We take your privacy seriously.
Tulq Health Services, LLC ("Tulq," "we," "us," or "our") is a healthcare services organization providing 24/7 telephone nurse triage services to healthcare provider organizations and the patients they serve.
This Privacy Policy and Notice of Privacy Practices ("Policy") describes:
- What information we collect and how we collect it
- How we use, disclose, and protect your information
- Your rights regarding your information
- How we comply with applicable federal and state privacy laws
- How to contact us with privacy concerns or complaints
This Policy applies to information collected through our nurse triage services, our website, and any other interactions you have with Tulq. By using our services, you acknowledge that you have read and understood this Policy.
HIPAA Notice of Privacy Practices
Tulq Health Services functions as a Business Associate of the healthcare provider organizations it serves, each a covered entity under HIPAA. Our obligations and your rights under federal law.
Our Legal Obligations
Tulq Health Services functions as a Business Associate of the healthcare provider organizations that contract with us (each a "covered entity" under the Health Insurance Portability and Accountability Act of 1996, as amended by the Health Information Technology for Economic and Clinical Health Act of 2009, collectively "HIPAA"). As a Business Associate, we are required by law to:
- Maintain the privacy and security of your Protected Health Information ("PHI")
- Provide you with this Notice of Privacy Practices
- Notify the covered entity in the event of a breach of your unsecured PHI
- Follow the terms of this Notice currently in effect
- Comply with all applicable provisions of the HIPAA Privacy Rule (45 CFR Part 164), the HIPAA Security Rule, and the HITECH Act
We are also bound by the terms of the Business Associate Agreement we execute with each contracting provider organization, and by applicable state health-information privacy laws.
What Is Protected Health Information
Protected Health Information ("PHI") is any information we create, receive, maintain, or transmit that relates to your past, present, or future physical or mental health condition, the provision of healthcare to you, or the past, present, or future payment for your healthcare, and that identifies you or could reasonably be used to identify you.
Your name, address, date of birth, telephone number, medical record number, health plan beneficiary number, account numbers, Social Security Number, and any information about your health conditions, symptoms, medications, or treatment.
How We Use and Disclose Your PHI
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Treatment
We use and disclose your PHI to provide you with nurse triage, clinical advice, and healthcare guidance. This includes creating encounter documentation, transmitting clinical notes back to the contracting provider organization and your care team, and communicating with that care team to ensure continuity of care.
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Healthcare Operations
We use your PHI for internal operations including quality assurance review, nurse competency evaluation, protocol compliance monitoring, staff training, and service improvement. These activities are conducted solely to improve the quality and safety of the care we provide.
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Required by Law
We will disclose your PHI when required to do so by federal or state law, including but not limited to responses to court orders, subpoenas, law enforcement requests made in accordance with applicable law, mandatory reporting obligations, and public health activities.
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Emergency Situations
If you or another person is in imminent danger, we will disclose PHI as necessary to prevent serious and imminent harm, including directing callers to emergency medical services and disclosing relevant clinical information to first responders.
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Business Associates
We may share your PHI with subcontractors and service providers who assist in the delivery of our services, including clinical decision support software providers and secure documentation transmission services. All such parties are required by contract (a Business Associate Agreement) to protect your PHI to the same standard we are.
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Reporting to the Provider Organization
As a contracted nurse triage provider, we transmit encounter documentation to the contracting provider organization, typically within 24 hours of each clinical encounter, using secure transmission methods. Utilization and performance reports provided to the organization will not include unnecessary PHI.
All other uses and disclosures of your PHI not described in this Policy require your written authorization. You may revoke any such authorization at any time by contacting us in writing, except to the extent we have already taken action in reliance on that authorization.
Special Protections: Behavioral Health & Substance Use
Information related to mental health treatment and substance use disorder treatment may be entitled to additional protections beyond standard HIPAA requirements, including protections under 42 CFR Part 2 (Confidentiality of Substance Use Disorder Patient Records).
