Consumer Health Data Privacy Policy
Strong Foundation Coaching & HR
Effective Date: September 21, 2026
Strong Foundation Coaching & HR recognizes that information about health and the way health circumstances affect a person's life can be deeply personal.
This Consumer Health Data Privacy Policy explains how Strong Foundation Coaching & HR ("we," "our," or "us") collects, uses, shares, retains, and protects consumer health data when applicable consumer health privacy laws apply.
This policy is separate from our general Privacy Policy and is intended to address consumer health data requirements, including those established by the Washington My Health My Data Act and Nevada consumer health data law.
Our general Privacy Policy governs other personal information collected through our website, communications, programs, services, and business operations.
Our Approach to Health Information
Strong Foundation Coaching & HR is not a medical provider and does not diagnose, treat, or provide medical advice.
Our work may involve conversations about how health circumstances affect a person's work, capacity, decisions, relationships, responsibilities, or daily life.
We generally do not ask clients or participants to provide an exact diagnosis, medical records, test results, medication lists, treatment histories, insurance records, or similar clinical information.
During coaching, workshops, facilitated programs, consulting, or other conversations, you may voluntarily choose to share health-related information when it is relevant to the circumstances you want to discuss.
You decide what you wish to share.
We encourage you to share only information that is reasonably relevant to the service you are seeking.
What We Mean by Consumer Health Data
Applicable law defines consumer health data broadly.
Consumer health data generally includes personal information that is linked or reasonably capable of being linked to an individual and that identifies, describes, reflects, or may reasonably indicate the individual's past, present, or future physical or mental health status.
Because the legal definition is broad, information you voluntarily share during a conversation may qualify as consumer health data even when we did not ask you to provide it.
Our actual collection practices are considerably narrower than the full range of information that may fall within the legal definition.
Consumer Health Data We May Receive
Consumer health data we receive is generally limited to information that you voluntarily choose to share in connection with a service you requested.
Depending on the conversation or service, this may include information about:
A health condition or health circumstance
Symptoms or changes you are experiencing
Changing physical or mental capacity
Functional limitations
Disability-related circumstances
The effect of a health circumstance on your work
Scheduling or capacity concerns related to health
The effect of health circumstances on family, relationships, community participation, or daily activities
Decisions or concerns you are considering because of a health circumstance
Workplace needs or communication concerns related to your health
Caring responsibilities that are affected by another person's health circumstances
You may sometimes choose to identify a diagnosis, treatment, medication, procedure, or other medical detail during a conversation. We do not generally request this level of information and ask that you provide it only when you believe it is relevant to the service you requested.
Information About Other People
People who are caring for or supporting another person sometimes discuss that person's health circumstances.
We encourage you to limit information about another person to what is reasonably necessary to explain your own circumstances, responsibilities, decisions, or needs.
For example, it may be relevant for us to understand that someone you support now needs supervision during part of the day. It ordinarily is not necessary for us to know that person's complete medical history, medication list, medical providers, test results, or other detailed clinical information.
Please avoid providing identifying medical information about another person when a more general description will accomplish the same purpose.
If unnecessary health information about another person is provided to us, we may avoid recording or retaining those details when they are not needed for the service being provided.
Information We Do Not Routinely Request
Strong Foundation Coaching & HR does not routinely request:
Medical records
Medical charts
Laboratory or diagnostic test results
Prescription or medication lists
Medical imaging
Insurance claim records
Complete treatment histories
Genetic information
Biometric health information
Reproductive or sexual health records
Detailed information about medical providers
Precise location information relating to healthcare visits
Please do not send us medical records or similar clinical documentation unless we have specifically discussed why the information is necessary.
Sources of Consumer Health Data
Consumer health data we receive generally comes directly from you.
It may be communicated through:
Individual coaching conversations
Consulting conversations
Workshops or facilitated programs
Video meetings
Telephone conversations
Email or other communications you send to us
Information you voluntarily provide while requesting or receiving a service
Registration for a health-related program may also indicate that you have chosen to participate in that program.
We do not use enrollment in a program, visits to particular website pages, or similar activity to infer that you have a particular diagnosis or medical condition.
We do not purchase consumer health data from data brokers.
