Notice of Privacy Practices

This notice applies to Path & Presence Therapy, an independent counseling practice operated by Carina Nation, a Clinical Mental Health Counselor serving adults, including young adults, and couples.

Services include individual counseling, couples therapy, telehealth throughout Utah, and outdoor Walk & Talk Therapy in the Park City area.

This notice applies to protected health information (PHI) associated with your care, including assessments, diagnoses, treatment plans, progress notes, appointment records, insurance information, billing records, and other related information.

You have the right to:

Access your records. You may request an electronic or paper copy of the health information maintained about you in a designated record set. Requests will generally be addressed within 30 days, subject to permitted extensions and exceptions. Certain separately maintained psychotherapy notes may be excluded from access.

Request corrections. You may ask us to amend information you believe is inaccurate or incomplete. If a request is denied, we will explain the reason and any available options.

Request confidential communication. You may request that we contact you through a particular method or at a different location. Reasonable requests will be accommodated as required by law.

Request restrictions. You may ask us to limit certain uses or disclosures of your information. We are not required to agree to every request. However, qualifying requests to withhold information from a health plan for a service paid entirely out of pocket will be honored unless disclosure is required by law.

Request an accounting of disclosures. You may request information about certain disclosures made during the previous six years, subject to applicable exceptions.

Receive this notice. You may request a paper or electronic copy at any time.

Designate a representative. An individual legally authorized to act on your behalf may exercise applicable privacy rights. Their authority will be verified before information is released.

File a complaint. You may raise concerns or file a privacy complaint without retaliation or discrimination.

To exercise these rights, contact Carina Nation at 435-776-5606 or Carina.nation@pathpresencetherapy.com.

Your information may be used or disclosed for treatment, payment, healthcare operations, and other legally permitted purposes.

Additional confidentiality protections apply to mental health communications under Utah law.

Treatment

Information may be used to assess your needs, provide therapy, develop treatment plans, document services, and coordinate clinically appropriate care.

When appropriate, information may be shared with other healthcare professionals involved in your treatment, subject to applicable confidentiality and authorization requirements.

Payment

Information may be used or disclosed to verify insurance eligibility, submit claims, process payments, address billing questions, and maintain financial records.

Healthcare Operations

Information may be used for practice management, maintaining records, quality improvement, professional compliance, and other appropriate administrative activities.

Service providers that handle protected health information on behalf of Path & Presence Therapy must comply with applicable privacy requirements, including business associate agreements when required.

Utah Code § 58-60-114 provides additional protections for confidential communications between licensed mental health therapists and their clients.

Generally, confidential therapeutic communications may not be disclosed without express written consent unless an applicable legal or professional exception permits or requires disclosure.

Exceptions may involve:

• Mandatory reporting of abuse, neglect, or exploitation.

• Certain serious threats to health or safety.

• Applicable duties to warn or protect.

• Qualifying legal proceedings or court orders.

• Other disclosures authorized or required by law or recognized professional standards.

Path & Presence Therapy will follow the more protective applicable requirement when federal and Utah law differ.

Subject to applicable federal and Utah protections, information may be disclosed when permitted or required for purposes such as public health reporting, healthcare oversight, professional licensing investigations, legally authorized research, workers' compensation, court proceedings, and certain law enforcement or safety-related circumstances.

A request, subpoena, or demand for records does not automatically authorize disclosure of confidential therapy communications.

Applicable legal requirements will be evaluated before information is released.

Written authorization will be obtained when required before:

• Using or disclosing protected information for marketing.

• Selling protected health information.

• Using or disclosing most separately maintained psychotherapy notes.

• Disclosing confidential information outside an applicable legal exception.

• Making other uses or disclosures requiring authorization.

Path & Presence Therapy does not sell protected health information or use confidential treatment records for third-party advertising.

You may revoke an authorization in writing. Revocation will not affect information already used or disclosed in reliance on that authorization.

Specially Protected Substance-Use Records

Certain substance-use-disorder records receive additional protection under 42 CFR Part 2.

If Path & Presence Therapy receives or maintains records protected by Part 2, those records will be handled according to applicable federal requirements.

Part 2 records generally may not be used or disclosed in proceedings against an individual without the specific consent or legal process required by law.

This notice does not identify Path & Presence Therapy as a separately designated substance-use-disorder treatment program.

Couples counseling involves additional privacy considerations because more than one individual participates in treatment.

Before couples therapy begins, participants will receive information regarding confidentiality, recordkeeping, information shared privately, access to records, and applicable authorization requirements.

