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Privacy Policy

Your privacy is the foundation of our practice. Progress Is Progress LLC (“Progress Is Progress,” “we,” “us,” or “our”) was built on the principle that seeking help for addiction or mental health concerns should never cost you your career, your reputation, or your peace of mind. This Privacy Policy explains how we collect, use, protect, and disclose information when you visit our website, contact us about services, or become a client.

Please read this policy carefully. By using our website or our services, you agree to the practices described here. If you do not agree, please do not use our website or services.

1. Our Confidentiality Commitment

Progress Is Progress LLC operates as a private-pay counseling and counseling practice. We do not bill insurance, and we do not submit claims to any insurance carrier, employer-sponsored health plan, or government program. This is a deliberate choice that shapes every aspect of how your information is handled.

What this means for you:

    • No insurance reporting: Because we do not file insurance claims, your sessions are not reported to any insurance company, pharmacy benefit manager, or medical information clearinghouse.

    • No entry into shared medical databases: Insurance-billed mental health and substance use treatment is routinely logged in databases such as the MIB Group (Medical Information Bureau) that can be accessed during underwriting for life, disability, and long-term care insurance. Because we do not bill insurance, your care with us is not entered into these systems by us.

    • No employer visibility: We do not communicate with your employer, HR department, or Employee Assistance Program unless you direct us to in writing.

    • Private payment: You pay us directly. Your credit card or bank statement will reflect a discreet practice name rather than a description of services received.

There are narrow exceptions to confidentiality required by law, which are described in Section 7 below. Outside of those legally mandated situations, your information stays between you and your counselor or coach.

Important note about your own disclosures: We cannot control what you choose to tell others about your care. If you disclose your participation in counseling to your primary care physician, request records be sent to another provider, or list us on forms that get submitted to insurers or employers, that information may enter records outside our control. We recommend discussing any third-party disclosure with your counselor before making it.

2. Information We Collect

We collect different types of information depending on how you interact with us. This section covers information collected through our website and initial inquiries. Clinical records created during the course of counseling or coaching are covered separately in Section 4.

2.1 Information You Provide Directly

When you contact us through our website, email, or phone, you may provide:

    • Your name or a preferred pseudonym

    • Your phone number and email address

    • Your state of residence (required to confirm we can legally serve you)

    • A description of what brings you to our practice

    • Preferred times for contact and preferred contact method

You are never required to use your real name to request an initial consultation. However, we will need your legal name before we can enter into a counseling or coaching agreement, process payment, or maintain clinical records in accordance with licensing requirements.

2.2 Information Collected Automatically

When you visit our website, certain information is collected automatically by our servers and by analytics tools. This typically includes:

    • Your IP address (which may indicate approximate geographic location)

    • Browser type and version

    • Device type (desktop, mobile, tablet) and operating system

    • Referring website, if you arrived by clicking a link

    • Pages you view on our site and the time spent on each

    • Date and time of your visit

This information is not linked to your clinical records. It is used in aggregate to understand how visitors find and use our website so we can improve it.

2.3 Cookies and Similar Technologies

Our website uses cookies and similar technologies. A cookie is a small text file stored on your device that allows a site to remember certain information between visits. We use:

    • Strictly necessary cookies that allow the site to function (for example, keeping a session active while you complete a contact form).

    • Analytics cookies that help us understand site usage in aggregate. These may be set by third-party services such as Google Analytics.

    • Functional cookies that remember preferences such as accessibility settings.

We do not use advertising or retargeting cookies on this website. We understand that seeing ads for an addiction treatment site following you around the internet would be a serious confidentiality concern, and we have specifically chosen not to deploy that type of tracking.

You can control cookies through your browser settings. Disabling cookies may affect some site functionality but will not prevent you from contacting us.

3. How We Use Your Information

We use the information we collect for the following purposes:

    • To respond to inquiries: When you contact us, we use your contact information to reply, answer questions, and schedule an initial consultation if you request one.

    • To confirm eligibility:We use your state of residence to confirm we are licensed or legally authorized to provide services to you.

    • To deliver services: Once you become a client, we use your information to schedule sessions, conduct counseling or coaching, process payment, and maintain records required by licensing bodies.

