TSCN Website and Care Coordination Privacy Policy
Purpose and scope. This Privacy Policy explains how TSCN, LLC (TSCN, we, us, or our) collects, uses, discloses, protects, and retains information obtained through TSCN.care, telephone calls, care-coordination activities, and related communications. TSCN provides care-coordination services. TSCN does not itself diagnose, treat, prescribe, or bill patients for healthcare.
TSCN performs care-coordination and related administrative services for participating independent medical practices. TSCN acts as a business associate of each member practice under a separate Business Associate Agreement. Each practice remains independently responsible for the healthcare it provides, its medical records, and its HIPAA Notice of Privacy Practices. This policy supplements, but does not replace, the notice issued by a treating practice. A current list of participating member practices is available upon request.
1 Information We Collect
We collect only information reasonably necessary to respond to inquiries, coordinate care, operate our services, protect our systems, and meet legal obligations. The information may include:
- Contact and identity information, including name, telephone number, email address, location, preferred language, and communication preferences.
- Health and coordination information, including symptoms, medical history, diagnoses reported to us, medications, prior treatment, imaging or record information, appointment needs, and provider preferences.
- Insurance and claim information, including insurer, coverage, claim type, Workers Compensation, No Fault, accident, employment, and related legal case information.
- Referral information received from or provided to participating practices and other authorized persons or organizations.
- Communications information, including telephone recordings, transcripts, summaries, messages, email content, text messages, and related dates and metadata.
- Online form information submitted for patient pre-registration, appointment requests, and current medical-status triage.
- Website and device information, including IP address, browser and device characteristics, pages viewed, referring source, cookie identifiers, and call attribution information.
2 How We Obtain Information
We may receive information directly from a patient or the patient's authorized representative; from a parent or legal guardian; from a participating member 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 patient pre-registration, appointment-request, and medical-status triage forms; through Jessie, TSCN's AI-assisted telephone receptionist; and automatically through website analytics, security tools, cookies, and call-attribution technologies as described below. Online form submissions are processed through Retell AI and stored in Ninox.
3 How We Use Information
TSCN may use information to:
- Understand and respond to a patient or representative's request.
- Identify participating independent practices that may fit a patient's needs, location, insurance, and preferences.
- Facilitate appointments and communications with selected practices.
- Coordinate information and transitions among participating providers.
- Assist with authorized insurance, accident, and claim-related coordination.
- Maintain coordination records and document follow-up.
- Provide care-related calls, text messages, and email communications.
- Measure website performance and the source of telephone inquiries.
- Protect patients, personnel, systems, and services; investigate misuse; and comply with law.
- Improve TSCN's coordination processes and service quality using appropriately protected information.
4 TSCN and Independent Member Practices
TSCN is a care-coordination organization and is not the treating healthcare provider. Participating practices are independent. The selected practice is responsible for diagnosis, treatment, prescriptions, billing, clinical decision-making, and maintenance of its medical record.
When a person begins an initial patient inquiry or intake through TSCN before another member practice has been selected, TSCN receives and processes that information on behalf of Apteum, LLC, as Apteum, LLC's business associate. Apteum, LLC is the covered practice represented during that initial-intake stage. If another member practice is selected for the requested care, TSCN continues coordination on behalf of that practice under its separate Business Associate Agreement.
When TSCN receives a request to access, amend, or obtain a formal medical record, TSCN forwards that request to the practice that maintains the record. The practice evaluates and responds to the request under its own Notice of Privacy Practices and applicable law.
TSCN provides services to each participating practice under a separate Business Associate Agreement. TSCN may use or disclose protected health information only as permitted by the applicable agreement, HIPAA, and other law. A current member-practice list may be requested from the Privacy Contact.
5 Jessie Telephone Recording and Artificial Intelligence
Jessie is TSCN's AI-assisted receptionist. Jessie may receive questions, collect information, route requests, and support appointment-related follow-up. Jessie does not independently diagnose a condition, prescribe treatment, select a medical treatment, or replace the judgment of a licensed healthcare professional.
TSCN records and transcribes calls handled by Jessie. A spoken notice is provided before recording begins. Retell processes and stores the call recording and transcript for 30 days. Retell then deletes them in accordance with TSCN's configured retention period and applicable contractual requirements.
Retell transfers contact details and a call summary to Ninox. The summary may include symptoms and medical history, insurance or claim information, appointment and provider preferences, and accident or legal case details. Retell is contractually prohibited from using TSCN call information to train its general artificial intelligence models.
A caller who does not wish to be recorded may end the Jessie call and use TSCN's direct, unrecorded line at +1 (201) 272-6793. The caller may also contact Tea@tscn.care to request another available method of communication.
