BrownStone CHC cares deeply about the privacy of its visitors and users. To that end, this Privacy Policy (“Privacy Policy”) describes how we., together with our affiliated companies (“we”, “our”, or “us”), collect, use, and share your Personal Information, as well as an explanation of the data rights you may have in that Personal Information. 

​

Specifically, this policy will inform you of the following:

What personally identifiable information is collected from you through our website;

Why we collect personally identifiable informations and the legal basis for such collection;

how we use the collected information;

What choices are available to you regarding the use of your data;

The security procedures in place to protect the misuse of the information.

 

Questions and complaints

I. ​POLICY:  

 

 

A. It is the policy of The Brownstone Project to that the persons served are encouraged to state complaints and/or grievances if they believe their rights have been violated, and to pursue a resolution to their concerns in a structured format that provides fair and equitable results through due process.

 

II. PROCEDURE:

 

 

A. Persons served will be fully informed of the grievance procedures during their orientation to services. In addition, they will receive printed materials that will provide an overview of this process for later reference.

 

B. Day-to-day issues affecting the persons served shall be resolved informally between the person served and the primary staff member responsible for his/her service coordination (Team Leader, Clinician, Family Advocate, etc). If the problem or complaint is not resolved to the satisfaction of the person served, the Corporate Compliance Officer will adhere to the guidelines contained in this policy and assist the person served in accessing the procedures necessary to resolve the concern.

 

C. Persons served have the right to due process with regard to grievances, and the organization will afford every reasonable opportunity for informal and/or formal resolution of the grievance.

 

D. Persons who may bring grievances include, but are not limited to:

 

1) The person served.

 

2) The guardian of the person served.

 

3) The attorney, designated representative, or a representative of a rights protection or advocacy agency of the person served.

 

E. A grievant shall in no way be subject to disciplinary action or reprisal, including reprisal in the form of denial or termination of services, loss of privileges, or loss of services as a result of filing a grievance.

 

F. Notices summarizing a person’s right to due process in regard to grievances, including the process which grievances may be filed and copies of forms to be used for such purpose, shall be available within each facility and program area.

 

G. Each person served will be informed of his/her right to grieve and the right to be assisted throughout the grievance process by a representative of his/her choice, in a manner designed to be understandable to the person served.

 

H. During a formal grievance procedure, the person served will have the right to the following:

 

1) Assistance by a representative of his/her choice.

 

2) Review of any information obtained in processing the grievance, except that which would violate the confidentiality of another person served.

 

3) Presentation of evidence of witnesses pertinent to the grievance.

 

4) Receipt of complete findings and recommendations, except those that would violate the confidentiality of another person served.

 

I. In all grievances the burden of proof shall be on the organization, facility, or program to show compliance or remedial action to comply with the policies and procedures established to ensure the rights of persons served.

 

J. All findings of a formal grievance procedure shall include:

 

1) A finding of fact.

 

2) A determination regarding the adherence of the organization, program, or employee, or the failure to adhere, to specific policies or procedures designed to ensure the rights of persons served.

 

3) Any specific remedial steps necessary to ensure compliance with organizational policies and procedures.

 

K. The steps of a formal grievance are as follows:

 

1) Formal grievances shall be filed first with the supervisor/director of the service unit or program in which the grievance arises.

 

2) A copy of the grievance shall be forwarded to the administrative head of the organization.

 

3) The supervisor/director of the service unit or program will meet with the grievant, and/or representatives, immediately following the filing to brainstorm resolution of any related issues that may get in the way of full participation in services. Actions may include, but not be limited to, a change in direct care providers or an adjustment in programming schedules and/or program environments. 

 

4) The organization will issue a formal written response to the grievant, and/or the designated representatives, within five working days, excluding weekends or holidays, of the complaint.

 

L. The steps to appeal a written response to a grievance:

 

1) If the grievant is unsatisfied with the findings of the written response to a grievance, he or she may appeal the decision to the Chief Operating Officer within five days, excluding weekends or holidays.

 

2) The Chief Operating Officer will issue a formal written response to the grievant, and/or the designated representatives, within five working days, excluding weekends or holidays, of the complaint. 

 

3) If the grievant is unsatisfied with the findings of the written response, he/she will be referred to a third party outside of the organization. Third parties may include organizations such as children’s or adult protective services, professional licensing boards, nursing home ombudsmen, or other appropriate organizations that may serve as an advocate for the person served. 

 

M. All staff members of The BrownStone Project, LLC, will be trained in the implementation of this policy and procedures during orientation, and will receive ongoing training of the procedures to ensure the process is applied in a comprehensive manner if a grievance is filed.

 

N. Grievances regarding the actions of specific staff members will be handled in accordance with personnel rules and contract provisions. No disciplinary action may be taken, nor facts found with regard to any alleged employee misconduct, except in accordance with applicable personnel rules and labor contract provisions.

 

O. A Grievance Log will be maintained by the organization detailing the nature of the complaint, relevant information obtained in the investigation, and the outcome of the process. All information contained will maintain the confidentiality of the participants in the process. This record will be reviewed annually by the Leadership Team to determine if there are trends in the complaints, and to identify areas to initiate performance improvement activities

​

Data retention

We may collect and make use of personal information to assist in the operation of our website and to ensure delivery of the services you need and request. We may retain your Personal Information for as long as your User Account is active, as indicated in this Privacy Policy, or as otherwise needed to provide you with our Services. 

​

​We are collecting your data for several reasons:

​

To better understand your needs and provide you with the services you have requested;

To for fill our legitimate interest in improving our services and products;

 

The data we collect from you will be stored for no longer than necessary. The length of time we retain said information will be determined based upon the following  criteria: the length of time your personal information remains relevant:

or as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users or their Users-of-Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.

​

Use of cookies and other third-party technologies

We and our Third Party Service Providers use cookies and other similar technologies (“Cookies”) in  order for us to provide our Service and ensure that it performs properly, to analyze our performance and marketing activities, and to personalize your experience.

​

​

Security

Our domain courier has implemented  the following security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services; the transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and we regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.