that THP communicate with you in a particular way or at a particular location. (For example, you may not want a family member to know that you are seeing your therapist. Upon your request, THP will send your bills to another address. You may also request that THP contact you only at work, or that THP does not leave voice mail messages.) THP will accommodate reasonable requests when appropriate. Requests should be made in writing whenever possible.
Right to be notified of a breach: If THP becomes aware of a breach of your unsecured protected health information that is required to be reported under HIPAA, THP will notify you as required by law.
Right to file a privacy complaint: You have the right to file a complaint if you believe THP has violated your privacy rights or failed to comply with HIPAA or this Notice of Privacy Practices. Complaints may be submitted to THP at admin@holdingplacehealing.com or directly to the Office for Civil Rights. THP will not retaliate against you for filing a complaint or for exercising any of your rights under HIPAA, for assisting in an investigation by HHS or another appropriate authority, or for opposing an act or practice that you believe in good faith violates HIPAA.
EFFECTIVE DATE: 9/1/2026