This Washington Consumer Health Data Privacy Policy ("Policy") applies to personal data defined as "Consumer Health Data" by the Washington My Health My Data Act ("MHMD") that is collected, used, or shared by Delta Dental of Washington ("DDWA", "we," "us," or "our"). This Policy supplements the DDWA Website Privacy Policy. In the event of a conflict between any other policy, statement, or notice and this Policy, this Policy will prevail as to Consumer Health Data protected under MHMD.

Consumer Health Data ("CHD") under MHMD is defined as personal information that is linked or reasonably linkable to a consumer and that identifies the consumer's past, present, or future physical or mental health status. This Policy does not apply when an exception or exemption applies such as for Protected Health Information ("PHI") under the Health Insurance Portability and Accountability Act ("HIPAA"). As a dental benefits provider, most of the data DDWA collects and uses is data excluded from MHMD because the data are regulated under HIPAA or other privacy laws. Examples of data we collect that are excluded from MHMD include:

  • Personal data defined as Protected Health Information ("PHI") under HIPAA;
  • Health care information collected, used, or disclosed in claims data;
  • Information and documents created specifically for and collected and maintained for DDWA’s Quality Improvement;
  • Information that is de-identified as defined in HIPAA and information derived from such de-identified data; and
  • Information used only for public health activities and purposes and Limited Data Sets as described in HIPAA.

Follow this link to see our Notice of Privacy Practices and other Privacy Policies that provide disclosures about personal information that is not CHD subject to MHMD.

Consumer Health Data We Collect

The personal data we collect depends on the context of your interactions with DDWA, the choices you make, the tools and features you use, your location, and applicable law. We may collect the following categories of personal information, which may be CHD if not excluded under the MHMD:

  • Information about your health-related conditions, status, or diagnoses;
  • Precise location information that could reasonably indicate a Washington consumer’s attempt to acquire or receive health services or supplies;
  • Internet or network activity information essential to running our website such as IP address, operating system and version, and browser type/version which could identify your attempt to seek health care services or information;
  • Other information that may be used to infer or derive data related to the above or other health information.

Sources of Consumer Health Data

Delta Dental of Washington does not collect your Consumer Health Data unless you voluntarily provide it to us. We may collect personal information, including CHD, from the following categories of sources:

  • Directly from you when you use our services or interact with us, including through connected devices or profiles.
  • From third-party sources including DDWA affiliates, contracted service providers, and business associates under HIPAA.
  • From websites and mobile applications and automatically from devices you use to connect to our services.
  • From voluntarily submitted data in open text fields unrelated to dental benefits.

Use of Your Consumer Health Data

To the extent we collect personal information, including CHD, as described above, we may collect and use it for the following purposes:

  • To provide you with the services you have requested or authorized,
  • To deliver the services and their features, including personalization of certain features,
  • To ensure the secure and reliable operation of the services and the systems that support them including troubleshooting and improving the services,
  • For essential business operations that support the provision of the services such as analyzing our performance, meeting our legal obligations, developing our workforce, and conducting research and development, and
  • For other purposes for which we give you choices or obtain your consent as required by law – for example, for advertising or marketing purposes.

Since we are a HIPAA-covered entity, most of the data DDWA shares is excluded from MHMD. As necessary for the purposes described above, we may share personal information (see “Consumer Health Data We Collect”), including CHD, with following categories of third parties:

  • Affiliates. We enable access to data across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access helps us to provide our services and operate our business. Our affiliates include Washington Dental Service, Triforza Corp, and Arcora Foundation.
  • Service providers. Vendors or agents (“processors”) working on our behalf may access CHD for the purposes described above.
  • Business partners. We may share CHD with other companies, for example, where you use a service that is cobranded and jointly operated with another company, or where you use our services to interact with another company.
  • Financial institutions & payment processors. When you make a purchase or enter into a financial transaction, we will disclose payment and transactional data to banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, analytics, or other related financial services.
  • Government agencies. We disclose data to law enforcement or other government agencies when necessary to comply with applicable law or respond to valid legal process.
  • Other third parties. In certain circumstances, it may be necessary to provide data to other third parties, for example, to comply with the law or to protect our rights or those of our customers.

How to Exercise Your Rights

MHMD provides you with certain rights with respect to CHD, including the right to access, delete, or withdraw consent relating to your CHD, subject to certain exceptions. You may exercise any of your rights by contacting us directly using the contact details found in this Policy. The written request should include sufficient information to verify your identity and specify the right you wish to exercise. For any questions or assistance, you may also reach out using the contact information below.

If your request to exercise a right under the MHMD is denied, you may appeal that decision by contacting our compliance team using the contact information below. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.

Changes to This Policy

DDWA reserves the right to change this Policy from time to time. When changes to this Policy are significant, we will post the new policy on this page.

Contact Information

Compliance Department
Delta Dental of Washington
400 Fairview Ave N, Suite 800
Seattle, WA 98109-5371
Compliance@deltadentalwa.com

Or call our customer service line at 1-800-554-1907