ReturnToDutyNow.com: Part 2 Patient Privacy Notice

Your Information. Your Rights. Our Responsibilities.

This notice describes:

• How health information about you may be used and disclosed
• Your rights with respect to your health information
• How to file a complaint concerning a violation of your privacy rights

You have a right to a copy of this notice and to discuss it with our Privacy Official. Privacy Official: Vernay Justice-Royster

Phone: 619-788-7327 | Email: Vernay.ReturnToDuty@gmail.com

In this notice, “health information” specifically refers to your substance use disorder (SUD) patient record created during your SAP evaluation or return-to-duty process.

Your Rights

You have the right to:

• Provide or withhold consent for most uses and disclosures of your SUD records.
• Request restrictions on the information we share.
• Obtain a copy of this privacy notice at any time.
• Get a list (accounting) of those with whom we’ve shared your electronic records.
• Choose someone to act for you (such as a legal guardian or medical power of attorney).
• File a complaint if you believe your privacy rights have been violated.

Your Choices (Requires Your Written Consent)

Because of the strict nature of 42 CFR Part 2, we typically only use or share your information with your explicit written consent to:

• Coordinate your care: Sharing information with other professionals involved in your treatment or recovery.
• Report to your employer/DER: Providing the necessary “Fitness-for-Duty” or SAP reports required for your return-to-duty process.
• Bill for services: Submitting information to health plans or entities for payment.
• Comply with court-referred treatment: Reporting your progress to the relevant legal authorities.

Our Uses and Disclosures (Without Your Consent)

Federal law permits us to share your information without your consent only in limited circumstances:

• Internal Operations: Communications within our program or with contractors who help us manage the business.
• Medical Emergencies: Sharing necessary info with medical personnel during a life-threatening emergency.
• Public Health: Reporting specific data that does not identify you (de-identified data).
• Crimes on Premises: Reporting a crime or a threat of a crime committed against our staff or on our premises.
• Child Abuse & Neglect: Reporting suspected cases as mandated by state and federal law.
• Court Orders: Responding to a specific Part 2-compliant court order and subpoena.

Legal Proceedings & Special Protections

Your SUD records have extra legal protections:

1. We will not use or share your information in any civil, administrative, criminal, or legislative proceedings against you without your specific written consent or a Part 2 court order.
2. A standard subpoena is not enough to release these records; it must be accompanied by a specific court order that protects your identity.
3. If your information is shared with a HIPAA-covered entity for treatment or payment, they may redisclose it as permitted by HIPAA, but the information still cannot be used against you in legal proceedings without your consent or a court order.

Our Responsibilities

• We are required by law to maintain the privacy and security of your protected health information.
• We must notify you promptly if a breach occurs that may have compromised the privacy or security of your information.
• We will not use or share your information other than as described in this notice unless you tell us we can in writing. You may change your mind and revoke your consent at any time by notifying us in writing.

Effective Date & Changes

Effective Date: March 23, 2026

Address: San Diego, California

Changes to this Notice: We can change the terms of this notice, and the changes will apply to all information we have about you. The newest version will always be available on our website at www.returntodutynow.com.

How to File a Complaint

If you feel your rights have been violated, you can contact Vernay Justice-Royster at the phone or email listed above.

You can also file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights:

200 Independence Avenue, S.W., Washington, D.C. 20201

1-877-696-6775 | www.hhs.gov/hipaa/filing-a-complaint/index.html

Additional Notes for ReturnToDutyNow.com

• State Law: In California, SUD records are subject to additional protections under the Confidentiality of Medical Information Act (CMIA). We adhere to whichever law (State or Federal) provides the highest level of privacy for your records.
• Fundraising & Marketing: We do not sell your information or use it for fundraising or marketing purposes.