TSCN Privacy Policy
TSCN direct line for urgent administrative matters, not medical emergencies (call 911)
Held by Tea Wask: (201) 819-0484 | support@tscn.care
1 Scope
This Privacy Policy explains how TSCN, LLC (TSCN, we, us, or our) collects, uses, discloses, protects, and retains information through https://tscn.care, telephone calls, text messages, email, online forms, Jessie, and related network and care-coordination activities.
TSCN provides free network and care-coordination functions and separately paid TSCN/Jessie services. TSCN is not itself the treating medical practice. Participating practices remain independent and bill for their own medical services. Separately purchased TSCN/Jessie services may be billed by TSCN.
This policy applies to TSCN’s website and coordination activities. If another participating practice becomes the selected treating practice, that practice’s own Notice of Privacy Practices governs its medical records and care.
2 Information We Collect
We collect information reasonably necessary to respond to inquiries, support coordination, operate our services, protect our systems, provide separately purchased TSCN/Jessie services, and meet legal obligations. The information may include:
- Contact and identity information, including name, telephone number, email address, mailing address, location, preferred language, and communication preferences.
- Patient, guardian, and representative information, including parent or legally authorized guardian details for patients under 18 and documentation of authority when needed.
- Health and coordination information, including symptoms, medical history reported to us, current concerns, medications, prior treatment, imaging or record information, appointment needs, and provider preferences.
- Insurance and claim-related information, including insurer, coverage, claim type, Workers Compensation, No Fault, accident, employment, and related legal case information.
- Referral and scheduling information received from or provided to participating practices and other authorized care participants.
- Communications information, including call recordings where applicable, transcripts, summaries, messages, email content, text messages, dates, times, and related metadata.
- Online form information submitted for patient pre-registration, appointment requests, current medical-status triage, care-coordination requests, and support requests.
- Website and device information, including IP address, browser and device characteristics, pages viewed, referring source, cookie identifiers, consent choices, and call attribution information.
- Billing and transaction information for separately purchased TSCN/Jessie services, such as service selection, payment status, receipts, and related support communications.
3 Sources of Information
We may receive information directly from a patient or the patient’s authorized representative; from a parent or legally authorized guardian; from a participating practice; from a treating provider; or, when authorized or otherwise permitted by law, from an attorney, insurer, employer, claims administrator, imaging facility, or other care participant.
We also collect information through online forms, Jessie calls, support communications, website security tools, cookies, call attribution technologies, and allow-listed analytics on eligible general informational pages as described in this policy and in the Cookie and Tracking Technologies Policy.
4 How We Use Information
TSCN may use information to:
- Understand and respond to a patient, parent, guardian, representative, or practice request.
- Provide free network and care-coordination functions.
- Identify participating independent practices that may fit a patient’s needs, location, insurance, and preferences.
- Facilitate appointments, referrals, follow-up, and communications with selected practices.
- Coordinate information and transitions among participating providers and authorized care participants.
- Assist with authorized insurance, accident, claim-related, and case-coordination tasks.
- Provide and support separately purchased TSCN/Jessie services, including billing and account-related communications for those services.
- Maintain coordination records, document follow-up, manage consent and authorization records, and respond to privacy requests.
- Provide care-related calls, text messages, emails, and other requested communications.
- Operate, secure, test, audit, troubleshoot, and improve our systems and coordination processes.
- Measure website performance and inquiry sources only where analytics and attribution are permitted under this policy.
- Protect patients, personnel, systems, and services; investigate misuse; enforce applicable terms; and comply with law.
5 TSCN and Independent Practices
TSCN is a network and care-coordination organization. TSCN is not the treating medical practice. Participating practices are independent and remain responsible for their own clinical services, medical records, professional judgment, privacy notices, patient relationships, and billing for their own medical services.
