Compliance

about-usGranger Genetics is committed to maintain compliance with applicable legal and ethical standards. The success of Granger Genetics compliance efforts depends on the dedication of each employee or other agent to work with the company to implement and adhere to the Compliance Program.

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Employees and others have the freedom to communicate compliance-related questions or concerns in person, by telephone, or through e-mail or other written correspondence. Any of these methods may be used to communicate with the Director of Compliance at any time, whether to report a suspected violation or to request guidance on a compliance issue.

No employee or other agent, contract worker, customer, vendor, or other person who does business with this organization is exempt from the requirements contained in the compliance policy which includes but is not limited to:

  • Achieving a culture of uncompromising integrity which is characterized by strict adherence to all federal, state, and local laws and regulations applicable to Granger Genetics’s business operations.
  • Full compliance with laws prohibiting fraud and abuse, (the federal False Claims Act, federal Anti-Kickback Statute, the Stark Law, and similar state laws).
  • Employees, directors, officers and other agents such as contracted representatives must not present or cause to be presented any false or fraudulent claims for payment.
  • Granger Genetics will submit claims for reimbursement to state and federal health care programs only if the ordering physician has signed for the test request indicating medically necessary services.
  • Granger Genetics expects all employees, directors, and officers and other agents to conduct business on its behalf in strict adherence with the laws and ethical standards applicable to the company’s business practices, without regard to personal considerations.
  • Employees, directors, and officers and other agents should never solicit gifts or any other personal benefit or favor of any kind from any individual or company doing business with Granger Genetics in exchange for, or as a reward or inducement for, business or for recommending or arranging for business to be referred to Granger Genetics.
  • All interactions with health care professionals and their staff on behalf of the Company must be professional exchanges meant to provide education about Granger Genetics’s test offerings and the benefits they offer to professionals and patients.
  • Granger Genetics does not employ or contract with individuals who or entities that are prohibited from doing business with any state or federal agency. OIG is checked on a routine basis for exclusions.
  • Employees, directors, and officers and other agents must comply with state and federal laws and regulations, including the Health Insurance Portability and Accountability Act (known as “HIPAA”), governing the privacy and security of patient information.
  • Employees, directors, and officers and other agents are prohibited from offering any gift or other item of value to a health care professional.
  • Granger Genetics does not offer professional courtesy testing to HCPs, family members of HCPs or employees of HCPs. Testing services provided to HCPs, family members of HCPs or employees of HCPs must be billed to the patient or to the patient’s insurer in accordance with normal pricing and billing practices.
  • Employees, directors, and officers and other agents are prohibited from offering processing and handling fees to a health care professional for processing of paperwork, sample preparation, sample mailing and/or other trivial task associated with submission of a sample

Privacy Policies

Granger Genetics is committed to protecting the privacy of your personal and health information. At Granger Genetics, we understand that health is a very personal, private subject, and we want you to feel as comfortable as possible visiting our web site and using our services. Granger Genetics takes this responsibility very seriously.

Our Online Privacy Policy describes what information we collect online, how we protect it and what choices you have about how that information is used. We urge you to read this Online Privacy Policy carefully so that you will understand both our commitment to you and your privacy, and how you can participate in that commitment. Should you have any questions about this policy or our privacy practices, please send an email to privacy@grangergenetics.com or write to us at:

Granger Genetics
Data Privacy and Security Officer
601 Biotech Drive Suite 301
Richmond, VA 23235

Information Collection and Use


Granger Genetics ("Us" or "We") is the sole owner of information collected on this site. We will not sell, share, or rent this information to any third parties, except as outlined in this policy. We will collect information that identifies you ("personal information") online only when you voluntarily provide it to us through our site. For example, when you choose to register on our site for our newsletter, we may ask you to provide some personal information, such as your first and last name, mailing address, telephone number and/or e-mail address. We also may collect information that will allow you to establish a username and password. In addition, we may collect information that you voluntarily provide to us through responses to questionnaires, such as customer satisfaction surveys or employment opportunities with Granger Genetics. If you elect to receive our newsletter, surveys or employment opportunities, your contact information will be used for the delivery of these items. However, if you elect not to receive newsletters, surveys or employment opportunities, we may still periodically send other transactional communications to you that contain client relationship information. This includes, for example, informational e-mails regarding changes in our policies, changes in our methods of conducting business or requesting that you review the information we have on file for you or the options that you have previously selected regarding your transactions with us.

We may also gather or receive information on you from third party sources, such as marketing databases made available for commercial purchase. Our use of such information will comply with applicable law, the limitations imposed by the third party on us in connection with our receipt of such information from such third party sources, but not necessarily this privacy statement.

