Privacy Policy

1. Who is responsible for the information

The agencies that use True Care System own the care records they keep in it. For those records we act as the agency’s Business Associate under HIPAA: we handle protected health information only to provide the service, as our Business Associate Agreement with the agency allows. If you receive care from an agency, that agency’s own privacy notice describes your rights, and requests about your health information go to the agency.

2. What we collect

• Account details for the agency staff who use the system: name, work e-mail, role, and sign-in and security events.
• Care records the agency enters, which include protected health information: the people served, their services and authorizations, schedules, visits, daily notes, medication and incident records, behavior support logs, claims, and messages between staff.
• Signatures, photos and documents: the signatures of the caregiver and of the person served on a daily note, photos and files attached to a message or an incident report, and the documents staff read and sign in the app.
• Calls between staff in the app. Calls are not recorded.
• Location from the mobile app at clock-in and clock-out, and the miles driven during a visit. Section 3 explains exactly when and how.
• Voice: when a caregiver speaks to True Care Assistant, dictates a note or clocks in by voice, the words are recognized on the phone. The voice itself is never recorded or sent; only the resulting text is used.
• Device details: whether the phone runs iOS or Android, the app version, an identifier for the app on that phone, a security key the phone creates for signing in (only its public part leaves the phone), and a push notification token so we can send the phone a notification. Fingerprint and face data used to unlock the app stay on the phone; the app never receives them.
• Website visits: the standard request data any web server receives. This website uses no cookies, no analytics and no advertising.
• Contact and demo requests you send through the form on this website: your name, work e-mail, phone number if you give one, organization, role, state, reason and message. We use them only to answer you. The form is delivered to us as an e-mail and is not stored on the website.
• Evaluation accounts for the Sandbox: a name and e-mail address (see section 10).

3. Location information and Electronic Visit Verification

The federal 21st Century Cures Act requires states to verify Medicaid-funded home care visits electronically. Electronic Visit Verification (EVV) records who gave the service, to whom, when, and where it was delivered. The True Care System mobile app uses the phone’s location for EVV, to measure the miles a caregiver drives during a visit, and to show distances on a map. It does not use location for anything else.

At clock-in and clock-out

• When a caregiver clocks in or clocks out, the app reads the phone's precise location once, at that moment.
• The location is stored with the visit and shared with the agency that employs the caregiver.
• It is part of the visit record the agency must send to the state or program EVV system it uses (in Pennsylvania, through Sandata).
• If the phone cannot give a location, the clock-in or clock-out is recorded without it, with the reason, and the agency must correct and document the visit.

During a visit, to measure mileage

• The app measures the miles driven during a visit, from Clock In to Clock Out only. It never starts before Clock In and always stops at Clock Out.
• When no visit is in progress, the app does not track the phone's location.
• While a visit is on, the measuring continues in the background, also when the screen is locked, and the phone shows it: on Android, a notification that reads “True Care System is measuring mileage” and “Only while your visit is on. It stops at Clock Out.”; on iPhone, the location indicator at the top of the screen.
• Only driving counts. Walking around the home adds no miles.
• The miles are used so the agency can reimburse the caregiver's travel. They fill in the mileage of the visit's daily note, which the caregiver can change with a reason, and appear in the agency's payroll report.

What stays on the phone

The positions read during the visit, and the line of the drives shown on the visit map, stay on the phone. They are kept encrypted in the phone’s secure storage, can be read only on that phone, and are not included in phone backups. They are removed when the caregiver signs out of the app on that phone, when another person signs in on it, or when the agency removes the phone from the account.

What is sent to us

For each drive: when it started, when it ended, and the miles. If location was turned off, its permission was taken away or the signal was lost during the visit, the reason is sent as well. The positions of the drive are not sent.

Who sees it

The caregiver and the authorized staff of the agency that employs the caregiver see the clock-in and clock-out locations and the miles, with the visit and its daily note. The clock-in and clock-out locations also go to the EVV system described above. We handle this information only to provide the service.

Maps and distances on shifts

• A shift's details, the Clock In screen and the visit in progress show a map with the home and the phone's position, and how far the phone is from the home. The app reads the location once when the screen opens, and only if location permission was already given.
• On a shift that needs cover, Distance from me asks for location only when the caregiver taps it, and estimates the distance and driving time.
• These distances are worked out on the phone. The position is not sent to us.
• Directions opens the phone's own maps app with the address of the visit.

Permission and your choice

• The app asks for location only while the app is in use (iPhone: “While Using the App”; Android: “Allow only while using the app”). It never asks to use location all the time.
• The caregiver can decline, or change the choice at any time, in the phone's Settings. Turning off precise location also stops the mileage measuring.
• Without location permission, a clock-in or clock-out is recorded without the location and becomes a manual entry that the agency corrects, and no miles are measured: the caregiver types the miles in the daily note, with a reason.

4. Why we use it

To run the service for the agency: plan and verify visits, keep care documentation, prepare claims and payroll exports, send notifications, keep accounts secure, and answer support requests. We do not sell information, we do not use it for advertising, and the apps contain no advertising or tracking across other companies’ apps and sites.