Neither partner automatically has unrestricted access to the other's confidential information.

Records requests and disclosures will be evaluated according to applicable law, the therapeutic relationship, and the couples counseling informed-consent agreement.

Telehealth

Telehealth counseling may be provided through approved technology platforms to clients physically located in Utah when legally and clinically appropriate.

Reasonable privacy safeguards are used, but no electronic communication system can eliminate every risk.

Clients are encouraged to participate from private locations and use secure devices and internet connections.

A separate telehealth informed-consent agreement addresses the specific benefits, limitations, risks, and expectations of virtual treatment.

Walk & Talk Therapy

Outdoor sessions may take place in designated natural settings in the Park City area.

Because these sessions occur outside a traditional office, there may be additional privacy considerations, including incidental encounters with members of the public.

Reasonable precautions will be taken to protect confidentiality, and clients will receive separate informed consent regarding outdoor privacy and safety.

Path & Presence Therapy uses Sessions Health, an electronic health record and practice management platform, for clinical documentation, client scheduling, intake forms, and appointment-related communications.

Clients may access the practice's scheduling and portal services at:

https://pathandpresencetherapy.sessionshealth.com/

Sessions Health provides a secure client portal through which authorized clients may access available practice features, complete intake documentation, manage appointments, and communicate through secure messaging when that feature is enabled.

Protected health information is handled through approved systems and applicable privacy and security safeguards.

Path & Presence Therapy uses Sessions Health to send appointment-related email and SMS reminders when clients have selected or authorized these communication methods.

Automated email and SMS reminders are not the same as secure client-portal messages.

These communications may pass through ordinary email or mobile networks and could be viewed by someone with access to your email account, telephone, notifications, or connected devices.

An appointment reminder may also reveal that you have a relationship with Path & Presence Therapy.

Clients will be informed of these risks and asked to acknowledge them when choosing nonsecure appointment reminders.

Clients may change their reminder preferences or opt out through their Sessions Health client portal or by contacting the practice.

SMS reminders are used for appointment-related communication, not for marketing campaigns or detailed clinical discussions.

Mobile phone numbers and SMS consent information are not sold or shared with third parties or affiliates for their independent marketing or promotional purposes.

For sensitive treatment-related communication, clients should use the approved secure client portal rather than standard SMS or email.

The Path & Presence Therapy website is hosted through Squarespace.

The website's general contact form is intended for basic inquiries about services and does not request clinical histories, diagnoses, treatment records, or other sensitive intake information.

Submitted inquiries are directed to Carina Nation at Carina.nation@pathpresencetherapy.com.

The Squarespace contact form is not the practice's clinical intake system or secure client portal.

Visitors should avoid including sensitive clinical information in general website inquiries.

Submitting a website inquiry does not automatically enroll an individual in SMS messaging or establish a therapeutic relationship.

For more information about website data practices, please review our separate Website Privacy Policy.

Path & Presence Therapy maintains clinical records in accordance with applicable Utah professional requirements.

Specified mental health treatment records are generally retained for at least ten years after documented termination of services.

Reasonable administrative, physical, and technical safeguards are used to protect information from unauthorized access, use, or disclosure.

If a reportable breach of unsecured protected health information occurs, notifications will be provided as required by law.

Path & Presence Therapy is responsible for:

• Protecting the privacy and security of protected health information.

• Following applicable federal and Utah confidentiality requirements.

• Providing clients with information about their privacy rights.

• Obtaining required consent or authorization.

• Maintaining appropriate recordkeeping and security safeguards.

• Providing legally required breach notifications.

• Refraining from retaliation against individuals who exercise privacy rights.

Path & Presence Therapy may revise this notice when laws, technology, or practice operations change.

The current version will be available on our website and upon request.

Updated practices may apply to information already maintained by the practice as permitted by law.

For privacy questions, records requests, or concerns, contact:

Path & Presence Therapy
Carina Nation, CMHC
Park City, Utah
Phone: 435-776-5606
Email: Carina.nation@pathpresencetherapy.com
Website: www.pathandpresencetherapy.com

You may also file a complaint with:

U.S. Department of Health and Human Services
Office for Civil Rights
Phone: 1-877-696-6775
Website: https://www.hhs.gov/hipaa/filing-a-complaint/index.html

Utah Division of Professional Licensing
Phone: 801-530-6628
Email: dopl@utah.gov
Website: https://commerce.utah.gov/dopl/file-a-complaint/

You will not be retaliated against for filing a complaint or exercising your privacy rights.