Note this is a NPP that reflects Omnibus changes as of March 2013

Atlantic Family Dental

NOTICE OF PRIVACY PRACTICES
Effective Date: 09/23/2013
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
Secti!n A" W#! Will F!ll!$ T#i% N!tice&
This Notice describesAtlantic Family Dental hereafter referred to as !"rovider#$ "rivacy "ractices and that of: Any %or&force member a'thori(ed to create medical information referred to as "rotected
)ealth *nformation ")*$ %hich may be 'sed for +'r+oses s'ch as Treatment, "ayment and )ealthcare -+erations. These %or&force members may incl'de:
All de+artments and 'nits of the "rovider.
Any member of a vol'nteer /ro'+.
All em+loyees, staff and other "rovider +ersonnel.
Any entity +rovidin/ services 'nder the "rovider0s direction and control %ill follo% the terms of this notice. *n addition, these entities, sites and locations may share medical information %ith each other for
Treatment, "ayment or )ealthcare -+erational +'r+oses described in this Notice.
Secti!n B" O'( Ple)*e Re*a()in* Me)ical In+!(mati!n
1e 'nderstand that medical information abo't yo' and yo'r health is +ersonal. 1e are committed to +rotectin/ medical information abo't yo'. 1e create a record of the care and services yo' receive
at the "rovider. 1e need this record to +rovide yo' %ith 2'ality care and to com+ly %ith certain le/al re2'irements. This Notice a++lies to all of the records of yo'r care /enerated or maintained by the "rovider,
%hether made by "rovider +ersonnel or yo'r +ersonal doctor.
This Notice %ill tell yo' abo't the %ays in %hich %e may 'se and disclose medical information abo't yo'. 1e also describe yo'r ri/hts and certain obli/ations %e have re/ardin/ the 'se and disclos're of medical
information. 1e are re2'ired by la% to:
3a&e s're that medical information that identifies yo' is &e+t +rivate4
5ive yo' this Notice of o'r le/al d'ties and +rivacy +ractices %ith res+ect to medical information abo't yo'4 and
Follo% the terms of the Notice that is c'rrently in effect.
Secti!n C" H!$ We May U%e an) Di%cl!%e Me)ical In+!(mati!n A,!'t Y!'
The follo%in/ cate/ories describe different %ays that %e 'se and disclose medical information. For each cate/ory of 'ses or disclos'res %e %ill e6+lain %hat %e mean and try to /ive some e6am+les.
Not every 'se or disclos're in a cate/ory %ill be listed. )o%ever, all of the %ays %e are +ermitted to 'se and disclose information %ill fall %ithin one of the cate/ories.
T(eatment 1e may 'se medical information abo't yo' to +rovide yo' %ith medical treatment or services. 1e may disclose medical information abo't yo' to doctors, n'rses, technicians, health care
st'dents, or other "rovider +ersonnel %ho are involved in ta&in/ care of yo' at the "rovider. For e6am+le, a doctor treatin/ yo' for a bro&en le/ may need to &no% if yo' have diabetes beca'se diabetes may slo%
the healin/ +rocess. *n addition, the doctor may need to tell the dietitian if yo' have diabetes so that %e can arran/e for a++ro+riate meals. Different de+artments of the "rovider also may share medical information
abo't yo' in order to coordinate different items, s'ch as +rescri+tions, lab %or& and 67rays. 1e also may disclose medical information abo't yo' to +eo+le o'tside the "rovider %ho may be involved in yo'r medical
care after yo' leave the "rovider.
Payment 1e may 'se and disclose medical information abo't yo' so that the treatment and services yo' receive at the "rovider may be billed and +ayment may be collected from yo', an ins'rance
com+any or a third +arty. For e6am+le, %e may need to /ive yo'r health +lan information abo't s'r/ery yo' received at the "rovider so yo'r health +lan %ill +ay 's or reimb'rse yo' for the +roced're. 1e may also
tell yo'r health +lan abo't a +rescribed treatment to obtain +rior a++roval or to determine %hether yo'r +lan %ill cover the treatment.
