Last Updated: June 17, 2024.
This Consumer Health Data Privacy Policy (“CHD Policy”) supplements the Bezos Academy Privacy Policy and is effective as of June 30, 2024. The Bezos Academy Privacy Policy describes the Personal Information that we collect and the sources from which we collect it. This CHD Policy is required by the My Health My Data Act (“MHMDA”) in Washington and applies only to Personal Information that may be considered “Consumer Health Data” under the MHMDA. Capitalized terms not otherwise defined shall have the meaning set forth in the Privacy Policy.
Categories of Consumer Health Data collected. As an educational provider, Bezos Academy may collect information that may be considered Consumer Health Data, such as:
- Individual health conditions, treatments, diseases, diagnoses, and prescribed medications, including without limitation student immunization records, allergies, health care provider contact, insurance information, and information related to individual care plans, student support plans, and reasonable accommodations;
- Social, physical, behavioral, and medical interventions, including without limitation student information related to individual care plans, student support plans, and reasonable accommodations;
- Health-related surgeries or procedures, including without limitation student information related to individual care plans, student support plans, and reasonable accommodations;
- Bodily functions, vital signs, or measurements of health information, including without limitation information related to an illness or injury at a Bezos Academy preschool or a school-related event;
- Observational information, including without limitation student behavioral notes, to the extent this may be considered consumer health data under MHMDA.
Purpose of collecting Consumer Health Data and how it may be used. We collect and use the categories of Consumer Health Data listed above to provide educational services. For example, we collect Consumer Health Data to ensure the health, safety, and well-being of students, to assist in the event of an emergency, to prepare individual care plans, student support plans, and reasonable accommodations, to comply with applicable law and regulations, to conduct internal audits of internal policies, to evaluate the effectiveness and impact of our educational services, to comply with our licensing requirements, and to communicate with you. We will not use Consumer Health Data for materially different, unrelated, or incompatible purposes without first disclosing such additional purposes and obtaining your consent.
Categories of Sources from which Consumer Health Data is collected. We obtain the categories of Consumer Health Data listed above from the following sources:
- Directly from you or your child. For example, when you share individual health and medical information during the enrollment process.
- Indirectly from you or your child. For example, we may collect a student’s temperature in our preschool.
- From government agencies. For example, a child protection agency may provide us with information regarding social interventions of children in our schools.
- From third parties. For example, HIPAA-regulated health care providers may share information about your child’s health with us (e.g., your physician sharing a medical record with us after obtaining your consent).
How Consumer Health Data may be disclosed. We do not sell Personal Information, including Consumer Health Data.
As described in our Privacy Policy, we share Personal Information, including Consumer Health Data, to the extent necessary to provide education services that you have requested from us. Such third parties include licensors, emergency personnel during a medical emergency, and Service Providers. Service Providers may have access to your Personal Information while they are performing their contractual obligations on our behalf, such as processing family applications and enrollment, sending family communications, and storing educational records. These Service Providers may have access to Consumer Health Data needed to perform their functions consistent with your consent or as necessary for us to provide educational services, and they may not use it for other purposes. We prohibit our Service Providers from selling, renting, or disclosing in an unauthorized manner the Personal Information we provide, and we require all Service Providers to maintain confidentiality standards to protect the security of your Personal Information.
In addition, we may disclose Personal Information, including Consumer Health Data, to third parties:
- if we have your consent to share the information; or
- in an anonymized or de-identified state as allowed by the MHMDA;
Security measures regarding Consumer Health Data. Bezos Academy restricts access to Consumer Health Data to only those employees, processors, or contractors for which access is necessary to further our provision of education services. We establish, implement, and maintain administrative, technical, and physical data security practices to protect the confidentiality, integrity, and accessibility in a manner consistent with the provision of early childhood education and other relevant factors as allowed by law.
How to exercise your rights related to Consumer Health Data. Bezos Academy offers choices to all our families that you can review in our Privacy Policy. In addition, if your Personal Information is covered by MHMDA, then you have the following rights:
- Right to Confirm and Access. You have the right to confirm whether we are collecting, sharing, or selling your Consumer Health Data and to access such data, including a list of all third parties and affiliates with whom we have shared your Consumer Health Data and an active email address or other online mechanism that you may use to contact these third parties and affiliates.
- Right to Withdraw Consent. You have the right to withdraw consent for Consumer Health Data collection and sharing.
- Right to Request Deletion. You have the right to have your Consumer Health Data deleted from our records.
To exercise your rights under MHMDA, please submit a request by emailing us at [email protected]. Certain Personal Information, including Consumer Health Data, is integral to the educational services we provide, and your restriction of our use of such information may result in us being unable to provide your child with educational services.
If you submit a data request, the law requires us to authenticate your identity. We will respond to your request within 45 days of its receipt. If we require more time (up to a total of ninety (90) days), we will inform you of the reason and the extension period in writing. If we are unable to authenticate your identity using commercially reasonable efforts, we are not required to comply and we may request additional information from you.
You are entitled to receive information in response to your request free of charge, up to twice per year. In case of requests that are manifestly unfounded, excessive, or repetitive, we may charge a reasonable fee to cover the administrative costs of complying with the request or decline to act on the request.
Only you, or a person that you authorize to act on your behalf, may submit a request to exercise your MHMDA rights. When a request is submitted by an authorized agent, we will require the requestor to: (i) provide the authorized agent’s written permission to do so; and (ii) verify their own identity directly with us. If we are unable to verify the identity of the requestor or if we do not receive proof from the authorized agent that the requestor authorized the agent to act on the requestor’s behalf, we will refuse to act on the request.
If you wish to appeal our refusal to act on your request, please email us at [email protected]. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, along with a written explanation of the reasons for our decisions.
Updates to this Consumer Health Data Disclosure. As our organization and educational services change, we may update this CHD Policy. If we make changes, we will update the date at the top of this Policy.