St. James Hospital / Compliance & Privacy
Compliance & Privacy
To further the Mission and in Support of its IICARE Values, St. James Hospital has developed a Corporate Compliance "Program" to establish a frame work for ethical conduct and legal compliance. The Program will assist SJH trustees, employees, agents, and vendors in complying with system-wide policies and procedures and applicable federal and state laws and regulations.
SJH pledges to meet its Mission in an atmosphere that recognizes its responsibility to conduct business affairs with integrity based on sound ethical and moral standards. SJH recognizes the responsibility to treat all people it serves with the same standards of care, regardless of payor source and in accordance with applicable rules, regulations and laws. SJH is intolerant of fraud, waste and abuse and strives to deliver medically necessary services in the most efficient and prudent manner. SJH also holds those it conducts business with to these same standards.
In keeping with our ICARE Value of Integrity, SJH has established a hotline for employees, patients and visitors to report compliance concerns. Confidential reporting is available 24 hours a day, 7 days a week by contacting the Integrity Hotline at (585) 756-8888 or integrityhotline.urmc.edu.
Commitment to Privacy
SJH does not collect any personal information about a visit unless that information is provided voluntarily by sending an email, responding to a survey, or completing an online transaction.
Information Collected Automatically When Visiting SJH’s Websites
SJH is able to collect the following information:
- The Internet Protocol address of the computer that accessed SJH’s websites;
- The type of browser, its version and the operating system on which that browser is running;
- The web page from which the user accessed the current web page;
- The date and time of the user’s request; and
- The pages that were visited and the amount of time spent at each page
None of the above-mentioned information is deemed to constitute personal information by the New York State Internet Privacy and Security Act. The information that is collected automatically is used to improve SJH’s website content and to understand how users are interacting with SJH’s websites. This information is collected for statistical analysis and to determine what information is of most and least interest to SJH’s users. The information is not collected for commercial marketing purposes and SJH is not authorized to sell or otherwise disclose information collected from websites for commercial marketing purposes.
Information Collected When Emailing or Completing a Transaction
During a visit to SJH’s websites, there may be a need to send an e-mail to SJH. The email address and contents of a message will be collected. The information collected is not limited to text characters and may include audio, video, and graphic information formats included in the message. The e-mail address and the information included in a message may be used to respond to a request, to address issues identified, to improve SJH’s websites, or to forward a message to another department or State agency for appropriate action. An e-mail address is not collected for commercial purposes and SJH is not authorized to sell or otherwise disclose e-mail addresses for commercial purposes.
During a visit to SJH’s websites a transaction may also be completed, such as a survey, registration, or order form. The information, including personal information, volunteered in completing a transaction is used to operate Institutional programs, which include the provision of goods, services, and information. The information collected may be disclosed by SJH for those purposes that may be reasonably ascertained from the nature and terms of the transaction in which the information was submitted.
SJH does not knowingly collect personal information from children or create profiles of children through SJH’s websites. Users are cautioned, however, that the collection of personal information submitted in an e-mail will be treated as though it was submitted by an adult, and may, unless exempted from access by Federal or State law, be subject to public access. SJH strongly encourages parents and teachers to be involved in children’s Internet activities and to provide guidance whenever children are asked to provide personal information online.
Information and Choice
As noted above, SJH does not collect any personal information unless you provide that information voluntarily by sending an e-mail, responding to a survey, or completing an online form. You may choose not to send SJH an email, respond to a survey, or complete an online form. While your choice not to participate in these activities may limit your ability to receive specific services or products through this website, it will not normally have an impact on your ability to take advantage of other features of the website, including browsing or downloading information.
Disclosure of Information Collected Through this Website
The collection of information through SJH’s websites and the disclosure of that information are subject to the provisions of the New York State Internet Privacy and Security Act. SJH will only collect personal information through SJH’s websites or disclose personal information collected through SJH’s websites if the user has consented to the collection or disclosure of such personal information. The voluntary disclosure of personal information to SJH by the user, constitutes consent to the collection and disclosure of the information by SJH for the purposes for which the user disclosed the information to SJH.
