Consumer Health Data Policy | Pro ESA Letter - Protecting Your Health Information

Consumer Health Data Policy

Our comprehensive policy outlining how we collect, use, and protect your consumer health data in compliance with state privacy laws and our unwavering commitment to your privacy rights.

Effective Date: January 1, 2024 | Last Updated: January 1, 2024

Pro ESA Letter Consumer Health Data Policy

This Consumer Health Data Policy supplements our Privacy Policy and HIPAA Notice of Privacy Practices. It specifically addresses how we handle consumer health data as defined under state privacy laws including Washington's My Health My Data Act, California's Confidentiality of Medical Information Act, and other applicable state consumer health data privacy laws.

Legal Compliance Notice

Pro ESA Letter is committed to complying with all applicable state and federal laws regarding consumer health data privacy. This policy outlines our practices concerning the collection, use, and disclosure of consumer health data and informs you of your rights regarding such data.

Scope and Definitions

What is Consumer Health Data?

Consumer Health Data refers to personal information that is linked or reasonably linkable to a consumer and that identifies the consumer's past, present, or future health status. This includes but is not limited to:

Health Conditions

Information about physical or mental health conditions, disorders, diseases, or diagnoses

Treatments & Medications

Information about treatments, medications, medical devices, or other health interventions

Health Measurements

Data derived from health measurements, tests, examinations, or health assessments

Healthcare Services

Information related to seeking, obtaining, or receiving healthcare services

What This Policy Covers

This Consumer Health Data Policy applies to all consumer health data we collect, use, or disclose in connection with our emotional support animal evaluation services. This includes data collected through:

  • Our telehealth platform and evaluation forms
  • Communications with our licensed mental health professionals
  • Customer support interactions
  • Website usage and analytics (where health-related)
  • Marketing communications (where health-related)
How We Collect Consumer Health Data

Our Data Collection Flow

1

Direct Collection

We collect consumer health data directly from you when you voluntarily provide it during the ESA evaluation process. This includes information you provide in evaluation forms, during telehealth consultations, and in communications with our mental health professionals.

2

Automated Collection

We automatically collect certain technical information when you use our website and services. This may include IP addresses, device information, browser type, and usage patterns. We only collect health-related data through automated means when you explicitly provide consent.

3

Third-Party Sources

In limited circumstances, we may receive consumer health data from third parties, such as when you authorize another healthcare provider to share information with us. We only accept data from third parties with your explicit consent and in compliance with applicable laws.

Types of Consumer Health Data We Collect

Specifically, we may collect the following categories of consumer health data:

Mental Health Information
Information about mental health conditions, symptoms, treatments, and assessment results related to emotional support animal eligibility evaluations.
Treatment Information
Details about current and past mental health treatments, therapies, medications, and healthcare providers.
Assessment Data
Results from mental health assessments, screening tools, and evaluation instruments used during the ESA qualification process.
Health-Related Communications
Communications between you and our mental health professionals regarding your mental health status and treatment needs.
How We Use Consumer Health Data

We use consumer health data solely for purposes that are consistent with our services and as permitted by law. Our primary uses include:

Service Provision

To provide you with emotional support animal evaluation services, including conducting assessments, determining eligibility, and issuing ESA letters when appropriate.

Treatment Coordination

To facilitate communication between you and our licensed mental health professionals and to coordinate your care when appropriate.

Service Improvement

To analyze and improve our services, develop new features, and enhance the quality of care we provide to all clients.

Legal Compliance

To comply with legal obligations, respond to legal requests, protect our rights and property, and ensure the security of our services.

Important Limitations

We do not use consumer health data for advertising purposes. We do not sell consumer health data to third parties. We do not use consumer health data to make decisions about employment, credit, insurance, or housing.

