School Board of Charlotte County
Bylaws & Policies
 

4430.05 - PRIVACY POLICY FOR EMPLOYEES/APPLICANTS PROTECTED HEALTH INFORMATION (PHI)

It is the policy of the School Board that all staff that has access to Protected Health Information (PHI) (hereafter "staff") preserves the integrity and the confidentiality of PHI pertaining to employees/applicants by adhering to the following requirements:

 A.Adhering to the standards set forth in the Notice of Privacy Practices;
 B.Collecting, using, and disclosing PHI only in conformance with state and federal laws and current procedures;
 C.Honoring employees'/applicants' covenants and/or authorizations, as appropriate;
  District staff will not use or disclose PHI for uses outside of District's treatment, payment, and health care operations (TSO), such as marketing, employment, life insurance applications, etc., without an authorization from employee/applicant.
 D.Using and disclosing PHI to remind employees/applicants of their appointments only within their consent;
 E.Recognizing that PHI collected about employees/applicants must be accurate, timely, complete, and available when needed;
  Privacy practices shall be implemented to protect the integrity of all PHI maintained.
 F.Respecting employees'/applicants' privacy to the extent allowable by law;
 G.Acting as responsible information stewards by adhering to the following:
  1.Treating all PHI data as confidential in accordance with professional ethics, accreditation standards, and legal requirements;
  2.Not disclosing PHI data unless the employee/applicant (or his/her authorized representative) has properly consented to or authorized the release, or the release is otherwise authorized by law;
 H.Recognizing that, although our District "owns" the medical information, the employee/applicant has a right to inspect and obtain a copy of his/her PHI;
  In addition, employees/applicants have a right to request an amendment to his/her medical information is s/he believes his/her information is inaccurate or incomplete.
  1.Employees/Applicants shall be permitted access to their medical information.
  2.Employees/Applicants shall be provided an opportunity to request the correction of inaccurate or incomplete PHI in their medical information in accordance with the law and professional standards.

All staff of our District shall maintain a list of all disclosures of PHI for purposes other than TPO for each employee/applicant. We will provide this list to employees/applicants upon written request.

All staff of our District shall adhere to any restrictions concerning the use or disclosure of PHI that employees/applicants have requested and have been approved by our District.

Violation of this policy is grounds for disciplinary action, up to and including termination of employment and criminal or professional sanctions in accordance with our District's personnel rules and regulations.

Any changes to this policy will be effective upon the release of a revised privacy policy and shall be made available to employees/applicants.

F.S. 626.9651
HIPAA, Pub. L. 104-191
45 C.F.R. 160.102, 160.103

Revised 8/24/10