Cookies


In order to provide better service, Granger Genetics may use a "cookie." Cookies are small files that your Web browser places on your computer's hard drive. We may use cookies to let us know that you are a prior customer and to retrieve certain information previously provided by you. We also may use cookies to keep track of information about your current "session" which will be discarded as soon as you log out or close your Web browser. This information also allows us to statistically monitor how many people are using our site and for what purpose.

This privacy statement covers the use of cookies by Granger Genetics only and does not cover the use of cookies by any advertisers.

Log Files


We use IP addresses to analyze trends, administer the site, track user movement, and gather broad demographic information for aggregate use. We do not link IP addresses to personally identifiable information, and we do not distribute or share IP information with any third parties.

Sharing


We may employ third party companies to perform functions on our behalf. These functions may include order fulfillment, package delivery, marketing assistance, postal and e-mail delivery, client service, data analysis, and credit processing. The third parties we contract for these purposes have limited access to your personal information and may not use it for other purposes. Among such third parties are the two referenced immediately below.

FedEx Corporation
942 South Shady Grove Road
Memphis, TN 38120
United States
www.fedex.com

US Postal Service Headquarters
475 L'Enfant Plaza, SW
Washington DC
1-800-ASK-USPS
www.usps.com

As our business continues to evolve, we may acquire or sell business units or subsidiaries. Customer information is one of the business assets that would be transferred in these types of transactions. In such a situation, your personally identifiable information would only be used in a manner consistent with our pre-existing Privacy Notice.

Be aware that when you volunteer information or create a public profile in the course of your participation in our community features such as forums, user opinions and reviews, chat rooms, photo sharing or other forms of public communication and interaction, you are also agreeing to allow certain aspects of your personally identifiable information to be made public. This includes your screen name, any address or personal information or images that you add to your signature or otherwise post to the public, and any content of any such post.

Links


This website contains links to other sites. Please be aware that Granger Genetics.com is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies only to information collected by this website.

Security


Access to all of our users' information is restricted. Granger Genetics operates in a secured and locked facility that requires all employees to check in and wear valid ID badges. Security cameras are positioned throughout the building in conjunction with multiple alarm systems. Only employees who need the information to perform a specific job are granted access to personally identifiable information.

All Granger Genetics servers, including web servers and database servers, are housed and maintained in secure locations. Access to the database is strictly monitored and protected from outside access. Internet access is restricted and protected by multiple firewalls. The servers on which we store personally identifiable information are kept in a secured environment, inside a secured and locked room. All backups are stored and locked in a high-level security room. Only personnel with proper security clearance have access to these restricted areas.

If you have any questions or concerns about Granger Genetics security practices, you can send us an e-mail at info@grangergenetics.com.

Notification of Changes


If we decide to change our Privacy Policy, we will post those changes to this privacy statement, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by e-mail, or by means of a notice on our home page.

Last Update


The Privacy Policy contained herein became officially effective 10-24-2011.

Granger Genetics
601 Biotech Drive Suite 301
Richmond, VA 23235

(V1.03 10-24-2011)
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

The Health Insurance Portability and Accountability Act (HIPAA; “Act”) of 1996, revised in 2013, requires us as your health care provider to maintain the privacy of your protected health information, to provide you with notice of our legal duties and privacy practices with respect to protected health information, and to notify affected individuals following a breach of unsecured protected health information. We are required to maintain these records of your health care and to maintain confidentiality of these records.

The Act also allows us to use your information for treatment, payment, and certain health operations unless otherwise prohibited by law and without your authorization.

  • Treatment: We may disclose your protected health information to you and to our staff or to other health care providers in order to get you the care you need. This includes information that may go to the pharmacy to get your prescription filled, to a diagnostic center to assist with your diagnosis, or to the hospital should you need to be admitted. If necessary to ensure that you get this care, we may also discuss the minimum necessary with friends or family members involved in your care unless you request otherwise.

  • Payment: We may send information to you or to your health plan in order to receive payment for the service or item we delivered. We may discuss the minimum necessary with friends or family members involved in your payment unless you request otherwise.

  • Health operations: We are allowed to use or disclose your protected health information to train new health care workers, to evaluate the health care delivered, to improve our business development, or for other internal needs.

  • We are required to disclose information as required by law, such as public health regulations, health care oversight activities, certain law suits and law enforcement.