How We Disclose Consumer Health Data

Disclosure to Service Providers

We may disclose consumer health data to third-party service providers who assist us in delivering our services. These providers are contractually bound to protect your data and may only use it for the specific purposes we authorize. Examples include:

  • Licensed mental health professionals conducting evaluations
  • Technical service providers maintaining our platform
  • Payment processors handling transactions
  • Customer support service providers

Legal and Required Disclosures

We may disclose consumer health data when required by law or in response to legal processes, including:

  • Court orders, subpoenas, or other legal requirements
  • Law enforcement requests (with appropriate legal process)
  • Government agency requests for oversight or compliance
  • To prevent imminent harm to individuals or the public

Disclosure with Your Authorization

We will only disclose your consumer health data to third parties for purposes not covered by this policy with your explicit, written authorization. You may revoke any authorization at any time by contacting us.

Authorization Requirements

Any authorization for disclosure of consumer health data must be in writing, specify the recipient, describe the information to be disclosed, state the purpose of the disclosure, and include an expiration date or event. You have the right to revoke any authorization at any time.

Your Rights Regarding Consumer Health Data

Depending on your state of residence and applicable laws, you may have certain rights regarding your consumer health data. These rights may include:

Right to Access

The right to confirm whether we are processing your consumer health data and to access such data.

Right to Delete

The right to request deletion of your consumer health data, subject to certain exceptions.

Right to Withdraw Consent

The right to withdraw consent for the collection and sharing of your consumer health data.

Right to Data Portability

The right to obtain a copy of your consumer health data in a portable, readily usable format.

How to Exercise Your Rights

To exercise any of these rights, please submit a verifiable consumer request to us by:

  1. Contacting us using the contact information provided in this policy
  2. Submitting a request through our designated online portal (if available)
  3. Calling our toll-free number for privacy requests

Verification Process

We will need to verify your identity before processing most requests. We may ask you to provide additional information to verify your identity. We will respond to verifiable consumer requests within the timeframes required by applicable law.

Data Security and Protection

Our Security Measures

We implement and maintain reasonable security measures to protect your consumer health data from unauthorized access, acquisition, destruction, use, modification, or disclosure. Our security program includes:

Technical Safeguards

Encryption of data in transit and at rest, secure access controls, regular security updates, and network security measures.

Administrative Safeguards

Employee training, security policies and procedures, risk assessments, and incident response plans.

Physical Safeguards

Secure data center facilities, access controls to physical locations, and proper disposal of physical records.

Monitoring & Auditing

Regular security monitoring, vulnerability assessments, penetration testing, and security audits.

Data Retention

We retain consumer health data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Our specific retention periods are:

  • Active client records: Retained for 7 years from last service date
  • Completed ESA evaluations: Retained for 7 years from evaluation date
  • Financial records: Retained for 7 years from transaction date
  • Legal compliance records: Retained as required by applicable laws

Breach Notification

In the event of a security breach involving your consumer health data, we will notify you as required by applicable law. Our breach notification process includes:

  • Prompt investigation of any suspected breach
  • Notification to affected individuals without unreasonable delay
  • Reporting to appropriate regulatory authorities as required
  • Implementation of remedial measures to prevent future breaches

Your Privacy Matters to Us

We are committed to protecting your consumer health data and respecting your privacy rights. If you have questions about this policy or wish to exercise your rights, we're here to help.

Contact Information

For questions about this Consumer Health Data Policy or to exercise your privacy rights, please contact our Privacy Team:

Privacy Officer

Consumer Health Data Privacy Team

Pro ESA Letter

Privacy Hotline

+1 (888) 555-1234

Monday-Friday, 9:00 AM - 6:00 PM EST

For privacy requests only

Email Address

privacy@proesaletter.com consumerhealth@proesaletter.com

For consumer health data inquiries

Mailing Address

Pro ESA Letter
Attn: Consumer Health Data Privacy
1234 Privacy Way, Suite 500
Los Angeles, CA 90012

We typically respond to privacy requests within 45 days as required by law. Complex requests may require an additional 45-day extension, in which case we will notify you.

Scroll to Top