Kendal is committed to protecting your personal information. This includes application materials, financial, medical and personal information. We do not sell or share our mailing list information with outside organizations.
If you have questions about our policy or would like to speak with our compliance officer, please call 1-800-548-9469.
Effective August 6, 2020
• Information that identifies you directly, such as your name, e-mail and mailing addresses, and phone number;
• Information about your contacts and activities with us; and
• Information collected using cookies and similar technologies when you visit our Website, such as your IP address, device ID, and internet usage.
Information you provide. We request your contact and other pertinent information when you contact us about any aspect of our work or service.
Records of communications. Our systems routinely log and retain records of incoming and outgoing phone calls, voicemails, emails, faxes, and text messages, as well as originals and electronic copies of letters and documents.
In-person visits. When you visit our office, we may collect your name, the date and times you visited, and who you were here to see. We may also use security cameras and other technologies to protect the physical security of our offices. If you use our guest wireless network, we may also log information about your use of that service for network administration, analysis, troubleshooting, and other operational purposes.
Other sources. We may receive information about you from professional referrals, Kendal Communities, sources in the field of aging services, and marketing research.
Payment data. We collect data necessary to process payments for events, and data is stored by a third-party payment processing service.
Kendal may use the personal information described above for multiple purposes, including:
• Responding to requests for information.
• Sharing information with Kendal at Oberlin.
• Sending direct emails and mail you requested or that we believe may be of interest to you based upon the information you provided and about our programs and services. We may also send you text messages if you give us “opt in” permission. See section titled “How to Opt-out of Direct Marketing.”
• Inviting you to events hosted or sponsored by Kendal Early Learning Center or Kendal at Oberlin.
• Conducting business operations.
• Reviewing job applications.
• Operating the Website, including testing, usage analytics, market research, troubleshooting, and improving.
• Protecting the Website and operations against fraud, unauthorized access attempts, identity theft, or other unlawful activities.
• Defending, protecting, and enforcing our rights, interests, and property.
• Protecting the rights of and interest of our Communities, personnel; and others.
• Maintaining the physical security of our offices.
• Complying with applicable laws, regulations, and other legal requirements.
How We May Share Your Information
We may disclose personal information or personal information may be accessible to the following categories of third parties:
Kendal at Oberlin for marketing and service optimization.
Third party Service Providers who support our business operations.
Compliance with Laws and Legal Process and Liability Insurers. To comply with applicable laws, we may disclose your personal information to third parties in response to a court order or subpoena. In addition, we may disclose your personal information, without notice to you, to government agencies in response to lawfully issued requests.
Protection of Our Websites and Services. We may disclose your personal information to third parties to enforce our Terms and Conditions, Codes of Online Conduct, protect our rights and properties, or protect the rights and properties of our guests and users of our services. For these purposes, we may disclose personal information to government agents, including law enforcement, private companies assisting with fraud protection or investigation, and our professional advisors.
If you prefer that we stop including you in our direct marketing, you may notify us in one of the following ways:
• Emails: Click “unsubscribe” in any e-mail you receive.
• Text messaging: Text “STOP” to the number from which the text was sent. After you opt out, your phone location will no longer be identified, and you will no longer receive automated messages.
• Direct mails: Send a letter to this street address:
Kendal Early Learning Center
c/o Kendal at Oberlin
Attention: Marketing Opt-out
600 Kendal Drive
Oberlin, OH 44074
KELC maintains reasonable security procedures and practices appropriate to the nature of the categories and types of personal information we collect to protect against loss, misuse, unauthorized access, disclosure, alteration, or destruction. However, please be aware that methods of electronic transmission and electronic storage are not completely secure, and we cannot guarantee the security of your personal information. Therefore, you use our Websites and services at your own risk, and we do not guarantee the performance or adequacy of our security measures.