Healt#ca(e O-e(ati!n% 1e may 'se and disclose medical information abo't yo' for "rovider o+erations. These 'ses and disclos'res are necessary to r'n the "rovider and ma&e s're that all of o'r
+atients receive 2'ality care. For e6am+le, %e may 'se medical information to revie% o'r treatment and services and to eval'ate the +erformance of o'r staff in carin/ for yo'. 1e may also combine medical
information abo't many "rovider +atients to decide %hat additional services the "rovider sho'ld offer, %hat services are not needed, and %hether certain ne% treatments are effective. 1e may also disclose
information to doctors, n'rses, technicians, health care st'dents, and other "rovider +ersonnel for revie% and learnin/ +'r+oses. 1e may also combine the medical information %e have %ith medical information
from other "roviders to com+are ho% %e are doin/ and see %here %e can ma&e im+rovements in the care and services %e offer. 1e may remove information that identifies yo' from this set of medical information
so others may 'se it to st'dy health care and health care delivery %itho't learnin/ a +atient0s identity.
A--!intment Remin)e(% 1e may 'se and disclose medical information to contact yo' as a reminder that yo' have an a++ointment for treatment or medical care at the "rovider.
T(eatment Alte(nati.e% 1e may 'se and disclose medical information to tell yo' abo't or recommend +ossible treatment o+tions or alternatives that may be of interest to yo'.
Healt#/Relate) Bene+it% an) Se(.ice% 1e may 'se and disclose medical information to tell yo' abo't health7related benefits or services that may be of interest to yo'.
F'n)(ai%in* Acti.itie% 1e may 'se information abo't yo' to contact yo' in an effort to raise money for the "rovider and its o+erations. 1e may disclose information to a fo'ndation related to the "rovider
so that the fo'ndation may contact yo' abo't raisin/ money for the "rovider. 1e only %o'ld release contact information, s'ch as yo'r name, address and +hone n'mber and the dates yo' received treatment or
services at the "rovider. *f yo' do not %ant the "rovider to contact yo' for f'ndraisin/ efforts, yo' m'st notify 's in %ritin/ and yo' %ill be /iven the o++ort'nity to !-+t7o't# of these comm'nications.
A't#!(i0ati!n% Re1'i(e) 1e %ill not 'se yo'r +rotected health information for any +'r+oses not s+ecifically allo%ed by Federal or 8tate la%s or re/'lations %itho't yo'r %ritten a'thori(ation, this incl'des
'ses of yo'r ")* for mar&etin/ or sales activities.
Eme(*encie% 1e may 'se or disclose yo'r medical information if yo' need emer/ency treatment or if %e are re2'ired by la% to treat yo' b't are 'nable to obtain yo'r consent. *f this ha++ens, %e %ill try to
obtain yo'r consent as soon as %e reasonably can after %e treat yo'.
P%yc#!t#e(a-y N!te% "sychothera+y notes are accorded strict +rotections 'nder several la%s and re/'lations. Therefore, %e %ill disclos're +sychothera+y notes only '+on yo'r %ritten a'thori(ation %ith
limited e6ce+tions.
C!mm'nicati!n Ba((ie(% 1e may 'se and disclose yo'r health information if %e are 'nable to obtain yo'r consent beca'se of s'bstantial comm'nication barriers, and %e believe yo' %o'ld %ant 's to
treat yo' if %e co'ld comm'nicate %ith yo'.
P(!.i)e( Di(ect!(y 1e may incl'de certain limited information abo't yo' in the "rovider directory %hile yo' are a +atient at the "rovider. This information may incl'de yo'r name, location in the "rovider,
yo'r /eneral condition e./., fair, stable, etc.$ and yo'r reli/io's affiliation. The directory information, e6ce+t for yo'r reli/io's affiliation, may also be released to +eo+le %ho as& for yo' by name. 9o'r reli/io's
affiliation may be /iven to a member of the cler/y, s'ch as a +riest or rabbi, even if they do not as& for yo' by name. This is so yo'r family, friends and cler/y can visit yo' in the "rovider and /enerally &no% ho%
yo' are doin/.
In)i.i)'al% In.!l.e) in Y!'( Ca(e !( Payment +!( Y!'( Ca(e 1e may release medical information abo't yo' to a friend or family member %ho is involved in yo'r medical care and %e may also
/ive information to someone %ho hel+s +ay for yo'r care, 'nless yo' ob:ect in %ritin/ and as& 's not to +rovide this information to s+ecific individ'als. *n addition, %e may disclose medical information abo't yo' to
an entity assistin/ in a disaster relief effort so that yo'r family can be notified abo't yo'r condition, stat's and location.