Why We Use Consumer Health Data
When health-related information is relevant to a service you requested, we may use it to:
Understand the circumstances you want to discuss
Provide coaching, facilitation, education, consulting, or another requested service
Help you explore your needs, options, capacity, decisions, or priorities
Discuss how changing circumstances affect your work or other areas of your life
Help you prepare for conversations or decisions involving your workplace
Understand the effect of caring responsibilities on your own circumstances
Respond to questions you ask
Communicate with you about the service you requested
Maintain limited records reasonably necessary to operate our business or provide the service
Meet applicable legal obligations
Our focus is generally on the effect of the circumstances on your life and the choices available to you, rather than collecting or analyzing medical details.
We do not use identifiable consumer health data for unrelated advertising.
We do not sell consumer health data.
Collection of Consumer Health Data
Applicable law may allow us to collect consumer health data when the collection is reasonably necessary to provide a product or service that you requested.
For example, if you voluntarily explain during a coaching conversation that a health condition has changed what you are able to do at work, we may need to understand that information to meaningfully provide the coaching service you requested.
Where consumer health data is not reasonably necessary to provide a requested service and applicable law requires consent before collection, we will seek the appropriate consent before intentionally collecting that information.
We do not use a general acceptance of our website terms or Privacy Policy as a substitute for specific consent when applicable law requires separate affirmative consent.
Sharing Consumer Health Data
We do not sell consumer health data.
We also do not disclose consumer health data to third parties for their independent advertising or marketing purposes.
Consumer health data may be processed or disclosed only when reasonably necessary to:
Provide a service you requested;
Operate technology used to deliver that service;
Work with an authorized collaborative provider involved in the particular service;
Comply with applicable law or legal process; or
Carry out another purpose for which you have provided appropriate consent.
Where applicable law requires separate consent before sharing consumer health data, we will obtain that consent unless an applicable exception allows the information to be processed or disclosed as part of providing the service you requested.
Service Providers
We use technology and service providers to operate our business and deliver services.
Depending on how you communicate or work with us, these providers may support functions such as:
Email
Calendar and scheduling
Video meetings
Document and file storage
Online forms
Registration and enrollment
Website services
Business communications
Administrative technology
Consumer health data may pass through these systems when you voluntarily include health information in a communication or conversation.
We seek to limit access to information to providers and systems reasonably necessary to provide our services and operate our business.
Collaborative Programs
Some services may be offered with another independent professional or organization.
We will not disclose consumer health data to a collaborative partner merely because that person or organization is collaborating with us.
Consumer health data may be shared when:
It is reasonably necessary to provide the collaborative service you requested;
You have directed or authorized the disclosure; or
Another applicable legal basis permits the disclosure.
Where separate affirmative consent is required by applicable consumer health privacy law, we will obtain that consent before sharing the information.
Group Programs and Workshops
Group programs, workshops, facilitated discussions, and similar experiences involve other participants.
You decide what personal or health-related information you wish to disclose during a group conversation.
We encourage participants to protect one another's privacy, but Strong Foundation Coaching & HR cannot control what another participant does with information that you voluntarily disclose directly to the group.
For that reason, we encourage you to share only the level of detail that feels appropriate and reasonably necessary for your participation.
You are not expected to disclose an exact diagnosis in order to participate in a health-related program unless a particular offering expressly states otherwise.
AI-Assisted Technology
Strong Foundation Coaching & HR may use artificial intelligence and other technology-assisted tools for purposes such as research, brainstorming, program development, administrative work, organization, and business operations.
We make reasonable efforts to minimize or remove identifying information before using AI-assisted tools when identifiable consumer health information is not necessary.
We do not intentionally enter identifiable consumer health information into general-purpose AI systems merely for experimentation, content creation, or unrelated purposes.
If identifiable consumer health data needs to be processed through a technology-assisted system in order to provide a requested service, we will consider the nature of the information, the purpose of the processing, available safeguards, and applicable consent requirements before doing so.
Website Activity and Health Inferences
Our website uses ordinary website technologies as described in our general Privacy Policy and cookie settings.
We do not intentionally use website browsing activity to infer that a visitor:
Has a particular diagnosis;
Has a particular disability;
Has a particular health condition;
Uses a particular medication;
Has received a particular treatment; or
Is seeking a particular form of medical care.
