Notice of Privacy Practices

COMPASS CHW CORP · Compass CHW

Effective date: October 29, 2026

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.

If you have questions about this notice, contact our Privacy Officer at privacy@joincompasschw.com or (213) 232-8251.

Who we are and what this notice covers

Compass CHW Corp (“Compass,” “we,” or “us”) arranges community health worker (CHW) services for Medi-Cal members in California, through independent CHWs who contract with Compass, and provides the Compass app. Because we bill Medi-Cal for those services, we are a health care provider covered by the Health Insurance Portability and Accountability Act (HIPAA), and we protect your health information as HIPAA and the California Confidentiality of Medical Information Act (CMIA) require.

This notice covers your protected health information: information that identifies you and relates to your health, the services you receive from a CHW through Compass, or payment for those services. Examples include your name and contact details, your Medi-Cal number, the services you ask for, your CHW’s session notes, session recordings and transcripts you agreed to, and billing records.

This notice applies to Compass, our employees, and the independent CHWs who provide services through Compass. Our Privacy Policy (joincompasschw.com/legal/privacy) explains how we handle other personal information, such as website and app usage.

Our duties

The law requires us to:

Keep your protected health information private and secure.
Give you this notice of our legal duties and privacy practices.
Follow the notice that is currently in effect.
Tell you promptly if a breach occurs that may have compromised the privacy or security of your information.

We will not use or share your information other than as described in this notice unless you tell us we can in writing. You can change your mind at any time by letting us know in writing.

To provide your services. We share your information with the CHW who works with you so they can help you and document your sessions. With your agreement, your CHW may refer you to a community organization, such as a food bank, and you choose what details to share with that organization. Example: your CHW sees the services you asked for and your earlier session notes before your next visit.

To get paid for your services. CHW services are a Medi-Cal benefit, and you do not pay for them. We never bill you or ask you to pay. To get paid by Medi-Cal, we share your information with our billing partner, Pear Suite, and with Medi-Cal and your Medi-Cal health plan to check your eligibility and bill for the services you receive. Example: after a session, we send the date, length and type of service to Pear Suite, which bills your health plan.

To run our organization. We use your information to check the quality of our services, make training available to CHWs, prevent fraud, and meet audit requirements. Example: we review session notes to make sure services are documented accurately.

To remind you and keep in touch. We may contact you about visits, sign-in codes, and new messages from your CHW by app notification, email, phone, or, if you agreed, text message. Texts do not include your CHW’s messages or other health details.

With our business associates. We use companies that help us run our services, such as cloud hosting, phone and text messaging, transcription, and AI tools that draft session summaries for your CHW to review. Each one must sign a contract (a business associate agreement) that requires it to protect your information and use it only for the work it does for us. Our AI service providers may not use your information to train their models.

With people involved in your care. We may share information with a family member, friend, or other person you name who is involved in your care or helps pay for it, unless you tell us not to. If you are not able to tell us your preference, for example in an emergency, we may share information if we believe it is in your best interest.

We may share your information without your written permission in these situations, only as the law allows and only as much as needed:

When the law requires it, including to the U.S. Department of Health and Human Services if it wants to see that we are complying with federal privacy law.
For public health and safety, such as preventing disease or reporting suspected abuse, neglect, or domestic violence.
To prevent a serious threat to your health or safety, or someone else’s.
For health oversight, such as audits and investigations by Medi-Cal, the California Department of Health Care Services, or other agencies that oversee health care.
In lawsuits and legal actions, in response to a court order, or to a subpoena when the law’s conditions are met.
For law enforcement, in limited situations the law allows, but never for immigration enforcement without a court order or a judge’s warrant (see the next section).
For workers’ compensation and other government programs, as the law allows.
To a coroner, medical examiner, or funeral director, and for organ and tissue donation.
For research, only when the law’s privacy protections are met.
For special government functions, such as military, national security, and correctional settings.

California law gives you more protection. Where California law, such as the CMIA, is stricter than HIPAA, we follow California law. This includes extra protection for certain sensitive information, such as mental health, HIV test results, and substance use treatment information.

Immigration enforcement

We know many people worry about this, so here is exactly what we do.

We do not share your information with immigration authorities, including U.S. Immigration and Customs Enforcement (ICE), unless a federal or California court orders us to or we receive a valid warrant signed by a judge. A request, a subpoena, or an administrative warrant from an immigration agency is not enough. California law (Civil Code § 56.10, as amended by SB 81 in 2025) requires this.
If we receive a demand, we will review it with a lawyer, challenge it when we can, share only the minimum the order requires, and tell you about it unless the law forbids us.
We do not ask for or record your immigration status or place of birth. Your CHW does not need this to help you. California law treats this information as medical information and protects it.
CHWs who work through Compass agree not to let immigration agents into a visit or share your information with them, and to contact Compass if an agent asks.

Compass can only control the information Compass holds. Information that Medi-Cal, your health plan, or other government agencies hold about you is covered by their own policies and by federal and state law.

Uses that need your written permission

We will never do the following without your written permission:

Use or share your information for marketing.
Sell your information.
Share psychotherapy notes. We do not keep these, but the rule still applies.

Any other use or sharing not described in this notice also needs your written permission. You may cancel your permission at any time in writing, except for anything we already did in reliance on it.

Recording a session, using AI tools to transcribe or summarize it, and receiving text messages are each optional. We ask for your agreement first, and you can say no and still receive services.

Your rights

You have the right to:

See and get a copy of your health information, on paper or electronically. Ask us in writing. We will respond within 30 days, and we may charge a reasonable, cost-based fee.
Ask us to correct your information if you think it is wrong or incomplete. Ask in writing and tell us why. We may say no, but we will explain why in writing within 60 days.
Ask us to contact you in a certain way or place, for example only by email, or at a different address. We will say yes to all reasonable requests.
Ask us to limit what we use or share. We are not required to agree, except in one case: if you pay for a service out of pocket in full, you can ask us not to share information about that service with your health plan, and we will agree unless the law requires us to share it. Because members do not pay for Compass CHW services, this rarely applies.
Get a list of who we shared your information with (an accounting of disclosures) for up to six years before your request, other than disclosures for your services, payment, and our operations, and certain others. One list a year is free.
Get a paper copy of this notice at any time, even if you agreed to get it electronically.
Choose someone to act for you, such as a legal guardian or a person you give medical power of attorney. We will check that the person has the authority before we act.
Be told about a breach that affects your information.
File a complaint if you think your rights were violated (see below).

To use any of these rights, contact our Privacy Officer using the information at the end of this notice.

Complaints

If you believe your privacy rights have been violated, you can complain to us or to the federal government. We will not take any action against you for filing a complaint.

To Compass: Privacy Officer, privacy@joincompasschw.com, (213) 232-8251, or by mail at the address below.
To the U.S. Department of Health and Human Services, Office for Civil Rights: 200 Independence Avenue SW, Washington, DC 20201; 1-877-696-6775; or online at www.hhs.gov/ocr/privacy/hipaa/complaints/.

Changes to this notice

We may change this notice, and the changes will apply to all information we have about you. The new notice will be posted at joincompasschw.com/legal/hipaa and in the Compass app, and a copy is available from us on request.

Language and accessibility

This notice is available in Spanish and in other formats. Ask your CHW or contact us. Este aviso está disponible en español. Pídalo a su trabajador comunitario de salud o escríbanos.

Contact us

Compass CHW Corp, Attn: Privacy Officer
Jemal Hussein, Privacy Officer
3701 Santa Rosalia Dr., Suite 1200, Los Angeles, CA 90008
privacy@joincompasschw.com · (213) 232-8251