Privacy Policy &
HIPAA Notice

Who We Are

Betwixt Counseling Center is an outpatient mental health practice specializing in therapy for women navigating life transitions. We are a covered entity under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and its implementing regulations, including the HITECH Act amendments.

This Privacy Policy and Notice of Privacy Practices applies to all clients of Betwixt Counseling Center, all forms of communication (in-person, telehealth, phone, email), and all records created or maintained by our practice.

By engaging our services, you acknowledge receipt of this notice. We will ask you to sign a written acknowledgment during your intake process.

What Is Protected Health Information

Protected Health Information (PHI) is any information that identifies you and relates to your physical or mental health, the provision of health care to you, or payment for health care. This includes information that is created, received, maintained, or transmitted in any form — written, electronic, or verbal.

Examples of PHI we collect and maintain:

• Your name, address, date of birth, and contact information
• Your Social Security number or insurance ID (if applicable)
• Your mental health history, diagnoses, and treatment records
• Session notes, treatment plans, and progress notes
• Billing records and payment information
• Communications between you and your clinician
• Referral information from other providers
• Emergency contact information

How We Use Your Information

HIPAA permits us to use your PHI for three primary purposes without requiring your separate written authorization: Treatment, Payment, and Health Care Operations (TPO).

Treatment

We use your information to provide, coordinate, and manage your mental health care. This includes sharing relevant information among members of our clinical team involved in your care, consulting with other providers with your knowledge, and coordinating referrals when appropriate.

Payment

We may use your PHI to bill your insurance company, process payments, verify coverage, or respond to insurance audits. If you pay out-of-pocket, your information is used only for billing and receipt purposes.

Health Care Operations

We may use your information for internal quality improvement, staff training, accreditation purposes, or legal and compliance activities. These uses are strictly internal and never result in your identifiable information being shared externally without your consent.

When We May Share Your Information

Beyond treatment, payment, and operations, there are specific circumstances under which HIPAA permits or requires us to disclose your information without your written authorization. These are limited and we take each seriously.

Mandatory Reporting — Safety Situations

• Imminent danger to yourself or others: If we have reasonable belief that you present a serious and imminent threat of harm to yourself or another identifiable person, we are both legally and ethically obligated to take protective action. This may include contacting emergency services or warning a potential victim.
• Child abuse or neglect: As licensed mental health professionals, we are mandated reporters. If we have reasonable suspicion of abuse, neglect, or exploitation of a minor, we are required by law to report this to the appropriate authorities.
• Abuse of a vulnerable adult: We are required to report known or suspected abuse, neglect, or exploitation of elderly or vulnerable adults to adult protective services.

Legal & Court Orders

• In response to a valid court order, subpoena, or legal process — we will make every reasonable effort to notify you before complying
• To comply with state or federal law as required
• In response to a valid request from a law enforcement official under specific legal circumstances

Business Associates

We may share your PHI with trusted third-party Business Associates — such as our electronic health record (EHR) system, billing services, or secure communication platforms — who assist us in providing care. All Business Associates are contractually required to protect your PHI and use it only as permitted by law. We maintain signed Business Associate Agreements (BAAs) with all such vendors.

With Your Authorization

For any use or disclosure not described above — such as sharing records with another provider, family member, attorney, or any other party — we will obtain your written authorization first. You may revoke that authorization at any time in writing.

What We Will Never Share

We want to be explicit about what we will not do with your information — because trust is the foundation of this work.

• We will never sell your PHI to any third party for any reason
• We will never share your information for marketing purposes without your explicit written authorization
• We will never disclose your status as a client to employers, family members, or friends without your written consent
• We will never use your information for research without your written authorization and appropriate ethical oversight
• We will never communicate with you through unsecured channels (such as standard email or text) about clinical matters without your informed consent and acknowledgment of the risks
• Psychotherapy notes (distinct from general progress notes) receive extra legal protection under HIPAA and require specific written authorization before they can be disclosed in most circumstances

Your Rights

You have significant rights regarding your protected health information under HIPAA. We are committed to honoring each of them fully.

To exercise any of these rights, please submit a written request to our Privacy Officer using the contact information at the end of this document. We will respond within 30 days.

Our Duties

Betwixt Counseling Center is required by law to:

• Maintain the privacy and security of your protected health information
• Provide you with this Notice of Privacy Practices
• Abide by the terms of this notice currently in effect
• Notify you in the event of a breach of your unsecured PHI
• Not retaliate against you for exercising your rights under HIPAA

We reserve the right to change this notice at any time. Any changes will apply to PHI we already hold as well as new information. We will post any updated notice on our website and have copies available in our office. The effective date will always be clearly indicated.

Website & Digital Data

This section describes how we handle information collected through our website at betwixtcounseling.com.

Information You Provide

If you contact us through a web form, email inquiry, or consultation request, we collect only the information you voluntarily provide — such as your name, email address, and the content of your message. This information is used solely to respond to your inquiry and is not added to clinical records unless you become a client.

Automatically Collected Information

Our website may collect standard technical data such as your browser type, IP address, and pages visited. This information is used only for website performance and security — never to identify individual visitors or for advertising.

Cookies

We use only essential cookies necessary for the website to function. We do not use tracking cookies, advertising cookies, or third-party analytics that sell your data.

Third-Party Links

Our website may contain links to third-party platforms such as scheduling tools or client portals. We are not responsible for the privacy practices of external sites. Please review their privacy policies independently.

Telehealth Privacy

Betwixt Counseling Center offers telehealth services. We are committed to protecting your privacy in virtual sessions.

• We use only HIPAA-compliant telehealth platforms with end-to-end encryption and signed BAAs
• Sessions are never recorded without your explicit written consent
• We recommend you participate in sessions from a private, confidential location and use headphones when possible
• You are responsible for ensuring the privacy of your environment during telehealth sessions
• We cannot fully control the security of your internet connection or personal devices — we encourage you to use a secure, private network

Minors & Guardians

Betwixt Counseling Center primarily serves adult women (18 and older). If we work with a minor client, the following applies:

• A parent or legal guardian must provide written consent for treatment of a minor
• In most circumstances, a parent or guardian has the right to access the minor's PHI
• There are legal exceptions where a minor may consent to certain treatment independently — we will communicate applicable state law clearly at intake
• Our website is not directed at individuals under 18 and we do not knowingly collect information from minors through our website

How to File a Complaint

If you believe your privacy rights have been violated, you have the right to file a complaint — and we take every complaint seriously. You will not be retaliated against for filing a complaint.

File a complaint with us directly:

Contact our Privacy Officer in writing at the address below. We will investigate all complaints and respond within 30 days.

File a complaint with the U.S. Department of Health & Human Services:

You may also file a complaint with the HHS Office for Civil Rights (OCR), which oversees HIPAA compliance:

• Online: hhs.gov/ocr/privacy/hipaa/complaints
• Phone: 1-800-368-1019
• TDD: 1-800-537-7697
• Mail: Hubert H. Humphrey Building, 200 Independence Avenue SW, Washington, D.C. 20201

Contact Us

For questions about this notice, to exercise your rights, or to file a complaint, please contact our Privacy Officer:

We are committed to responding to all privacy-related inquiries within 5 business days and to resolving complaints within 30 days.