PRIVACY POLICY

The Meals On Wheels (MOWW), Santa Monica, CA provides home-delivered meal services to people in need. Meals on Wheels West (MOWW) is dedicated to nourishing and enriching the lives of the home-bound by delivering healthy meals and services that promote self-respect and independent living.

Personal information from those who communicate with us online may be collected for the purpose of responding to specific questions, advising visitors of new online material, activities and events, and offering opportunities for contributing to local and national programs and research initiatives. Our web server recognizes consumer domain names for the purpose of analyzing web site access and improving the content of our web site.
Personal data such as your health related information, e-mail address, telephone number, address, age and gender may be collected in order to respond to your specific request for information. Online donations to the Meals On Wheels West (MOWW) are processed over a secure connection between your computer and the server. Credit card information is encrypted when submitted to the processor.

MOWW does not share the personal information collected with any outside organizations. If you wish to verify and correct the information we have collected, you may call the MOWW office at 310-394-5133 or email your request to moww@mealsonwheelswest.org.

Our privacy policy is subject to change without notice. Therefore, we recommend that you check this web page periodically for updates and revisions. This privacy policy is in effect as of the date below.

Credit Card Security
We care about the safety and security of your transaction. We use high grade encryption and the https security protocol (SSL) to communicate with your browser software. This method is the industry standard security protocol, which makes it extremely difficult for anyone else to intercept the credit card information you send to us. Companies we work with to process credit card transactions also use high grade encryption and security protocols.

DEFINITIONS:
Confidential Information: This is information obtained or created by MOWW which is restricted as to access, disclosure or use. It may be found in any medium, whether oral, written, or electronic. It includes the following:
PI: Personal Information (PI) is any non-public information that is identifiable to an individual. It may be demographic, such as the individual’s age or address, or it may be health information, such as his or her medical history.
PHI: Protected health information (PHI) is a subset of Personal Information (PI).
PHI is individually identifiable health and demographic information created or collected. SI: Security Information (SI) is information which, if improperly disclosed, could adversely impact the security of a MOWW client, a MOWW staff client, or MOWW’s assets. Examples include information about MOWW’s computer systems, financial accounts, and access systems.

MOWW employs error checking procedures to make certain transactions are processed completely and accurately. As necessary, changes are made to improve our systems. And, independent external and internal audits are conducted to ensure the privacy, security and appropriate processing of your information on our site.

OBJECTIVE:
This privacy policy provides guidance to enable MOWW to meet its commitment to protect the privacy of its clients, protect the security of MOWW, its employees and its assets, and comply with relevant legal requirements.
There are a number of laws that address privacy and security issues. The following laws most significantly impact MOWW.
• In the 1937 Act, California Government Code 31532 precludes disclosure of MOWW’s client records and sworn statements unless proper authorization is provided.
• The Health Insurance Portability and Accountability Act of 1996 (HIPAA) governs PHI and imposes certain administrative requirements.

Beyond these legal requirements, MOWW continuously reviews legislation and privacy and security practices to ensure the privacy of its clients and the security of its operations.

PRIVACY POLICY DIRECTIVES:
In accordance with applicable laws and MOWW’s mission, all MOWW employees* are responsible for ensuring that PI and PHI, including client records and sworn statements, are not disclosed except to:

• Authorized MOWW employees for approved purposes, the client upon request, or third parties who have appropriate authorizing documentation.
• Volunteers, employees and board members are required to submit to background check before engaging in job responsibilities. The information acquired is held confidential database at the American Red Cross database.

In addition, MOWW employees are responsible for ensuring that PI and PHI are obtained, used or shared only to the minimum necessary extent that is required to further MOWW’s mission, within the constraints of applicable laws. This means that access to PI and PHI is permitted on a need-to-know basis.

Reasonable safeguards are to be implemented to ensure the privacy of PI and PHI, including controls on who can access the information, how the information is used, how it is obtained, stored and shared, and how it is eventually discarded. Client sworn statements and client records are to be kept confidential.

HIPAA imposes specific restrictions with respect to PHI. As the administrator for the retirement health care insurance benefits of its clients, MOWW generally may not disclose PHI for purposes other than the TPO of its retirement health care function without obtaining a written authorization from the individual and tracking its use of the
SI and PRI are to be secured at all times from unauthorized disclosure or use.

The deliberate or negligent mishandling or misuse of PI, PHI, SI, or PRI is considered to be misconduct and is enforced through MOWW’s Misconduct and Illegal Acts Policy.
* With regard to this policy only, the term “employee(s)” refers to all MOWW personnel who are directed or directly supervised by MOWW management.