We treat all behavioral health and substance use information with the highest degree of confidentiality and will not disclose such information without your express written consent except as required by law or in genuine life-safety emergencies.
Your Rights Regarding Your PHI
You have the following rights with respect to your PHI that we maintain. Requests must be made in writing to our Privacy Officer unless otherwise noted.
Right to Access
You have the right to inspect and obtain a copy of your PHI. We will respond within 30 days. We may charge a reasonable cost-based fee for copies.
Right to Amend
You have the right to request that we amend PHI that you believe is inaccurate or incomplete. We may deny your request under certain circumstances and will explain any denial in writing.
Right to an Accounting of Disclosures
You have the right to request a list of disclosures of your PHI made for purposes other than treatment, payment, and healthcare operations. Requests may cover no more than six years.
Right to Request Restrictions
You have the right to request restrictions on how we use or disclose your PHI. We are not required to agree to all restrictions, but we will comply with any restriction we do agree to.
Right to Confidential Communications
You have the right to request that we communicate with you about your PHI in a particular way or at a particular location.
Right to File a Complaint
You have the right to file a complaint if you believe your privacy rights have been violated. We will not retaliate against you for filing a complaint. See Privacy Officer contact below.
You also have the right to receive a paper copy of this Notice at any time, regardless of whether you have agreed to receive it electronically.
Breach Notification
In the event of a breach of your unsecured PHI, we will notify the affected provider organization and, where required, you and the U.S. Department of Health and Human Services Office for Civil Rights, in accordance with the HIPAA Breach Notification Rule (45 CFR §§ 164.400–414).
Notification will occur without unreasonable delay and in no case later than 60 calendar days after discovery of the breach. Initial notification for urgent incidents affecting patient safety or service continuity will occur as soon as practicable after discovery, consistent with the requirements of our services agreements.
Minimum Necessary Standard
We make reasonable efforts to limit the use and disclosure of your PHI to the minimum amount necessary to accomplish the intended purpose of the use or disclosure.
Privacy Officer & Complaints
Our designated Privacy Officer is responsible for ensuring compliance with this Policy and applicable law.
Reach the people who'd actually pick up.
Vancouver, WA 98662-6191
Office for Civil Rights
Washington, D.C. 20201
General Website & Services Privacy
How we collect and use information through our website and nurse triage services — and our commitment to never selling your data.
Information We Collect
Information You Provide Directly. When you call our nurse triage line, we collect information you provide during the call, including your name, contact information, the provider organization or program you are calling through, chief concern, symptoms, relevant medical history, and any other information you choose to share with our nurses.
Automatically Collected Information. When you visit our website, we may automatically collect certain technical information including your IP address, browser type and version, operating system, referring URLs, pages viewed, and the date and time of your visit. This information is collected through standard web server logs and, where applicable, cookies or similar technologies.
Telephony Data. Call metadata including the date, time, duration, and originating number of calls to our nurse triage line may be retained for quality assurance, billing, and compliance purposes.
How We Use Your Information
We use the information we collect to:
- Provide nurse triage and clinical advice services
- Create and transmit encounter documentation to the contracting provider organization
- Comply with our services-agreement and applicable regulatory obligations
- Generate de-identified utilization and performance reports
- Improve the quality and safety of our services
- Train and evaluate clinical staff
- Respond to your inquiries
- Comply with applicable law
- Protect the safety of callers, staff, and the public
We do not sell, rent, or trade your personal information or PHI to any third party for commercial purposes. Ever.
Cookies & Tracking Technologies
Our website may use cookies and similar tracking technologies to improve your browsing experience and analyze website traffic. You may configure your browser to refuse cookies or to alert you when cookies are being sent. Please note that some features of our website may not function properly if cookies are disabled.
We do not use tracking technologies to collect PHI through our website.
Third-Party Service Providers
We may share information with carefully selected third-party service providers who assist in the operation of our services. These include:
- Clinical decision support software providers
- HIPAA-compliant cloud storage and documentation providers
- Telephony and toll-free number service providers
- Secure file transmission service providers
All third-party service providers who may access PHI are required to execute a Business Associate Agreement and are prohibited from using your information for any purpose other than providing services to us. We require all service providers to maintain appropriate administrative, physical, and technical safeguards.