During initial intake or triage before another participating practice is selected, TSCN acts on behalf of Apteum, LLC as Apteum’s Business Associate. If another practice becomes the selected treating practice, that practice’s own Notice of Privacy Practices governs its medical records and care, and TSCN performs coordination for that practice under the applicable arrangement.
When TSCN receives a request involving a formal medical record maintained by a participating practice, TSCN forwards or directs the request to the practice that maintains the record. The practice evaluates and responds under its own Notice of Privacy Practices and applicable law.
6 HIPAA and Business-Associate Role
TSCN acts as a HIPAA Business Associate to participating covered practices under Business Associate Agreements. TSCN may use or disclose protected health information only as permitted by the applicable Business Associate Agreement, HIPAA, other applicable law, and this policy.
TSCN does not sell medical information. TSCN does not disclose protected health information for another party’s marketing without authorization when authorization is required by law.
7 Jessie and AI-Assisted Calls
Jessie is TSCN’s AI-assisted telephone and coordination service. Jessie may receive questions, collect information, route requests, summarize communications, support appointment-related follow-up, and support separately purchased TSCN/Jessie services. Jessie is not a substitute for a participating practice’s clinical judgment.
Jessie calls may be recorded and transcribed after spoken notice. Retell processes Jessie call recordings and transcripts and retains them for 30 days. Retell may transfer contact details and call summaries to Ninox. A summary may include symptoms and medical history reported to us, insurance or claim information, appointment and provider preferences, and accident or legal case details.
A person who declines recording may contact support@tscn.care or Tea Wask at (201) 819-0484 to request another available communication method.
8 Disclosures of Information
We may disclose information only as reasonably necessary for the purposes described in this policy, as authorized by the individual or representative, or as permitted or required by law. Recipients may include:
- Participating independent practices and care coordinators involved in the requested coordination.
- Apteum, LLC during initial intake or triage before another participating practice is selected.
- Imaging facilities, laboratories, referral recipients, and other care participants involved in an authorized coordination pathway.
- Service providers that support telephone, AI, database, email, texting, cloud hosting, backup, security, analytics, consent management, payment, and call attribution functions.
- Attorneys, insurers, employers, claims administrators, or other third parties when authorized by the patient or representative or when disclosure is otherwise permitted or required by law.
- Government, regulatory, judicial, or law enforcement authorities when disclosure is legally required or permitted.
- Professional advisers and parties involved in protecting TSCN’s legal rights, safety, systems, or operations, subject to applicable confidentiality requirements.
9 Vendors and Service Providers
TSCN may use Google Workspace, AWS, SendGrid, Retell, Ninox, Twilio, Google Tag Manager, Google Analytics, subject to applicable Business Associate Agreements and confidentiality obligations where protected health information is handled.
Google Tag Manager manages allow-listed tags. Google Analytics and other nonessential analytics must be blocked from patient-intake and healthcare-interaction pages. Microsoft Clarity is not used.
Service providers may change as TSCN’s operations evolve. TSCN evaluates privacy, security, and contractual requirements before allowing a provider to handle protected health information.
10 Cookies, Analytics, and Tracking
The website may use essential technologies needed for security, operation, accessibility, consent management, and user-requested functions. Nonessential analytics and tracking operate only as permitted by the site’s consent and allow-list controls.
Google Analytics and other nonessential analytics must be blocked from patient-intake and healthcare-interaction pages, including pre-registration, appointment-request, triage, care-coordination, patient-message, and similar workflows. Analytics may operate only on eligible general informational pages under the site’s consent and allow-list controls. Consent to analytics on an eligible general informational page does not authorize analytics on a patient-intake or healthcare-interaction page.
On eligible general informational pages, allow-listed analytics technologies may collect device, browser, interaction, referral, and approximate location information. TSCN uses this information to understand website performance and inquiry sources. Analytics tools must not receive patient-entered information, protected health information, form-field values, or identifiers from patient-intake or healthcare-interaction pages.