We provide links to other websites, including social media platforms, only as a convenience to our users. The links do not mean that we endorse the materials disseminated at those locations. We also maintain an online presence on social media platforms. When you interact with our pages on these social media platforms, including “liking” our pages, sending us direct messages, or submitting other information, your information is subject to the data practices of these platforms. If you use these links to other websites or social media features, the third parties that operate those locations may collect your IP address, which page you are visiting on our Website, and may set a cookie to enable the feature to function properly. We are not responsible for the privacy practices, content, or reliability of any third-party links to our Website. If you have any questions about how these third parties collect or use your information, you should review their privacy policies and contact them directly.
Information collected when you access our Website. When you visit or use our Website, Kendal and third parties we authorize place cookies and other internet devices on your browser to enable some of the functionality of the Websites and mobile applications and to collect technical data about your use of our Website. Similar identifiers are used for serving ads on third-party websites and mobile device applications. Different types of cookies will remain on your device for different time periods, including the following:
• Session cookies are temporary and only remain on your browser until you close the browser after using the Websites or apps. Session cookies facilitate the efficient operation of the Websites.
• Persistent cookies stay on your browser after you have visited or clicked on the site. For example, when you log onto our Websites or apps, a persistent cookie helps us identify you as a unique visitor and is used to remember your account access information and preferences the next time you log in.
The types of information collected include the following: IP address, internet domain name, browser used, operating system, device information, telephone number of your device, location, time of visit, referring site or application, files visited and time spent in each file, time and date of each visit, and email.
We may use third-party technology, such as Facebook and Instagram, to collect and use data in connection with interest-based advertising. These third-party ad technology companies and advertisers may use, store, or access cookies and other tracking technologies to collect or receive information from the Website and apps and elsewhere on the Internet and use that information to provide advertising services to us, including interest-based advertising or advertisements targeted to your interests.
We may use certain third-party web analytics services, including Google Analytics, DoubleClick and Facebook Custom Audiences, to help us understand and analyze how visitors use our Website and to serve ads on our behalf across the Internet. We and third-party vendors may use first-party cookies or other first-party identifiers as well as third-party cookies or other third-party identifiers to create a profile of you, measure your interests, detect your demographics, detect your location, and personalize content.
Your web browser may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. Like many websites, our Website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, visit http://www.allaboutdnt.com/.
Please note that we or third parties may collect personal information about your online activities over time and across different devices and online properties when you use our Website.
How we use and share information collected using these technologies. We use information collected by cookies and similar technologies to further our legitimate interest in building a business relationship with visitors to the Website and apps to:
• Administer and monitor the use of the Website and apps by measuring the number of visits, average time spent, page views, and other statistical data;
• Store visitor preferences, account information, and deliver more personalized services;
• Enable third party advertisers to collect data for targeted advertising purposes; and
• Analyze the overall customer experience to improve our products, services, and performance of the Website and apps.
How to Restrict Cookies. You can control how cookies and other internet technologies are used to track and log your online activities in several ways:
• Manage the preference settings on your browser and device;
• For more information on how Google Analytics uses data collected through the Website, visit: www.google.com/policies/privacy/partners/. To opt out of Google Analytics cookies, visit: http://www.google.com/settings/ads and https://tools.google.com/dlpage/gaoptout/.
• Purchase a utility from an independent software provider that you install on your computer browsers to make website visits anonymous.
• For Facebook Customer Audience and Twitter advertisements, sign into your Facebook or Twitter account and change your advertising settings or preferences as per Facebook or Twitter’s instructions.
• Visit www.aboutads.info/choices to learn more about personalized advertising and how to opt out of personalized advertising on your web browser and mobile apps by companies participating in the Digital Advertising Alliance.
• Visit www.networkadvertising.org/choices/ to learn more about interest-based ads delivered by the Network Advertising Initiative and how to opt out of such targeted advertising.
Individuals who are residents of California and have provided certain personal information to us may request information regarding our disclosures, if any, of that personal information to third parties for direct marketing purposes. Such requests must be submitted to us as explained in the section “How to Contact Us”.
Such requests must include the reference “Request for California Privacy Information” on the subject line and in the body of the message and must include the email address or mailing address, as applicable, for us to send our response. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted other than to the address specified under “How to Contact Us.”