Government-Funded Program Obligations
Where we provide services to or on behalf of a provider organization that participates in a government-funded program — for example, a Federally Qualified Health Center, Rural Health Clinic, Critical Access Hospital, hospice, or a Medicaid-funded program — additional contractual and regulatory privacy obligations may apply to the handling of information collected in connection with that program.
In those cases we handle information in accordance with the contracting organization's Business Associate Agreement, applicable program requirements, and applicable federal and state law, in addition to the HIPAA obligations described in this Policy.
Security
We maintain comprehensive administrative, physical, and technical safeguards to protect the information we collect and maintain, including PHI and personally identifiable information ("PII"). Our security measures include:
- Encryption of PHI in transit and at rest
- Access controls limiting PHI access to authorized personnel only
- Regular workforce training on privacy and security obligations
- Incident response and breach notification procedures
- Business Continuity and Disaster Recovery planning
- Vendor management and Business Associate Agreement enforcement
No method of data transmission or storage is 100% secure. While we employ industry-standard security measures, we cannot guarantee absolute security. In the event of a security incident affecting your information, we will notify you as required by applicable law.
Retention of Information
We retain PHI and personal information for the minimum period necessary to fulfill the purposes for which it was collected and to comply with applicable legal, regulatory, and contractual obligations. Upon termination or expiration of a services agreement, we will return or securely dispose of all data as directed by the contracting provider organization and in accordance with HIPAA and applicable law.
Children's Privacy
Our nurse triage line serves patients of all ages, including minors. We collect health information about minors only in the course of providing triage services and only as necessary to assess and address the health concern for which the call was made. We comply with all applicable laws governing the privacy of minors' health information, including applicable state minor consent laws.
Our website is not directed to children under the age of 13 and we do not knowingly collect personal information from children under 13 through our website. If you believe we have inadvertently collected such information, please contact our Privacy Officer immediately.
State Privacy Rights
Oregon residents have additional rights under the Oregon Consumer Privacy Act (OCPA), ORS Chapter 646A, including the right to know what personal data we process, the right to correct inaccurate personal data, the right to delete personal data, the right to obtain a copy of personal data, and the right to opt out of certain processing activities. To exercise these rights, contact our Privacy Officer. Note that HIPAA-regulated PHI is governed by HIPAA rather than the OCPA.
Washington residents have additional rights under Washington's My Health MY Data Act (MHMD Act), RCW Chapter 70.372, with respect to consumer health data. We comply with all applicable requirements of the MHMD Act. Washington residents may contact our Privacy Officer to exercise rights under that law.
Our website may contain links to third-party websites. We are not responsible for the privacy practices of those websites and encourage you to review their privacy policies independently. Our website does not currently respond to Do Not Track signals. We do not track users across third-party websites.
General Provisions
Changes to this policy, governing law, severability, and how to reach us.
Changes to This Policy
We reserve the right to modify this Policy at any time. Material changes will be posted on our website with a revised effective date. Your continued use of our services following the posting of changes constitutes your acceptance of those changes. We encourage you to review this Policy periodically.
Governing Law
This Policy is governed by and construed in accordance with applicable federal law, including HIPAA, and applicable state law. The laws of the State of Washington govern matters related to our principal place of business, without regard to conflicts of law principles. Where services are delivered under a provider organization's program, the laws applicable to that organization and program may also apply.
Severability
If any provision of this Policy is found to be unenforceable, that provision will be modified to the minimum extent necessary to make it enforceable, and the remaining provisions will continue in full force and effect.
Contact Us
For questions, concerns, or to exercise any rights described in this Policy:
Questions about your privacy?
Vancouver, WA 98662-6191
Office for Civil Rights
This Privacy Policy was last reviewed and updated on May 16, 2026. Tulq Health Services, LLC reserves all rights not expressly granted herein.