Re%ea(c# ;nder certain circ'mstances, %e may 'se and disclose medical information abo't yo' for research +'r+oses. For e6am+le, a research +ro:ect may involve com+arin/ the health and recovery of all
+atients %ho received one medication to those %ho received another, for the same condition. All research +ro:ects, ho%ever, are s'b:ect to a s+ecial a++roval +rocess. This +rocess eval'ates a +ro+osed research
+ro:ect and its 'se of medical information, tryin/ to balance the research needs %ith +atients0 need for +rivacy of their medical information. <efore %e 'se or disclose medical information for research, the +ro:ect %ill
have been a++roved thro'/h this research a++roval +rocess, b't %e may, ho%ever, disclose medical information abo't yo' to +eo+le +re+arin/ to cond'ct a research +ro:ect, for e6am+le, to hel+ them loo& for
+atients %ith s+ecific medical needs, so lon/ as the medical information they revie% does not leave the "rovider. 1e %ill almost al%ays /enerally as& for yo'r s+ecific +ermission if the researcher %ill have access to
yo'r name, address or other information that reveals %ho yo' are, or %ill be involved in yo'r care at the "rovider.
A% Re1'i(e) By La$ 1e %ill disclose medical information abo't yo' %hen re2'ired to do so by federal, state or local la%.
T! A.e(t a Se(i!'% T#(eat t! Healt# !( Sa+ety 1e may 'se and disclose medical information abo't yo' %hen necessary to +revent a serio's threat to yo'r health and safety or the health and safety
of the +'blic or another +erson. Any disclos're, ho%ever, %o'ld only be to someone able to hel+ +revent the threat.
E/mail U%e E7mail %ill only be 'sed follo%in/ this -r/ani(ation#s c'rrent +olicies and +ractices and %ith yo'r +ermission. The 'se of sec'red, encry+ted e7mail is enco'ra/ed.
Secti!n D" S-ecial Sit'ati!n%
O(*an an) Ti%%'e D!nati!n *f yo' are an or/an donor, %e may release medical information to or/ani(ations that handle or/an +roc'rement or or/an, eye or tiss'e trans+lantation or to an or/an donation
ban&, as necessary to facilitate or/an or tiss'e donation and trans+lantation.
Milita(y an) Vete(an% *f yo' are a member of the armed forces, %e may release medical information abo't yo' as re2'ired by military command a'thorities. 1e may also release medical information
abo't forei/n military +ersonnel to the a++ro+riate forei/n military a'thority.
W!(2e(%3 C!m-en%ati!n 1e may release medical information abo't yo' for %or&ers0 com+ensation or similar +ro/rams.
P',lic Healt# Ri%2% 1e may disclose medical information abo't yo' for +'blic health activities. These activities /enerally incl'de the follo%in/:
o to +revent or control disease, in:'ry or disability4
o to re+ort births and deaths4
o to re+ort child ab'se or ne/lect4
o to re+ort reactions to medications or +roblems %ith +rod'cts4
o to notify +eo+le of recalls of +rod'cts they may be 'sin/4
o to notify a +erson %ho may have been e6+osed to a disease or may be at ris& for contractin/ or s+readin/ a disease or condition4 and
o to notify the a++ro+riate /overnment a'thority if %e believe a +atient has been the victim of ab'se, ne/lect or domestic violence. 1e %ill only ma&e this disclos're if yo' a/ree or %hen re2'ired or
a'thori(ed by la%.
Healt# O.e(%i*#t Acti.itie% 1e may disclose medical information to a health oversi/ht a/ency for activities a'thori(ed by la%. These oversi/ht activities incl'de, for e6am+le, a'dits, investi/ations,
ins+ections, and licens're. These activities are necessary for the /overnment to monitor the health care system, /overnment +ro/rams, and com+liance %ith civil ri/hts la%s.
