The sample notice of privacy has sections that address situations that our facilities just do not have, e.g. A facility directory, marketing, and fundraising. Can we take out these sections if we don’t have a facility directory, and don’t do fundraising or marketing?

Yes. We left it in because some of our providers have facility directories of some sort; e.g. large single site facilities might have a switchboard with a directory, or a small facility might have names on mailboxes that are open to the general public. For these agencies, it is wise to leave this in and to give clients an opportunity to object. Regarding fundraising – if you believe that you will never perform fundraising, you may take it out, but given the fiscal times we are in, you might change your position. On Marketing, if you ever use a client’s name or face on a brochure, in a newsletter, or in an ad, you should leave this in.