Kendal Early Learning Center
c/o Kendal at Oberlin
Attention: Compliance Officer
600 Kendal Drive
Oberlin, OH 44074
If you do not receive acknowledgment of your correspondence or the matter is not satisfactorily addressed, you should call 440-775-9815 and request to speak to a representative.
AS A HEALTH CARE ORGANIZATION, KENDAL AT OBERLIN ALSO ABIDES BY THE FOLLOWING PRIVACY PRACTICES (HIPAA):
NOTICE OF PRIVACY INFORMATION PRACTICES
THIS NOTICE DESCRIBES HOW PERSONAL HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
1. Any health care professional authorized to enter information into your medical record created and/or maintained at our organization;
2. Any member of a volunteer group which we allow to help you while receiving services at Kendal at Oberlin; and
3. All employees, staff, and other personnel of our organization.
All of the individuals or entities identified above will follow the terms of this notice. These individuals or entities may share your protected health information with each other for purposes of treatment, payment, or health care operations, as further described in this notice.
We are committed to preserving the privacy and confidentiality of your protected health information created and/or maintained at our organization. Certain state and federal laws and regulations require us to implement policies and procedures to safeguard the privacy of your protected health information.
Individually identifiable information about your past, present, or future physical or mental health or condition, the provision of health care to you, or payment for the health care treatment or services you receive is considered to be protected health information (PHI). As such, we are required to provide you with this Privacy Notice that contains information regarding our privacy practices that explains how, when, and why we may use or disclose your protected health information and your rights and our obligations regarding any such uses or disclosures. Except in specified circumstances, we must use or disclose only the minimum necessary protected health information to accomplish the intended purpose of the use or disclosure of such information.
This notice will provide you with information regarding our privacy practices and applies to all of your protected health information created and/or maintained at our organization, including any information that we receive from other health care providers or facilities. We will abide by the terms of this notice, including any future revisions that we may make to the notice as required or authorized by law.
We reserve the right to change this notice and to make the revised or changed notice effective for protected health information we already have about you as well as any information we receive in the future. We will post a copy of the current notice in our organization. The first page of the notice contains the effective date and any dates of revision. Should you have questions concerning our Privacy Notice, please contact the individual listed on the last page of this document.
We may use or disclose your protected health information in one of following ways:
(1) For purposes of treatment, payment or health care operations
(2) Pursuant to your written authorization (for purposes other than treatment, payment or health care operations)
(3) Pursuant to your verbal agreement (for use in our organization directory or to discuss your health condition with family or friends who are involved in your care);
(4) As permitted by law
(5) As required by law
The following describes each of the different ways that we may use or disclose your protected health information. Where appropriate, we have included examples of the different types of uses or disclosures. While not every use or disclosure is listed, we have included all of the ways in which we may make such uses or disclosures.
1. Uses or disclosures for treatment, payment or health care operations.
We may use or disclose your protected health information for purposes of treatment, payment, or health care operations.
a. Treatment. We may use your protected health information to provide you with health care treatment and services. We may disclose your protected health information to doctors, nurses, nursing assistants, medication aides, technicians, medical and nursing students, rehabilitation therapy specialists, or other personnel who are involved in your health care. For example, your physician may order physical therapy services to improve your strength and walking abilities. Our nursing staff will need to talk with the physical therapist so that we can coordinate services and develop a plan of care. We also may disclose your protected health information to people outside of our organization who may be involved in your health care, such as family members, social services, hospice or home health agencies.
i. Appointment reminders. We may use or disclose your protected health information for purposes of contacting you to remind you of a health care appointment.
ii. Treatment alternatives, health-related benefits and services. We may use or disclose your protected health information for purposes of contacting you to inform you of treatment alternatives or health-related benefits and services that may be of interest to you
iii. Kendal at Oberlin may use information provided by you for the following: resident or member telephone directory, hospitalization notice or posting, memorial posting, information about new residents or members in newsletter articles/bulletin board photographs and notices/internal electronic bulletin board, and in supporting our affiliate organizations in providing care and services.
