Our Privacy Policy
page 5
- all elements of dates (except year) for dates directly related to the individual, including birth date, admission date, discharge date, date of death; and all ages over 89 and all elements (including year) indicative of such age, except that ages and elements may be aggregated into a single category of 90 or older;
- telephone numbers;
- fax numbers;
- electronic mail (e-mail) addresses;
- Social Security numbers;
- medical record numbers;
- health plan beneficiary numbers;
- account numbers;
- certificate/license numbers;
- vehicle identifiers and serial numbers, including license plate numbers;
- device identifiers and serial numbers;
- World Wide Web Universal Resource Locators (URLs);
- internet protocol (IP) address numbers;
- biometric identifiers, including finger and voice prints;
- full face photographic images and comparable images; and
- any other unique identifying number, characteristic or code.
Because de-identified information is no longer considered protected health information, such de-identified information is not subject to the TPO restriction and generally may be used and disclosed without limitation. However, agency staff must obtain approval from Sallyanne Burgess, Privacy Officer or designee that protected health information has been appropriately de-identified prior to treating such information as de-identified information.
D. Uses of Protected Health Information for Reasons Other Than TPO
Agency staff are instructed to consult their department supervisors if they are unsure whether a particular use or disclosure satisfies the definition of TPO, or if they believe they need to use or disclose protected health information for reasons other TPO and they are unsure whether an exception applies or if the agency has obtained an authorization for that particular use or disclosure. The department supervisors will be responsible for providing guidance or directing the individual to the agency staff member or the department better able to provide the necessary guidance.
VIOLATIONS
The agency's Privacy Officer has general responsibility for implementation of this policy. Members of our agency staff who violate this policy will be subject to disciplinary action up to and including termination of employment or contract with Aid to the Developmentally Disabled. Anyone who knows or has reason to believe that another person has violated this policy should report the matter promptly to his or her supervisor or the agency's Privacy Officer. All reported matters will be investigated, and, where appropriate, steps will be taken to remedy the situation. Where possible, Aid to the Developmentally Disabled will make every effort to handle the reported matter confidentially. Any attempt to retaliate against a person for reporting a violation of this policy will itself be considered a violation of this policy that may result in disciplinary action up to and including termination of employment or contract with Aid to the Developmentally Disabled.
QUESTIONS
If you have questions about this policy, please contact your department supervisor or the agency's Privacy Officer immediately. It is important that all questions be resolved as soon as possible to ensure protected health information is used and disclosed appropriately.
Effective Date: April 14, 2003