We do not intentionally use precise geolocation information to identify or infer visits to healthcare providers or facilities.
Sale of Consumer Health Data
Strong Foundation Coaching & HR does not sell consumer health data.
We do not exchange consumer health data for money or other consideration for advertising, data brokerage, or similar purposes.
Your Consumer Health Data Rights
Depending on applicable law and your circumstances, you may have the right to:
Confirm whether we collect consumer health data relating to you
Confirm whether we share or sell consumer health data relating to you
Access consumer health data we maintain about you
Obtain information about third parties or affiliates with whom applicable consumer health data has been shared or sold
Withdraw consent for future collection or sharing when processing is based on your consent
Ask us to stop collecting or sharing applicable consumer health data
Request deletion of eligible consumer health data
Appeal certain decisions regarding a consumer health data request
Exercise applicable privacy rights without unlawful discrimination
Washington and Nevada both provide consumer rights relating to health-data collection, sharing, and deletion, although the precise rights and procedures differ by state.
Requesting Access or Deletion
To submit a request regarding your consumer health data, contact:
Hello@StrongFoundationCoaching.com
Please use the subject line:
Consumer Health Data Request
Tell us what you are requesting and provide enough information for us to reasonably identify the relevant records.
We may request additional information when reasonably necessary to authenticate your identity and protect information from unauthorized disclosure or deletion.
You do not need to create a new account to submit a request.
Withdrawal of Consent
If consumer health data is being collected or shared based on your consent, you may withdraw your consent for future collection or sharing.
Contact:
Hello@StrongFoundationCoaching.com
Subject line:
Withdraw Consumer Health Data Consent
Withdrawal does not necessarily affect collection or processing that occurred lawfully before your withdrawal.
If particular health-related information is reasonably necessary to provide a service you requested, withdrawing permission to process that information may affect our ability to continue providing that service.
Deletion Requests
If you make an eligible deletion request, we will take the steps required by applicable law to delete covered consumer health data from our records.
Where required, we will also communicate the deletion request to applicable service providers, processors, or other recipients of the information.
Some information may be retained where applicable law permits or requires retention.
Response to Requests
We will respond to authenticated consumer health data requests within the timeframe required by applicable law.
That period is generally within 45 days, although applicable law may permit additional time in certain circumstances.
If additional time is permitted and needed, we will provide notice as required.
Appeals
If we decline to act on an eligible consumer health data request and applicable law provides a right to appeal, you may appeal the decision by contacting:
Hello@StrongFoundationCoaching.com
Subject line:
Consumer Health Data Appeal
Please identify the original request and explain why you believe the decision should be reconsidered.
We will review the appeal and respond within the timeframe required by applicable law.
If applicable law requires us to provide additional information about contacting a state Attorney General or another regulatory authority following an unsuccessful appeal, we will provide that information.
Security
We use reasonable administrative, technical, and physical practices designed to protect consumer health data against unauthorized access, disclosure, alteration, misuse, loss, or destruction.
Access to consumer health data is limited to individuals, service providers, and systems for whom access is reasonably necessary to provide a requested service or fulfill another authorized purpose.
Washington specifically requires businesses subject to its law to restrict access to people and processors for whom access is necessary and to maintain reasonable administrative, technical, and physical security practices.
No electronic communication or storage method can be guaranteed to be completely secure.
Retention
We do not seek to maintain detailed medical information about clients or participants.
Consumer health data is retained only as long as reasonably necessary for the purpose for which it was collected, to provide services you requested, maintain appropriate business records, or satisfy applicable legal obligations.
When detailed health information is not necessary for our services or business records, we seek to avoid retaining it.
Changes to This Policy
We may update this Consumer Health Data Privacy Policy when our services, technology, data practices, or legal obligations change.
The current version will be posted on our website with the effective date shown at the top.
If we materially change the categories of consumer health data we intentionally collect, how we use that information, or the categories of entities with whom it is shared, we will provide additional notice and obtain consent where required by applicable law.
Contact Us
Questions about this Consumer Health Data Privacy Policy or our handling of consumer health data may be directed to:
Strong Foundation Coaching & HR
Jennifer Cortum
Email: Hello@StrongFoundationCoaching.com
Website: www.StrongFoundationCoaching.com