"a/e 1 of 2 =o+yri/ht > 2013 8tericycle, *nc. All ri/hts reserved. )*"AA =om+liance "ro/ram


La$%'it% an) Di%-'te% *f yo' are involved in a la%s'it or a dis+'te, %e may disclose medical information abo't yo' in res+onse to a co'rt or administrative order. 1e may also disclose medical
information abo't yo' in res+onse to a s'b+oena, discovery re2'est, or other la%f'l +rocess by someone else involved in the dis+'te, b't only if efforts have been made to tell yo' abo't the re2'est or to obtain an
order +rotectin/ the information re2'ested.
La$ En+!(cement 1e may release medical information if as&ed to do so by a la% enforcement official:
o in res+onse to a co'rt order, s'b+oena, %arrant, s'mmons or similar +rocess4
o to identify or locate a s's+ect, f'/itive, material %itness, or missin/ +erson4
o abo't the victim of a crime if, 'nder certain limited circ'mstances, %e are 'nable to obtain the +erson0s a/reement4
o abo't a death %e believe may be the res'lt of criminal cond'ct4
o abo't criminal cond'ct at the "rovider4 and
o in emer/ency circ'mstances, to re+ort a crime4 the location of the crime or victims4 or the identity, descri+tion or location of the +erson %ho committed the crime.
C!(!ne(%4 Me)ical E5amine(% an) F'ne(al Di(ect!(% 1e may release medical information to a coroner or medical e6aminer. This may be necessary, for e6am+le, to identify a deceased +erson
or determine the ca'se of death. 1e may also release medical information abo't +atients of the "rovider to f'neral directors as necessary to carry o't their d'ties.
Nati!nal Sec'(ity an) Intelli*ence Acti.itie% 1e may release medical information abo't yo' to a'thori(ed federal officials for intelli/ence, co'nterintelli/ence, and other national sec'rity activities
a'thori(ed by la%.
P(!tecti.e Se(.ice% +!( t#e P(e%i)ent an) Ot#e(% 1e may disclose medical information abo't yo' to a'thori(ed federal officials so they may +rovide +rotection to the "resident, other a'thori(ed
+ersons or forei/n heads of state or cond'ct s+ecial investi/ations.
Inmate% *f yo' are an inmate of a correctional instit'tion or 'nder the c'stody of a la% enforcement official, %e may release medical information abo't yo' to the correctional instit'tion or la% enforcement
official. This release %o'ld be necessary for the instit'tion to +rovide yo' %ith health care, to +rotect yo'r health and safety or the health and safety of others, or for the safety and sec'rity of the correctional
instit'tion.
Secti!n E" Y!'( Ri*#t% Re*a()in* Me)ical In+!(mati!n A,!'t Y!'
9o' have the follo%in/ ri/hts re/ardin/ medical information %e maintain abo't yo':
Ri*#t t! Acce%%4 In%-ect an) C!-y 9o' have the ri/ht to access, ins+ect and co+y the medical information that may be 'sed to ma&e decisions abo't yo'r care, %ith a fe% e6ce+tions. ;s'ally, this
incl'des medical and billin/ records, b't may not incl'de +sychothera+y notes. *f yo' re2'est a co+y of the information, %e may char/e a fee for the costs of co+yin/, mailin/ or other s'++lies associated %ith yo'r
re2'est.
1e may deny yo'r re2'est to ins+ect and co+y medical information in certain very limited circ'mstances. *f yo' are denied access to medical information, in some cases, yo' may re2'est that the denial be
revie%ed. Another licensed health care +rofessional chosen by the "rovider %ill revie% yo'r re2'est and the denial. The +erson cond'ctin/ the revie% %ill not be the +erson %ho denied yo'r re2'est. 1e %ill com+ly
%ith the o'tcome of the revie%.
Ri*#t t! Amen) *f yo' feel that medical information %e have abo't yo' is incorrect or incom+lete, yo' may as& 's to amend the information. 9o' have the ri/ht to re2'est an amendment for as lon/ as
the information is &e+t by or for the "rovider. *n addition, yo' m'st +rovide a reason that s'++orts yo'r re2'est.
1e may deny yo'r re2'est for an amendment if it is not in %ritin/ or does not incl'de a reason to s'++ort the re2'est. *n addition, %e may deny yo'r re2'est if yo' as& 's to amend information that:
o 1as not created by 's, 'nless the +erson or entity that created the information is no lon/er available to ma&e the amendment4
o *s not +art of the medical information &e+t by or for the "rovider4
o *s not +art of the information %hich yo' %o'ld be +ermitted to ins+ect and co+y4 or
o *s acc'rate and com+lete.