Certain ways that your protected health information could be used disclosed require an authorization from you: disclosure of psychotherapy notes, use or disclosure of your information for marketing, disclosures or uses that constitute a sale of protected health information, and any uses or disclosures not described in this NPP. We cannot disclose your protected health information to your employer or to your school without your authorization unless required by law. You will receive a copy of your authorization and may revoke the authorization in writing. We will honor that revocation beginning the date we receive the written signed revocation.

You have several rights concerning your protected health information. When you wish to use one of these rights, please inform our office so that we may give you the correct form for documenting your request.

  • You have the right to access your records and/or to receive a copy of your records, with the exception of psychotherapy notes. Your request must be in writing, and we must verify your identity before allowing the requested access. We are required to allow the access or provide the copy within 30 days of your request. We may provide the copy to you or to your designee in an electronic format acceptable to you or as a hard copy. We may charge you our cost for making and providing the copy. If your request is denied, you may request a review of this denial by a licensed health care provider.

  • You have the right to request restrictions on how your protected health information is used for treatment, payment, and health operations. For example, you may request that a certain friend or family member not have access to this information. We are not required to agree to this request, but if we agree to your request, we are obligated to fulfill the request, except in an emergency where this restriction might interfere with your care. We may terminate these restrictions if necessary to fulfill treatment and payment.

  • We are required to grant your request for restriction if the requested restriction applies only to information that would be submitted to a health plan for payment for a health care service or item for which you have paid in full out-of-pocket, and if the restriction is not otherwise forbidden by law. For example, we are required to submit information to federal health plans and managed care organizations even if you request a restriction. We must have your restriction documented prior to initiating the service. Some exceptions may apply, so ask for a form to request the restriction and to get additional information. We are not required to inform other covered entities of this request, but we are not allowed to use or disclose information that has been restricted to business associates that may disclose the information to the health plan.

  • You have the right to request confidential communications. For example, you may prefer that we call your cell phone number rather than your home phone. These requests must be in writing, may be revoked in writing, and must give us an effective means of communication for us to comply. If the alternate means of communications incurs additional cost, that cost will be passed on to you.

  • Your medical records are legal documents that provide crucial information regarding your care. You have the right to request an amendment to your medical records, but you must make this request in writing and understand that we are not required to grant this request.

  • You have the right to an accounting of disclosures. This will tell you how we have used or disclosed your protected health information. We are required to inform you of a breach that may have affected your protected health information.

  • You have the right to receive a copy of this notice, either electronic or paper or both.

  • You have the right to opt out of fund raising communications.

If you have any questions about our privacy practices, please contact our Privacy Officer at the number below. You have the right to file a complaint with us or with the Office for Civil Rights. We will not discriminate or retaliate in any way for this action. To file a complaint, please contact the applicable party:

Privacy Officer
Phone number: 804 915 3845
Fax number: 804 648 2641

Office for Civil Rights
http://www.hhs.gov/ocr/privacy/hipaa/complaints/index.html
We are required to abide by the policies stated in this Notice of Privacy Practices, which became effective on 20SEP2013.
Granger Genetics carefully protects the confidentiality of personal information provided to it by consumers, employees, healthcare professionals and business partners. Granger Genetics values the confidence of its consumers, employees, healthcare professionals and business partners. Granger Genetics will not release personal information to third parties about employees, potential employees, and their family members, contractors and contingent workers, scientific and medical research subjects, scientific and medical investigators and staff, service providers and business partners, investors and shareholders, medical and healthcare professionals, customers, suppliers, vendors, government officials, industry experts and opinion leaders for purposes other than providing services which have been agreed or to comply with applicable legal requirements. Granger Genetics is committed to upholding best practice in our use, collection and disclosure of personal information.

Granger Genetics complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Granger Genetics has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Granger Genetics' certification, please visit http://www.export.gov/safeharbor/

Safe Harbor

The United States Department of Commerce the European Commission and the Swiss Federal Data Protection and Information Commissioner have agreed on a set of data protection principles and frequently asked questions (the “Safe Harbor Principles”) to enable U.S. companies to satisfy the requirement under European Union and Swiss law that adequate protection is given to personal information transferred from the EU or Switzerland to the United States. The EU and Switzerland have also recognized the U.S. Safe Harbor as providing adequate data protection. Granger Genetics is committed to protecting personal privacy and adheres to the seven Safe Harbor principles.

Scope

This Safe Harbor Privacy Policy (the “Policy”) applies to all personal information received by Granger Genetics in the United States of America from the EU and Switzerland, in any form including electronic, paper or verbal.

Definitions

For purposes of this Policy, the following definitions shall apply:

  • "Agent" means any third party that collects or uses personal information under the instructions of Granger Genetics or to which Granger Genetics discloses personal information for use on Granger Genetics's behalf. These third parties are most commonly: employee payroll, employee benefits, distribution and billing partners.