b. Payment. We may use or disclose your protected health information so that we may bill and collect payment from you, an insurance company, or another third party for the health care services you receive at our organization. For example, we may need to give information to your health plan regarding the services you received from our organization so that your health plan will pay us or reimburse you for the services. We also may tell your health plan about a treatment you are going to receive in order to obtain prior approval for the services or to determine whether your health plan will cover the treatment.
c. Health care operations. We may use or disclose your protected health information to perform certain functions within our organization. These uses or disclosures are necessary to operate our organization and to make sure that our Residents/Clients receive quality care. For example, we may use your protected health information to review our treatment and services and to evaluate the performance of our staff in caring for you. We may use your protected health information in electronic communications (e-mail) internally among staff members who are involved in treatment, payment, or health care operations. We may combine protected health information about many of our Resident/Clients to determine whether certain services are effective or whether additional services should be provided. We may disclose your protected health information to physicians, nurses, nursing assistants, medication aides, rehabilitation therapy specialists, technicians, medical and nursing students, and other personnel for review and learning purposes. We also may combine protected health information with information from other health care providers or facilities to compare how we are doing and see where we can make improvements in the care and services offered to our Resident/Clients. We may remove information that identifies you from this set of protected health information so that others may use the information to study health care and health care delivery without learning the specific identities of our Resident/Clients.
d. Fundraising activities. We may use a limited amount of your protected health information when raising money for our organization and its operations. The information we may use will be limited to permitted demographic information and dates for which you received treatment or services at our facility. If you do not wish to be contacted for participation in fundraising activities, you must provide us with a written notification. The name of the person to contact and the method of contacting him/her are listed in #D7 on the last page of this notice.
2. Uses or disclosures made pursuant to your written authorization.
We may use or disclose your protected health information pursuant to your written authorization for purposes other than treatment, payment or health care operations and for purposes, which are not permitted or required by law. You have the right to revoke a written authorization at any time as long as your revocation is provided to us in writing. If you revoke your written authorization, we will no longer use or disclose your protected health information for the purposes identified in the authorization. You understand that we are unable to retrieve any disclosures, which we may have made pursuant to your authorization prior to its revocation. Examples of uses or disclosures that may require your written authorization include the following:
a. A request to provide certain protected health information to a pharmaceutical company for purposes of marketing
b. A request to provide your protected health information to an attorney for use in a civil litigation claim
3. Uses or disclosures made pursuant to your verbal agreement.
We may use or disclose your protected health information, pursuant to your verbal agreement, for purposes of including you in our organization directory or for purposes of releasing information to persons involved in your care as described below.
a. Organization directory. We may use or disclose certain limited protected health information about you in our organization directory, our daily health center roster, and for internal postings while you are a Resident/Client at our organization. This information may include your name, your assigned unit and room number, your religious affiliation, and a phone number. Your religious affiliation may be given to a member of the clergy. The directory information, except for religious affiliation and phone number, may be given to people who ask for you by name. The health center roster containing name and room number may be posted on internal bulletin boards.
b. Individuals involved in your care. We may disclose your protected health information to individuals, such as family and friends, who are involved in your care or who help pay for your care. This disclosure may be face to face, by phone or by electronic mail. We also may disclose your protected health information to a person or organization assisting in disaster relief efforts for the purpose of notifying your family or friends involved in your care about your condition, status and location.