Ri*#t t! an Acc!'ntin* !+ Di%cl!%'(e% 9o' have the ri/ht to re2'est an !Acco'ntin/ of Disclos'res#. This is a list of the disclos'res %e made of medical information abo't yo'. 9o'r re2'est m'st
state a time +eriod %hich may not be lon/er than si6 years and may not incl'de dates before A+ril 1?, 2003. 9o'r re2'est sho'ld indicate in %hat form yo' %ant the acco'ntin/ for e6am+le, on +a+er or
electronically, if available$. The first acco'ntin/ yo' re2'est %ithin a 12 month +eriod %ill be com+limentary. For additional lists, %e may char/e yo' for the costs of +rovidin/ the list. 1e %ill notify yo' of the cost
involved and yo' may choose to %ithdra% or modify yo'r re2'est at that time before any costs are inc'rred.
Ri*#t t! Re1'e%t Re%t(icti!n% 9o' have the ri/ht to re2'est a restriction or limitation on the medical information %e 'se or disclose abo't yo' for +ayment or healthcare o+erations. 9o' also have the
ri/ht to re2'est a limit on the medical information %e disclose abo't yo' to someone %ho is involved in yo'r care or the +ayment for yo'r care, li&e a family member or friend. For e6am+le, yo' co'ld as& that %e not
'se or disclose information abo't a s'r/ery yo' had. *n yo'r re2'est, yo' m'st tell 's %hat information yo' %ant to limit, %hether yo' %ant to limit o'r 'se, disclos're or both, and to %hom yo' %ant the limits to
a++ly for e6am+le, disclos'res to yo'r s+o'se$. 1e are not re2'ired to a/ree to these ty+es of re2'est. 1e %ill not com+ly %ith any re2'ests to restrict 'se or access of yo'r medical information for treatment
+'r+oses.
9o' also have the ri/ht to restrict 'se and disclos're of yo'r medical information abo't a service or item for %hich yo' have +aid o't of +oc&et, for +ayment i.e. health +lans$ and o+erational b't not
treatment$ +'r+oses, if yo' have com+letely +aid yo'r bill for this item or service. 1e %ill not acce+t yo'r re2'est for this ty+e of restriction 'ntil yo' have com+letely +aid yo'r bill (ero balance$ for this item or
service. 1e are not re2'ired to notify other healthcare +roviders of these restrictions, that is yo'r res+onsibility.
Ri*#t t! Recei.e N!tice !+ a B(eac# 1e are re2'ired to notify yo' by first class mail or by email if yo' have indicated a +reference to receive information by email$, of any breaches of ;nsec'red
"rotected )ealth *nformation as soon as +ossible, b't in any event, no later than @0 days follo%in/ the discovery of the breach. A;nsec'red "rotected )ealth *nformationB is information that is not sec'red thro'/h
the 'se of a technolo/y or methodolo/y identified by the 8ecretary of the ;.8. De+artment of )ealth and )'man 8ervices to render the "rotected )ealth *nformation 'n'sable, 'nreadable, and 'ndeci+herable to
'na'thori(ed 'sers. The notice is re2'ired to incl'de the follo%in/ information:
o a brief descri+tion of the breach, incl'din/ the date of the breach and the date of its discovery, if &no%n4
o a descri+tion of the ty+e of ;nsec'red "rotected )ealth *nformation involved in the breach4
o ste+s yo' sho'ld ta&e to +rotect yo'rself from +otential harm res'ltin/ from the breach4
o a brief descri+tion of actions %e are ta&in/ to investi/ate the breach, miti/ate losses, and +rotect a/ainst f'rther breaches4
o contact information, incl'din/ a toll7free tele+hone n'mber, e7mail address, 1eb site or +ostal address to +ermit yo' to as& 2'estions or obtain additional *nformation.
*n the event the breach involves 10 or more +atients %hose contact information is o't of date %e %ill +ost a notice of the breach on the home +a/e of o'r %ebsite or in a ma:or +rint or broadcast media. *f
the breach involves more than C00 +atients in the state or :'risdiction, %e %ill send notices to +rominent media o'tlets. *f the breach involves more than C00 +atients, %e are re2'ired to immediately notify the
8ecretary. 1e also are re2'ired to s'bmit an ann'al re+ort to the 8ecretary of a breach that involved less than C00 +atients d'rin/ the year and %ill maintain a %ritten lo/ of breaches involvin/ less than C00
+atients.