5. Who receives it

Only the agency that owns the records, its authorized users, and these categories of providers:

• Amazon Web Services, which hosts True Care System in the United States.
• Google Workspace, which carries our e-mail and creates the links for video meetings the agency sets up.
• Google's public connection service, which helps two devices find each other for a call in the app. The call goes directly between the people in it.
• Expo, which delivers updates of the mobile app and passes notifications on to the phone maker's notification service.
• The phone maker's notification service (Apple or Google), which delivers notifications written without health information.
• Google Maps on Android and Apple Maps on iPhone, which draw the maps in the mobile app.
• Geocodio, which checks and completes postal addresses. It receives the street, city, state and ZIP code only, never a name.
• Stripe, which handles the invoices and payments of agencies to True Care. It receives no information about the people served.
• Resend, which delivers the messages sent through the website's contact and demo form to our mailbox.
• An artificial intelligence provider for True Care Assistant, where the agency turns it on. Names, identifiers and other details that could identify a person are replaced before any text is sent; the provider receives de-identified text only.
• Sandata, the aggregator for Pennsylvania Alternate EVV, which receives visit verification records.
• Pennsylvania PROMISe, which receives claims and eligibility requests the agency submits.

Providers that handle protected health information do so under a Business Associate Agreement or the program’s own rules. We also disclose information when the law requires it.

6. How we protect it

Access is limited by role. In the web app, sign-in asks for a code from an authenticator app as a second factor; a browser the person chose to remember may skip the code for a while. In the mobile app, sign-in uses the agency, the e-mail address and the password, and is tied to the registered phone through a security key kept on that phone; the person can turn on fingerprint or face unlock, and the password is asked again at least every 30 days. Sessions end after inactivity, data is encrypted in transit and at rest, what the mobile app keeps on the phone is encrypted, each agency’s data is kept separate, views and changes of health information are recorded in an audit trail, and databases are backed up. If a security incident affects an agency’s health information, we notify the agency as HIPAA and our agreement require.

7. How long we keep it

Care records are kept while the agency’s agreement is in effect and afterwards only as long as that agreement, the law or state program rules require; then they are returned or destroyed as the agreement says. Security audit records are kept for at least six years.

8. Your choices and requests

If you have an account, you can ask to see, correct or get a copy of your account information by e-mailing support@truecaresystem.com from the address on the account. To delete your account, follow the steps in section 9, Delete your account. Requests about care records, such as visits, notes or health information, go to the agency that keeps them.

9. Delete your account

This section explains how to delete an account of True Care System, the web app and the mobile app made by True Care System LLC, including the “True Care System Mobile” and “True Care System Sandbox” apps, what is deleted, and what is kept and for how long.

How to ask for your account to be deleted

1. In the mobile app: open Settings → Delete my account and confirm.
2. Or by e-mail: write to support@truecaresystem.com from the e-mail address on the account and ask for the account to be deleted.
3. Sandbox evaluation accounts: use either way above, or do nothing: we delete them when the evaluation ends.

Staff accounts are created by the agency that employs you, so your request goes to that agency. The agency that created the account closes it within 30 days, and we confirm by e-mail to the address on the account. For a Sandbox evaluation account, True Care System LLC created the account and closes it.

What is deleted

• The sign-in e-mail address and the name on the account.
• The password and the sign-in keys of the account.
• The account's app settings.
• The phone's registration and its notification token.
• Everything the app kept on the phone: it is removed when you sign out, or when the phone is removed from the account.

What is kept, and for how long

• Visit, Electronic Visit Verification, care, billing and payroll records that the agency must keep under its agreement with us, the law and state program rules. They are kept for as long as those require, then returned or destroyed as the agreement says. Files attached to those records, such as documents and photos, are deleted automatically seven years after their record closes.
• Security and audit records, such as sign-in history and the record of who viewed or changed information: at least six years.

If you ask, we tell you what was kept and why.

10. Sandbox and demonstration environment

True Care System has a Sandbox for demonstrations and evaluation: the Sandbox web app at testv2-app.truecaresystem.com and the “True Care System Sandbox” mobile app.

• The Sandbox holds fictional records only. Do not enter real health information or details about real people.
• Sandbox data may be reset or deleted at any time. It is not covered by a Business Associate Agreement.
• Sandbox e-mails, such as sign-in and password e-mails, are sent only to the address entered for the account.
• The location rules in section 3 apply to the Sandbox mobile app too.

Evaluation accounts

To give a prospective customer or potential partner access to the Sandbox, we collect their name and e-mail address and use them only to create the account and send its sign-in e-mails. We also keep a copy of the signed non-disclosure agreement. We delete evaluation accounts when the evaluation ends, or sooner on request to support@truecaresystem.com. See also our Terms of Service.

11. Children

True Care System is not meant for children under 13, and we do not knowingly collect information from them. Agencies may keep records about the people they serve, including minors; those records are handled as protected health information for the agency.

12. Changes to this policy

When this policy changes, we update the date at the top of this page. If a change is significant, we tell the agencies that use True Care System before it takes effect.

13. Contact

Questions about this policy: contact@truecaresystem.com. Help with an account, including deletion requests: support@truecaresystem.com.