    • To improve our website and services: Aggregated analytics data helps us understand what content is useful and how visitors navigate the site.

    • To comply with legal obligations: We use and retain information as required by applicable law, licensing regulations, and professional ethics codes.

We do not sell your personal information. We do not rent it. We do not share it with marketing partners, data brokers, or advertisers.

4. Clinical Records and Protected Health Information

If you become a client, the information created in the course of counseling or coaching is treated with a higher level of protection than general website data.

4.1 What Clinical Records Contain

Clinical records for counseling clients typically include:

    • Intake paperwork and signed consent forms

    • Assessment information and treatment goals

    • Progress notes documenting the date, length, and general content of each session

    • Payment records

    • Any correspondence related to your care

counseling records are more limited in scope and do not constitute a clinical medical record. They typically include a coaching agreement, session logs, and payment records.

4.2 Where Records Are Stored

Clinical records are stored in an encrypted, HIPAA-compliant electronic health record (EHR) system. Access is limited to the clinician providing your care and, where applicable, clinical supervisors bound by the same confidentiality obligations. Paper records, if any, are stored in locked files.

We select technology vendors (including our EHR, video platform, and payment processor) based in part on their ability to sign a Business Associate Agreement (BAA) under HIPAA and to meet reasonable security standards.

4.3 HIPAA and 42 CFR Part 2

counseling services provided by Progress Is Progress are subject to the Health Insurance Portability and Accountability Act (HIPAA). Services that involve the diagnosis or treatment of a substance use disorder are additionally subject to 42 CFR Part 2, a federal regulation that provides heightened confidentiality protections for substance use disorder patient records.

Under 42 CFR Part 2, records identifying you as having received substance use disorder services generally cannot be disclosed without your written consent, even to other healthcare providers, and even in response to a subpoena, absent a qualifying court order. These protections are among the strongest confidentiality protections in US law.

You will receive a separate Notice of Privacy Practices at intake that describes HIPAA and, where applicable, 42 CFR Part 2 protections in greater detail. That Notice governs the handling of your clinical records and controls over anything described in this general website Privacy Policy in the event of a conflict.

4.4 counseling Confidentiality

counseling is not licensed counseling and is not a medical service. Coaching records are not covered by HIPAA or 42 CFR Part 2 in the same way clinical records are. However, Progress Is Progress holds coaching information to the same practical standard of confidentiality as clinical information as a matter of policy. Your coaching agreement will describe the confidentiality terms that apply to that specific service.

5. Telehealth and Video Sessions

All sessions are conducted online. We use a video platform that is HIPAA-compliant and covered by a Business Associate Agreement. Sessions are not recorded by us. We ask that you do not record sessions either.

To protect your privacy during telehealth sessions, we recommend that you:

    • Attend sessions from a private, quiet location where you will not be overheard

    • Use a personal device rather than a work-issued device when possible, since employers may monitor activity on work devices

    • Connect over a secure network (home Wi-Fi with a password) rather than public Wi-Fi

    • Use headphones to prevent others from hearing audio

    • Close other applications, particularly any that may be monitored or shared

We cannot guarantee the privacy of a session on your end if your device or network is monitored by a third party. If you have concerns about device monitoring, please raise them with your counselor or coach before your first session.

6. Payment Information

We do not store full credit card numbers on our systems. Payments are processed through a PCI-compliant third-party payment processor that handles card data under its own security protocols.

Your bank or credit card statement will show a charge from a merchant name that does not identify the specific nature of services received. You can request the exact descriptor that will appear on your statement before your first payment is processed.

Receipts are not automatically provided to any third party. If you need documentation for your own records, we can provide a general-purpose receipt on request.

7. When We Are Required to Disclose Information

Confidentiality has legal limits. We are required by law or professional ethics to disclose information, without your consent, in a small number of specific situations:

    • Imminent risk of serious harm to self: If a counselor has a reasonable belief that you present an imminent danger of serious harm to yourself, we may take steps to protect your safety, which can include contacting emergency services or a designated emergency contact.

    • Imminent risk of serious harm to an identifiable other person: If you make a serious threat of physical violence against a specific, identifiable person, the law may require us to warn that person and/or notify law enforcement.