Ri*#t t! Re1'e%t C!n+i)ential C!mm'nicati!n% 9o' have the ri/ht to re2'est that %e comm'nicate %ith yo' abo't medical matters in a certain %ay or at a certain location. For e6am+le, yo'
can as& that %e only contact yo' at %or& or hard co+y or e7mail. 1e %ill not as& yo' the reason for yo'r re2'est. 1e %ill accommodate all reasonable re2'ests. 9o'r re2'est m'st s+ecify ho% or %here yo' %ish to
be contacted.
Ri*#t t! a Pa-e( C!-y !+ T#i% N!tice 9o' have the ri/ht to a +a+er co+y of this Notice. 9o' may as& 's to /ive yo' a co+y of this Notice at any time. Even if yo' have a/reed to receive this Notice
electronically, yo' are still entitled to a +a+er co+y of this Notice. 9o' may obtain a co+y of this Notice at o'r %ebsite. Atlanticfamilydental.net
To e6ercise the above ri/hts, +lease contact the individ'al listed at the to+ of this Notice to obtain a co+y of the relevant form yo' %ill need to com+lete to ma&e yo'r re2'est.
Secti!n F" C#an*e% t! T#i% N!tice
1e reserve the ri/ht to chan/e this Notice. 1e reserve the ri/ht to ma&e the revised or chan/ed Notice effective for medical information %e already have abo't yo' as %ell as any information %e receive in the
f't're. 1e %ill +ost a co+y of the c'rrent Notice. The Notice %ill contain on the first +a/e, in the to+ ri/ht hand corner, the effective date. *n addition, each time yo' re/ister at or are admitted to the "rovider for
treatment or health care services as an in+atient or o't+atient, %e %ill offer yo' a co+y of the c'rrent Notice in effect.
Secti!n G" C!m-laint%
*f yo' believe yo'r +rivacy ri/hts have been violated, yo' may file a com+laint %ith the "rovider or %ith the 8ecretary of the De+artment of )ealth and )'man 8ervices4
htt+://%%%.hhs./ov/ocr/+rivacy/hi+aa/com+laints/inde6.html
To file a com+laint %ith the "rovider, contact the individ'al listed on the first +a/e of this Notice. All com+laints m'st be s'bmitted in %ritin/. 9o' %ill not be +enali(ed for filin/ a com+laint.
Secti!n H" Ot#e( U%e% !+ Me)ical In+!(mati!n
-ther 'ses and disclos'res of medical information not covered by this Notice or the la%s that a++ly to 's %ill be made only %ith yo'r %ritten +ermission. *f yo' +rovide 's +ermission to 'se or disclose
medical information abo't yo', yo' may revo&e that +ermission, in %ritin/, at any time. *f yo' revo&e yo'r +ermission, %e %ill no lon/er 'se or disclose medical information abo't yo' for the reasons covered by yo'r
%ritten a'thori(ation. 9o' 'nderstand that %e are 'nable to ta&e bac& any disclos'res %e have already made %ith yo'r +ermission, and that %e are re2'ired to retain o'r records of the care that %e +rovided to yo'.
Secti!n I" O(*ani0e) Healt#ca(e A((an*ement
The "rovider, the inde+endent contractor members of its 3edical 8taff incl'din/ yo'r +hysician$, and other healthcare +roviders affiliated %ith the "rovider have a/reed, as +ermitted by la%, to share
yo'r health information amon/ themselves for +'r+oses of treatment, +ayment or health care o+erations. This enables 's to better address yo'r healthcare needs.
Devision Date: 3arch 03, 2013, to be com+liant %ith )*"AA -mnib's "rivacy D'les. -ri/inal Effective Date: A+ril 1?, 2003.
*f yo' have any 2'estions abo't this Notice of "rivacy "ractices ANoticeB$, +lease contact:
=andice Eisber/
"hone n'mber: 919$ EFE71E10
"a/e 2 of 2 =o+yri/ht > 2013 8tericycle, *nc. All ri/hts reserved. )*"AA =om+liance "ro/ram