6 How We Disclose 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 member practices and care coordinators involved in the requested coordination.
- Imaging facilities, laboratories, and other care participants involved in an authorized coordination pathway.
- Service providers that support telephone, AI, database, email, texting, cloud hosting, backup, security, analytics, and call attribution functions.
- 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.
TSCN discloses patient information to attorneys, insurers, employers, or claims administrators only with the patient's written authorization, except when a different disclosure is required by law.
TSCN does not sell medical information. We do not disclose protected health information for another party's marketing without the authorization required by law.
7 Service Providers
TSCN uses service providers that may process information on our behalf. These currently include Retell, Ninox, Google Workspace, Amazon Web Services, SendGrid, Twilio, Google Tag Manager, Google Analytics, and CallRail. Applicable vendors that handle protected health information are subject to HIPAA Business Associate Agreements and other confidentiality and security obligations.
CallRail is used for call attribution and campaign measurement and is configured not to record or transcribe calls. Google Tag Manager manages an allow list of approved tags. Google Analytics may operate only on general informational pages that do not collect, display, transmit, or support the entry of patient or health information.
Service providers may change as TSCN's operations evolve. TSCN evaluates the privacy, security, and contractual requirements applicable to a provider before allowing it to handle protected health information.
8 Cookies, Analytics, and Tracking
The website may use essential technologies needed for security, operation, accessibility, and user-requested functions. Nonessential tracking is rejected by default. Consent to analytics on an eligible 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 after the applicable tracking choice. TSCN uses this information to understand website performance and inquiry sources. Google Analytics is completely blocked from every patient-intake or healthcare-interaction page, including pre-registration, appointment-request, triage, care-coordination, patient-message, and similar workflows. Blocking occurs before such a page loads or begins processing information; it does not depend on whether a visitor has started typing. Google Analytics must not receive patient-entered information, health information, page content, form-field values, or identifiers from those 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.
TSCN retains analytics and attribution information only as long as reasonably necessary for the operational purpose for which it was collected, subject to applicable law and configured provider settings. TSCN periodically reviews the retention settings used for Google services and CallRail.
9 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 emailing Tea@tscn.care.
Marketing communications require separate consent. Declining or withdrawing marketing consent does not affect eligibility for care coordination. TSCN will honor legally valid opt-out requests.
Before submitting online pre-registration, appointment-request, or triage information, the patient or authorized representative is provided a link to this Privacy Policy and consents to care-coordination processing. That consent includes sending the submitted information to a participating member practice selected for the requested coordination.
10 Information About Minors
TSCN does not communicate or coordinate directly with minors. For a patient under 18, TSCN works exclusively with the patient's 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 treating practice is responsible for determining consent, confidentiality, and parental-access rules governing medical care and records.
11 Retention and Deletion
TSCN applies the following retention periods to its principal coordination records:
- Retell call recordings and full transcripts: 30 days.
- Online pre-registration, appointment-request, and triage information processed by Retell: 30 days.
- Ninox contact details and call summaries: for the duration of care coordination and for one year after coordination ends.
- Online pre-registration, appointment-request, and triage information stored in Ninox: for the duration of care coordination and for one year after coordination ends.
- Formal medical records: retained by the treating member practice under that practice's policies and legal obligations.
Other operational, security, consent, authorization, and transaction 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 AWS or other backups for up to 90 days before the applicable backup cycle expires.
12 Security
TSCN uses administrative, technical, and physical safeguards designed to protect information. These include role-based access controls, encryption in transit and at rest, 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.
13 Privacy Rights
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 will be forwarded to the practice that maintains that record. TSCN uses reasonable methods to verify identity and authority and may request government-issued identification or other appropriate documentation when necessary. TSCN aims to respond to privacy requests and complaints within 30 calendar days, subject to applicable legal deadlines and any permitted extension.
14 Authorized Representatives
A person acting for a patient may be required to provide documentation showing authority to act, such as parental or guardianship authority, a healthcare proxy, power of attorney, or written authorization. TSCN may decline a request when it cannot reasonably verify the person's identity or authority, subject to applicable law.
15 Complaints and Questions
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
Tea@tscn.care
+1 (201) 272-6793
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.
16 Changes to This Policy
TSCN may revise this Privacy Policy when its practices, services, technology, legal obligations, or participating arrangements change. The current version will be posted on TSCN.care with its effective date and version number. Material changes will apply prospectively unless law permits or requires another approach.
17 Relationship to Other Notices
This policy describes TSCN's website and coordination practices. A member practice's Notice of Privacy Practices governs the practice's clinical services and medical record. If this policy conflicts with a legal requirement or an applicable Notice of Privacy Practices, the controlling law or applicable notice governs to the extent of the conflict.