However, SJH may collect or disclose personal information without consent if the collection or disclosure is: 1) necessary to perform the statutory duties of SJH, or necessary for SJH to operate a program authorized by law, or authorized by state or federal statute or regulation; 2) made pursuant to a court order or by law; 3) for the purpose of validating the identity of the user; or 4) of information to be used solely for statistical purposes that is in a form that cannot be used to identify any particular person.
Further, the disclosure of information, including personal information, collected through SJH’s websites is subject to the provisions of the New York State Freedom of Information Law and the Personal Privacy Protection Law.
SJH may disclose personal information to federal or state law enforcement authorities to enforce its rights against unauthorized access or attempted unauthorized access to SJH’s information technology assets.
Retention of Information Collected Through this Website
Access to and Correction of Personal Information Maintained by SJH
Any user may submit a request to SJH’s Privacy Officer to determine whether personal information pertaining to that user has been collected and maintained through SJH’s Websites. Any such request shall be made in writing and must be accompanied by reasonable proof of identity of the user. Reasonable proof of identity may include verification of a signature, inclusion of an identifier requested or assigned by SJH, or similar appropriate identification.
The Privacy Officer may be contacted at:
St. James Hospital
7329 Seneca Road North
Hornell, NY 14843
Attn: Jason Soles, Privacy Officer
The Privacy Officer shall, within five (5) business days of the receipt of a proper request, acknowledge the receipt of the request in writing, and within thirty (30) days from the date of the acknowledgment provide access to the personal information; deny access in writing, explaining the reasons therefore; or, stating the approximate date when the request will be granted or denied.
In the event that SJH has collected and maintained personal information pertaining to a user through SJMH’s websites, the information is to be provided to the user pursuant to the user’s request. The Privacy Officer shall inform the user of his or her right to request that the personal information be amended or corrected under the procedures set forth in section 95 of the Public Officers Law.
Confidentiality and Integrity of Personal Information Collected Through this Website
SJH is strongly committed to protecting personal information collected through SJH’s websites against unauthorized access, use, or disclosure. Consequently, SJH limits employee access to personal information collected through SJH’s websites to only those employees who need access to the information in the performance of their official duties. Employees who have access to this information follow appropriate procedures in connection with any disclosures of personal information.
In addition, SJH has implemented procedures to safeguard the integrity of its information technology assets, including, but not limited to, authentication, authorization, monitoring, auditing, and encryption. These security procedures have been integrated into the design, implementation, and day-to-day operations of SJH’s websites as part of SJH’s continuing commitment to the security of electronic content as well as the electronic transmission of information.
For website security purposes and to maintain the availability of SJH’s websites for all users, SJH employs software to monitor traffic to identify unauthorized attempts to upload or change information or otherwise damage SJH’s websites.
Some sections of the SJH website require login identifiers and/or passwords. You are responsible for taking reasonable steps to ensure that no unauthorized person has access to your password or account login information. It is your sole responsibility to control the use of login information and passwords, to authorize, monitor and control access to and use of your website account and password and to inform the website promptly of any need to deactivate a password.
Third-Party Vendors/Content Providers
SJH occasionally will engage reputable third-party vendors to help us manage our website, provide content and information and enable us to interact better with our patients and visitors. SJH never shares any personally identifiable information you provide when requesting information with third parties, except as required by law.
Links to External Websites
St. James Hospital
7329 Seneca Road North
Hornell, NY 14843
Attn: Privacy Officer
Modifications to SJH’s Policy
SJH will perform a review and revise this policy as necessary. Users will be notified about significant changes to this policy by a prominent notice placed on SJH’s website regarding the changes and how they affect your privacy.
The following definitions apply to, and appear in italics, in this policy:
Personal information: For purposes of this policy, "personal information" means any information concerning a natural person which, because of name, number, symbol, mark, or other identifier, can be used to identify that natural person.
State agency websites shall have the meaning set forth in subdivision 7 of section 202 of the New York State Technology Law.
User shall have the meaning set forth in subdivision 8 of section 202 of the New York State Technology Law.