A visitor may use the website’s cookie-preference control to review or change available choices. Browser settings may also limit cookies, although some site functions may not work as intended.
11 Communications and Marketing
After a person contacts TSCN, we may use the contact information provided to make care-related telephone calls and send care-related text messages or emails. Message and data rates may apply. A person may request a different communication method or opt out of nonessential text or email communications by replying STOP where supported or by contacting support@tscn.care.
Marketing communications require consent where required by law. Declining or withdrawing marketing consent does not affect eligibility for free network or care-coordination functions. TSCN will honor legally valid opt-out requests.
Before submitting online pre-registration, appointment-request, triage, or care-coordination information, the patient or authorized representative may be provided links to applicable policies and notices. Submitted information may be sent to a participating practice selected for the requested coordination.
12 Minors
TSCN intake and coordination for patients under 18 occurs only through a parent or legally authorized guardian. The parent or guardian must submit information, make coordination requests, provide applicable authorizations, and receive communications on the minor’s behalf.
TSCN does not knowingly collect personal information directly from a minor through the website, Jessie, text message, or email. If a minor contacts TSCN directly, TSCN will request the involvement of a parent or legally authorized guardian before continuing, except when applicable law requires a different response. The selected treating practice is responsible for determining consent, confidentiality, and parental-access rules governing medical care and records.
13 Retention
TSCN applies the following retention periods to its principal coordination records:
- Retell call recordings and transcripts: 30 days.
- Ninox coordination data: for the coordination period plus one year.
- Formal medical records: retained by the selected treating practice under that practice’s policies and legal obligations.
Other operational, security, consent, authorization, billing, transaction, and support records are retained only for as long as reasonably necessary for the purpose collected, contractual requirements, dispute resolution, security, or applicable law. Deleted information may remain in protected backups until the applicable backup cycle expires.
14 Security
TSCN uses administrative, technical, and physical safeguards designed to protect information, including role-based access controls, encryption in transit and at rest where appropriate, audit or access logging, and multifactor authentication. Access is limited to persons and service providers that need information for an authorized function.
No system can guarantee absolute security. If TSCN discovers an incident involving information, it will investigate and provide notifications when required by HIPAA or other applicable law.
15 Privacy Rights and Requests
Depending on the information, TSCN’s role, and applicable law, an individual or authorized representative may have the right to:
- Request access to or a copy of protected health information.
- Request correction or amendment of information.
- Request restrictions on certain uses or disclosures.
- Request confidential communications through a reasonable alternative method or location.
- Request an accounting of certain disclosures.
- Withdraw an authorization for future uses or disclosures, subject to actions already taken in reliance on it.
- Receive a paper or electronic copy of an applicable privacy notice.
- Submit a complaint without retaliation.
- Exercise additional access, correction, deletion, appeal, or tracking-choice rights when provided by applicable state or federal law.
Requests concerning a formal medical record maintained by a participating practice will be forwarded or directed to that practice. TSCN uses reasonable identity verification and may request documentation when necessary to verify identity or authority. TSCN responds to privacy requests within 30 days when reasonably practicable, subject to applicable legal deadlines and any permitted extension.
16 Changes to This Policy
TSCN may revise this Privacy Policy when its practices, services, technology, legal obligations, vendor relationships, or participating-practice arrangements change. The current version will be posted on https://tscn.care with its effective date. Material changes will apply prospectively unless law permits or requires another approach.
17 Contact
Questions, privacy-rights requests, requests for the current list of participating practices, and complaints may be directed to:
Tea Wask
Privacy Contact for TSCN, LLC
support@tscn.care
(201) 819-0484
411 Route 17S, Suite 110
Hasbrouck Heights, NJ 07604
TSCN will not retaliate against a person for making a good-faith privacy complaint or exercising a privacy right. A person may also submit a HIPAA complaint to the U.S. Department of Health and Human Services Office for Civil Rights when applicable.