4. Uses or disclosures required by law
We may use or disclose your information where such uses or disclosures are required by federal, state or local law.
a. Public health activities. We may use or disclose your protected health information to public health authorities that are authorized by law to receive and collect protected health information for the purpose of preventing or controlling disease, injury or disability. We may use or disclose your protected health information for the following purposes:
i. To report births and deaths
ii. To report suspected or actual abuse, neglect, or domestic violence involving a child or an adult
iii. To report adverse reactions to medications or problems with health care products iv. To notify individuals of product recalls
v. To notify an individual who may have been exposed to a disease or may be at risk for spreading or contracting a disease or condition
b. Judicial or administrative proceedings. We may use or disclose your protected health information to courts or administrative agencies charged with the authority to hear and resolve lawsuits or disputes. We may disclose your protected health information pursuant to a court order, a subpoena, a discovery request, or other lawful process issued by a judge or other person involved in the dispute, but only if efforts have been made to (i) notify you of the request for disclosure or (ii) obtain an order protecting your protected health information.
c. Law Enforcement official. We may use or disclose your protected health information in response to a request received from a law enforcement official for the following purposes:
i. In response to a court order, subpoena, warrant, summons or similar lawful process
ii. To identify or locate a suspect, fugitive, material witness, or missing person
iii. Regarding a victim of a crime if, under certain limited circumstances, we are unable to obtain the person’s agreement
iv. To report a death that we believe may be the result of criminal conduct
v. To report criminal conduct at our organization vi. In emergency situations, to report a crime—the location of the crime and possible victims; or the identity, description, or location of the individual who committed the crime
5. Uses or disclosures permitted by law
Certain state and federal laws and regulations either require or permit us to make certain uses or disclosures of your protected health information without your permission. These uses or disclosures are generally made to meet public health reporting obligations or to ensure the health and safety of the public at large. The uses or disclosures, which we may make pursuant to these laws and regulations include the following:
a. Health oversight activities. We may use or disclose your protected health information to a health oversight agency that is authorized by law to conduct health oversight activities. These oversight activities may include audits, investigations, inspections, or licensure and certification surveys. These activities are necessary for the government to monitor the persons or organizations that provide health care to individuals and to ensure compliance with applicable state and federal laws and regulations.
b. Worker’s compensation. We may use or disclose your protected health information to worker’s compensation programs when your health condition arises out of a work-related illness or injury. c. Coroners, medical examiners, or funeral directors. We may use or disclose your protected health information to a coroner or medical examiner for the purpose of identifying a deceased individual or to determine the cause of death. We also may use or disclose your protected health information to a funeral director for the purpose of carrying out his/her necessary activities.
d. Organ procurement organizations or tissue banks. If you are an organ donor, we may use or disclose your protected health information to organizations that handle organ procurement, transplantation, or tissue banking for the purpose of facilitating organ or tissue donation or transplantation.
e. Research. We may use or disclose your protected health information for research purposes under certain limited circumstances. Because all research projects are subject to a special approval process, we will not use or disclose your protected health information for research purposes until the particular research project for which your protected health information may be used or disclosed has been approved through this special approval process. However, we may use or disclose your protected health information to individuals preparing to conduct the research project in order to assist them in identifying Resident/Clients with specific health care needs who may qualify to participate in the research project. Any use or disclosure of your protected health information which may be done for the purpose of identifying qualified participants will be conducted onsite at our organization. In most instances, we will ask for your specific permission to use or disclose your protected health information if the researcher will have access to your name, address or other identifying information.
f. To avert a serious threat to health or safety. We may use or disclose your protected health information when necessary to prevent a serious threat to the health or safety of you or other individuals. Any such use or disclosure would be made solely to the individual(s) or organization(s) that have the ability and/or authority to assist in preventing the threat.
g. Military and veterans. If you are a member of the armed forces, we may use or disclose your protected health information as required by military command authorities.
h. National security and intelligence activities. We may use or disclose your protected health information to authorized federal officials for purposes of intelligence, counterintelligence, and other national security activities, as authorized by law.
You have the following rights regarding your protected health information, which we create and/or maintain:
1. Right to inspect and copy. You have the right to inspect and copy protected health information that may be used to make decisions about your care. Generally, this includes medical and billing records, but does not include psychotherapy notes.
To inspect and copy your protected health information, you must submit your request in writing to Corporate Compliance Officer, Kendal at Oberlin, 600 Kendal Drive, Oberlin, OH 44074. If you request a copy of the information, we may charge a fee for the costs of copying, mailing, or other supplies associated with your request.