    • Suspected abuse or neglect of a child, elderly person, or dependent adult: Counselors are mandated reporters. If we learn of suspected abuse or neglect, we are required to report it to the appropriate state agency.

    • Valid court orders: A court may, in rare circumstances, order the disclosure of records. For substance use disorder records protected under 42 CFR Part 2, the standard for such orders is significantly higher than for general medical records. We will resist disclosure to the extent the law permits and will notify you when legally permissible.

    • Licensing board investigations: If a licensing board conducts an investigation of a counselor, it may require access to relevant records.

Outside of these circumstances, we will not release information about you without your written, informed consent. Consent can be limited to a specific recipient, a specific purpose, and a specific time period, and you can revoke consent in writing at any time (though we cannot undo a disclosure already made in reliance on a valid consent).

8. Third-Party Service Providers

We work with a small number of service providers whose tools make our practice possible. These providers may have access to certain information in order to perform their function. We select providers that offer appropriate security and, where legally required, sign Business Associate Agreements with us.

Categories of providers we use include:

    • Electronic health record (EHR) platform for clinical documentation and scheduling

    • HIPAA-compliant video conferencing platform for sessions

    • Secure messaging or client portal system

    • Payment processor

    • Email service provider

    • Website hosting and analytics

These providers are contractually limited to using your information only to perform services for us. They are not permitted to use your information for their own marketing or to sell it.

9. Data Retention

We retain clinical records for the period required by applicable state licensing laws, which typically range from five to ten years after the end of treatment, and longer for records involving minors. counseling records are retained for a shorter period as specified in the coaching agreement.

Website contact form submissions that do not result in services are generally retained for no longer than twelve months and then deleted.

After the applicable retention period, records are securely destroyed in accordance with professional standards.

10. Your Rights

Depending on your state of residence and the type of information involved, you may have the right to:

    • Request access to the information we hold about you

    • Request correction of information that is inaccurate or incomplete

    • Request a copy of your clinical record, subject to limited exceptions recognized by law

    • Request an accounting of disclosures of your protected health information

    • Request restrictions on certain uses and disclosures

    • Request confidential communications at an alternate address or phone number

    • File a complaint if you believe your privacy rights have been violated

To exercise any of these rights, please contact us using the information in Section 14. For clinical records, specific procedures and timelines are described in the Notice of Privacy Practices you receive at intake.

If you are a resident of a state with a comprehensive consumer privacy law (such as California, Colorado, Virginia, Connecticut, Utah, or others), you may have additional rights with respect to non-clinical data, including the right to delete certain data and the right to opt out of certain data sharing. Contact us to exercise these rights.

11. Security

We take reasonable technical, administrative, and physical safeguards to protect the information we hold. These include encryption in transit and at rest for clinical records, access controls, secure password policies, multi-factor authentication where available, and regular review of our security practices.

No system is completely immune from unauthorized access. In the unlikely event of a breach that affects your information, we will notify you in accordance with applicable federal and state breach notification laws.

12. Children’s Privacy

Our website and services are intended for adults. We do not knowingly collect information from children under 13. If we learn that we have collected information from a child under 13 without verified parental consent, we will delete it.

If we provide counseling services to a minor (under 18), additional consent requirements apply. These are addressed in the intake process and governed by the laws of the state where the minor resides.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will update the “Last Updated” date at the top of the policy and, where appropriate, provide additional notice (such as a notice on our website or a direct email to current clients).

We encourage you to review this policy periodically. Continued use of our website or services after changes take effect constitutes acceptance of the updated policy.

14. Contact Us

If you have questions about this Privacy Policy, want to exercise any of the rights described above, or wish to file a privacy-related complaint, please contact us:

Progress Is Progress LLC

Phone: (715) 494-4700

Complaints can also be filed with the US Department of Health and Human Services, Office for Civil Rights, for matters involving HIPAA or 42 CFR Part 2. We will not retaliate against you for filing a complaint.

This Privacy Policy describes our practices in general terms. For current clients, the Notice of Privacy Practices provided at intake governs the handling of protected health information and controls in the event of any conflict with this general website policy.

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