  • "Granger Genetics" means Granger Genetics, American International Biotechnology LLC, its successors, affiliates, subsidiaries, divisions and groups in the United States of America and Switzerland.

  • "Personal information" means any information or set of information that identifies or is used by or on behalf of Granger Genetics to identify an individual in the context of providing Granger Genetics's services. Personal information does not include information that is encoded or anonymized.

  • "Sensitive personal information" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. Granger Genetics will treat any information received from a third party as sensitive personal information where that third party treats and identifies the information as sensitive personal information.

Privacy Principles

The privacy principles in this Policy are based on the Safe Harbor Principles.

Notice: Where Granger Genetics collects personal information directly from individuals (such as employees or customers) in the EU or Switzerland, it will inform them about the purposes for which it collects and uses such personal information and the type of Agents to which it discloses such information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Granger Genetics, or as soon as practicable thereafter, and in any event before Granger Genetics uses or discloses the information for a purpose other than that for which it was originally collected.

Where Granger Genetics receives personal information from its subsidiaries, affiliates or other entities in the EU or Switzerland, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals in respect of their personal information.

  • Choice: Granger Genetics does not use personal information for purposes other than which it was collected, i.e., the provision of Granger Genetics services. Such information is not disclosed to non-agent third parties.

  • Transfers To Agents: Granger Genetics most commonly transfers personal information to agents who are subject to the HIPAA Privacy Rule. As such they must safeguard personal information in a way that is consistent with the HIPAA Privacy Rule and the terms of this Policy. In the event that information is transferred to agents who are not subject to the HIPAA Privacy Rule appropriate assurances will be sought from these agents. These may include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Switzerland). Where Granger Genetics has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Granger Genetics will take all reasonable steps to prevent that use or disclosure.

  • Security: Granger Genetics will take all reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access. In addition, Granger Genetics will take all reasonable steps to prevent unauthorized disclosure, alteration and destruction of personal information.

  • Data Integrity: Granger Genetics will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Granger Genetics will take all reasonable steps to ensure that personal information is relevant to its intended use and is accurate, complete, and up-to-date and does so in order to provide the very best services.

  • Access And Correction: Upon request, Granger Genetics will grant individuals reasonable access to personal information that it holds about them. This consists mainly of information received from third parties. In addition, Granger Genetics will take reasonable steps to permit individuals to correct, amend, or delete information that is inaccurate or incomplete with the relevant third party. Granger Genetics is unable to correct anything other than factual errors in any report Granger Genetics produce for its consumers because it is based on information provided by third parties. However,Granger Genetics will take all reasonable steps to facilitate amendments to information provided by third parties if an individual raises a query.

  • Enforcement: Granger Genetics will conduct compliance audits of its relevant privacy practices, for example its information systems and data processing installations, to verify adherence to this Policy. Any employee that Granger Genetics determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

  • Dispute Resolution: Any questions or concerns regarding the use or disclosure of personal information should be directed to the Granger Genetics Privacy Officer at the address given below. Granger Genetics will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between Granger Genetics and the complainant, Granger Genetics has agreed to use the American Arbitration Association, as an independent dispute resolution mechanism that agrees to hear each complaint in compliance with the Framework(s).

Training

Granger Genetics has provided its employees with appropriate training to ensure that all individuals who process personal information are fully aware of their responsibility with respect to data protection.

Limitation On Application Of Principles

Adherence by Granger Genetics to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; and (b) to the extent expressly permitted by an applicable law, rule or regulation.

Internet Privacy

Granger Genetics sees the internet and the use of other technologies as valuable tools for communicating and interacting with consumers, employees, healthcare professionals, business partners, and others. Granger Genetics recognizes the importance of maintaining the privacy of information collected and/or stored online and has systems in place that protect data collected and/or stored online or via an electronic database. Personal information that is transferred from the EU or Switzerland to the United States of America will be treated in accordance with this policy.

Contact Information

Questions or comments regarding this Policy should be submitted to the Granger Genetics Privacy Officer by mail as follows:

Granger Genetics
ATTN: Privacy Officer
601 Biotech Drive Suite 301
Richmond, VA 23235
Email: info@grangergenetics.com


Changes To This Safe Harbor Privacy Policy

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. If we make changes to this Policy, we will promptly post a copy of the updated Policy on our website. A notice will be posted on the Granger Genetics web site www.grangergenetics.com whenever this Safe Harbor Privacy Policy is changed in a material way.