We may deny your request to inspect and copy your protected health information in certain limited circumstances. If you are denied access to your protected health information, you may request that the denial be reviewed. Another licensed health care professional selected by our organization will review your request and the denial. The person conducting the review will not be the person who initially denied your request. We will comply with the outcome of this review.
2. Right to request an amendment. If you feel that the protected health information, we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept by or for our organization.
To request an amendment, your request must be made in writing and submitted to Corporate Compliance Officer, Kendal at Oberlin, 600 Kendal Drive, Oberlin, OH 44074. In addition, you must provide us with a reason that supports your request.
We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to amend information that
a. was not created by us, unless the person or entity that created the information is no longer available to make the amendment
b. is not part of the protected health information kept by or for our organization
c. is not part of the information which you would be permitted to inspect and copy
d. is accurate and complete
3. Right to an accounting of disclosures. You have the right to request an accounting of the disclosures, which we have made of your protected health information. This accounting will not include disclosures of protected health information that we made for purposes of treatment, payment, or health care operations.
To request an accounting of disclosures, you must submit your request in writing to Corporate Compliance Officer, Kendal at Oberlin, 600 Kendal Drive, Oberlin, OH 44074. Your request must state a time period, which may not be longer than six (6) years prior to the date of your request and may not include dates before April 14, 2003. Your request should indicate in what form you want to receive the accounting (for example, on paper or via electronic means). The first accounting that you request within a twelve (12)-month period will be free. For additional accountings, we may charge you for the costs of providing the accounting. We will notify you of the cost involved, and you may choose to withdraw or modify your request at that time before any costs are incurred.
4. Right to request restrictions. You have the right to request a restriction or limitation on the protected health information we use or disclose about you for treatment, payment, or health care operations. You also have the right to request a limit on the protected health information we disclose about you to someone, such as a family member or friend, who is involved in your care or in the payment of your care. For example, you could ask that we not use or disclose information regarding a particular treatment that you received.
We are not required to agree to your request. If we do agree, we will comply with your request not to release such information unless the information is needed to provide emergency care or treatment to you.
To request restrictions, you must make your request in writing to Corporate Compliance Officer, Kendal at Oberlin, 600 Kendal Drive, Oberlin, OH 44074. In your request, you must tell us (a) what information you want to limit; (b) whether you want to limit our use, disclosure or both; and (c) to whom you want the limits to apply (for example, disclosures to a family member).
5. Right to request confidential communications. You have the right to request that we communicate with you about your health care in a certain way or at a certain location. For example, you can ask that we only contact you by mail.
To request confidential communications, you must make your request in writing to Corporate Compliance Officer, Kendal at Oberlin, 600 Kendal Drive, Oberlin, OH 44074. We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.
6. Right to a paper copy of this notice. You have the right to receive a paper copy of this notice. You may ask us to give you a copy of this Notice at any time. Even if you have agreed to receive this notice electronically, you are still entitled to a paper copy of this notice.
You may obtain a copy of this notice at our Web site www.kao.kendal.org To obtain a paper copy of this notice, contact Corporate Compliance Officer, Kendal at Oberlin, 600 Kendal Drive, Oberlin, OH 44074.
7. Right to Opt Out of Fundraising Activities. You have the right to opt out of receiving fundraising requests from us. Please send your written request to: Chief Executive Officer, Kendal at Oberlin, 600 Kendal Drive, Oberlin, OH 44074.
If you believe your privacy rights have been violated, you may file a complaint with our organization by using our confidential hotline service, the Friends Compliance and Privacy Line at 1-800-211-2713 or with the secretary of the Department of Health and Human Services (200 Independence Avenue, SW, Washington, DC 20201, (202) 619-0257, or toll-free 1-877-696- 6775).
To file a complaint with our organization or to ask questions regarding this notice, contact:
Corporate Compliance Officer
Kendal at Oberlin
600 Kendal Drive
Oberlin, Ohio 44074
All complaints must be submitted in writing. You will NOT be penalized for filing a complaint.