Privacy Policy

Electronic Visit Verification (EVV) System

Last Updated: {{Insert Date}}

This notice provides the privacy policy for the Electronic Visit Verification (“EVV”) system (“the System”) regarding the nature, purpose, use, and sharing of any Personally Identifiable Information (PII) and Protected Health Information (PHI) collected through our application or related services. Our privacy policy explains our information practices when PII/PHI is provided to us—whether collected online, through our mobile application, via API connections, or during onboarding and operational interactions with agencies, caregivers, or service recipients.

We protect all information consistent with applicable laws and regulations, including the Privacy Act, HIPAA, the 21st Century Cures Act, Minnesota DHS 245D requirements, and the Federal Records Act analogs for state-level retention.

The PII/PHI you provide will be used only for its intended purpose: supporting the delivery, documentation, verification, and compliance of EVV-related services.


Personally Identifiable Information

As a general rule, we do not collect PII/PHI beyond what is required for EVV or administrative system functions unless you choose to provide such information to us. Providing PII is voluntary; however, refusing to provide certain required data may prevent the System from fulfilling DHS EVV requirements or may limit access to features.

If you choose to enter PII or PHI—through account creation, visit verification, care documentation, support messaging, or agency-level setup—we use that information strictly to provide the requested service or respond to your inquiry.

When information is collected, the reasons for collecting it, the intended usage, how to grant consent for non-mandatory uses, and any additional notices will be clearly described in a dedicated “Privacy Notice” either displayed at the point of collection or accessible via hyperlink.


Email

If you send us an email, in-app message, or support request, we use the information only to respond to your inquiry or provide support services.

Email is not always secure. We strongly advise users not to send sensitive PHI, Social Security numbers, financial information, or other private data via email. Certain sensitive communications should be submitted through:

  • secure in-app messaging,
  • secure upload pages,
  • encrypted API connections, or
  • physical mail (when appropriate).

Electronic communications that qualify as records under applicable retention laws are preserved and stored for required periods. Messages not meeting record criteria are deleted when no longer needed.


Information Automatically Collected

We collect and temporarily store certain technical information about your visit for security, auditing, and system-improvement purposes only. This data helps us ensure the system functions properly and securely.

This may include:

  1. Internet domain
  2. IP address
  3. Browser type and version
  4. Operating system
  5. Date and time of access
  6. URLs/screens viewed
  7. User ID
  8. Referring site
  9. Device identifiers
  10. Geolocation for EVV verification

This information may be shared internally or with authorized third parties strictly for system maintenance, audits, fraud prevention, security, or regulatory compliance. Raw logs are retained only as long as necessary.


Third-Party Services

The System uses secure third-party systems such as:

  • Cloud hosting (e.g., AWS)
  • SMS providers (e.g., Twilio)
  • Audit tools
  • DHS aggregator systems

We do not sell, disclose, or transfer PII/PHI for marketing or unrelated profiling. Third-party services may collect minimal operational data but are bound by Business Associate Agreements (BAAs).

If you navigate away from our System, you are subject to the external website’s policies.


Surveys and Feedback

We may use optional surveys to collect feedback.
These:

  • do not collect PHI,
  • are voluntary,
  • do not impact access to services.

Cookies

We use cookies for:

  • auth
  • sessions
  • preferences
  • security

Types:

  • Session cookies (temporary)
  • Persistent cookies (saved settings)

You may disable cookies, but some functions may break.
We do not use them for ads.


Security

We use administrative, physical, and technical safeguards including:

  • RBAC
  • MFA (optional)
  • Encryption (TLS 1.2+ and AES at-rest)
  • Firewalls
  • Backups
  • Intrusion detection
  • Logging
  • Regular security audits

Contractors and third-parties with PHI access must comply with HIPAA.


Children’s Privacy

We do not knowingly collect information directly from children under 13.
If a minor is a service recipient, their data is:

  • entered by authorized staff/caregivers,
  • used strictly for EVV and care documentation,
  • protected by HIPAA and state law.

External Websites

Links to external resources may appear in the System.
These are not controlled by us and may have different privacy/security policies.


Use & Sharing of Information

We use collected data to:

  • document EVV visits
  • verify location
  • support billing
  • maintain audit trails
  • operate and improve the System

We may share information with:

  • authorized agency administrators
  • DHS systems and approved aggregators
  • contractors under BAAs
  • auditors, regulators
  • law enforcement (when required)

We do not sell data.


Data Retention

Retention rules:

  • EVV visit data: 7–10 years
  • Audit logs: 6+ years
  • Billing/claims: 7 years
  • Account records: as required by law

After retention, data is securely deleted via NIST-compliant destruction methods.


User Rights

Users may:

  • view their profile data
  • request corrections
  • request access logs (via agency admin)

Users may not:

  • delete EVV-required data
  • remove audit logs
  • disable location capture required for EVV verification

Contact Information

For privacy questions or access requests:

{{Your Company Name}} – Privacy Office
{{Your Address}}
{{Email}}
{{Phone}}