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Table-Top Privacy Breach Fire Drill

Table-Top Privacy Breach Fire Drill

What is a Table-Top Privacy Breach Fire Drill?

A table-top privacy breach fire drill is a cost-effective way to prepare for a privacy and security incident in your healthcare organization. You should have a written privacy breach incident response plan in your healthcare practice. Have you practiced your response plan lately?

A table-top privacy breach fire drill allows your incident response team to rehearse their skills in a controlled exercise.

Do you remember your school days when every month or two you had a fire drill? The fire alarm would go off and everybody would go out the doors and very calmly go down the stairs and out the doors and into their muster point.

We take the same approach with privacy breach fire drills. Fires can happen at different times, places, and for different reasons. Whey you change the scenario, you develop alternate strategies or playbooks to best respond to the fire.

A privacy breach incident playbook contains all the actionable steps to take when a privacy beach incident occurs. Your playbook will have many ‘plays’ or actions to take when different types of privacy breach incidents occur. You could also think of it as a recipe book. You have many types of recipes to select from. Identify the ingredients that you have on hand (or the characteristics of the latest privacy incident) and select the most appropriate recipe to resolve the incident.

The Importance of Practicing Your Privacy Breach Response Plan

Healthcare providers, owners, and privacy officers hear about big privacy breaches on the news and hope it won’t happen to them. It keeps them up at night…because they know that properly preventing or managing a privacy breach is critical to the continued success of their business. Implementing a table-top privacy breach fire drill will help!

Picture this. You call a meeting of your incident response team. This may include your privacy officer, computer network support or managed services provider lead, physician, dentist, or other healthcare lead, your media spokesperson, and clinic manager. The privacy officer distributes a privacy breach incident scenario summarized on one page.

The team members read the scenario and then discuss what steps that they would take to respond to the privacy breach incident.

Using the 4 Step Response Plan as your playbook guideline, the incident response team note-keeper documents the hypothetical steps that the team takes to respond to the breach. Record the decisions, the resources, and the questions that you explore in this scenario.

When the table-top exercise is complete, you now have a detailed action steps that you can take when a similar privacy incident occurs in your healthcare practice.

How To Use The Table-Top Privacy Breach Fire Drill Technique

The goal of a privacy breach fire drill is to develop your playbook so you can spring into action when a similar privacy and security incident occurs in your healthcare practice.

Real-World Scenarios: Turning Headlines into Practice Drills

First, identify a scenario that could happen in your practice. Unfortunately, it’s easy to find an example about a privacy and security breach in the news. Grab a privacy breach example and pull out the bits and pieces of the information that might apply to your organization. When you select scenarios that could happen in your organization the exercise is more meaningful for you, and you will develop tools and templates that are going to help you in the event that a very similar privacy and security incident happens in your organization.

Let’s use the recent privacy breach incident that came from the province of Saskatchewan* when a cybersecurity attack that happened in their E-Health system. This attack may have started when an employee who had authorized access to the e-health system used a personal tablet to connect with a USB to the Saskatchewan health authority’s computer. This enabled a virus from that personal tablet to infect the computer system and ultimately the e-health system, allowing millions of files to be stolen. Strip the example down to its key points. Create additional details and assumptions where needed to give the team members enough information to discuss the scenario during the fire drill exercise.

Step 1 Contain The Breach Immediately

The first step in every incident is to spot and stop the breach. Make an assumption that the employee who connected the personal device to your computer is now seeing that message on the screen that says that there’s a virus in the system. One of your incident team members plays the role of the employee and completes Step 1 of the privacy breach incident response form and notifies their supervisor or the privacy officer.

Another team member assumes the role of the privacy officer and explains what their next action steps would be.

Record each action that you consider. Document each policy, resource, phone number and email address that you would use in a real event. This creates the action steps in your playbook.

Step 2 Evaluate the Risks Thoroughly

Discuss the risks that could affect the computer systems. What tools do you need to evaluate the harm of this incident? How might this affect patient care and the privacy of patient information?

Contact your vendors and ask them to contribute to the risk assessment in this scenario.

Who else might you want to call on for assistance to investigate this incident?

You might want to revisit the news item for additional information about the actions that were taken that you might also need to explore.

In your playbook, record good leading questions to help you to investigate the incident and evaluate the risks of harm.

Step 3 Notify the Right People and Authorities

Strategize who you would notify about the incident. Prepare written notification to the custodians, patients, regulators and even media statements. These become templates in your playbook that you can quickly implement in your real event.

Role-play your media spokesperson being interviewed on the evening news. It’s much better to practice now, before you are in a crisis.

Step 4 Prevent the Breach From Happening Again

This might be the most valuable step in the privacy breach fire drill. Complete the privacy breach incident worksheet and summarize this practice scenario. Consider how likely this scenario could happen in your practice. What type of training could be done now to prevent this from happening? What tools or training do your incident response team members need today to make it easier for them to monitor and prevent this scenario from happening?

The Benefits of Regular Privacy Breach Fire Drills

At the conclusion of this fire-drill, your team is ready, energized, and have the tools that they need to make sure that they can respond to that privacy and security breach as quickly as possible. This absolutely is a great investment in your time. These table-top privacy breach fire drills are a great demonstration of your commitment as an organization to ensure that you are protecting the privacy confidentiality and security of health information.

 

Strengthen Your Privacy Defense with Table-Top Drills

In-Person Workshop Coming to a Region Near You!

If you are a clinic manager, privacy officer, information technology support, or administrative lead responsible to prevent and to respond to a privacy breach of personally identifying health information, register now to participate in this practical workshop near you!

Find Out More!

The Top 3 Agreements Your Healthcare Practice MUST Have (and Why)

The Top 3 Agreements Your Healthcare Practice MUST Have (and Why)

In order to provide services, healthcare practices must collect pertinent information from patients. This data gathering often includes many sources of information, across different types of technology, among multiple vendors. Good business practices and health records management is supported by three agreements your healthcare must have: information manager agreement (IMA), information sharing agreement (ISA), and successor custodian agreement.

For instance, when a patient attends a clinic, their details are nearly always entered into a computer software program to maintain demographic information, manage patient appointments, and to process payments. Often, health service providers (including physicians, pharmacists, chiropractors, dentists, psychiatrists and more) record their patients’ notes into an electronic medical record (EMR).

Patient information is shared between providers where required. For example, when the patient visits a diagnostic lab for testing, results are often transmitted electronically to the ordering physician’s fax machine or to the EMR.

Custodians including physicians, pharmacists, chiropractors, dentists, and psychiatrists, as defined by the Alberta’s Health Information Act (HIA), must follow HIA legislation when they collect, use, and disclose health information.

Often, custodians are also the owners of independent healthcare practices. However, an owner of a healthcare practice is not the custodian if they are not also an active member of a regulated health profession named as custodians in the HIA.

1. Information Manager Agreement

The HIA allows custodians to contract with other health service providers and vendors for the purposes of providing information management or information technology services, so patients can receive health services, and make payments. This often requires the custodian to share patient information with a vendor (or give them access to) so the vendor can process, store, or provide information as needed.

The custodian selects one or more business to provide the services, equipment, or software to assist in the management of health information. For example: EMR provider, contracted transcriptionist, billing agent, remote backup service, etc. These businesses are known in the HIA as information managers.

Before sharing health information with someone else, the custodian must ensure that the partners and vendors have reasonable safeguards in place to protect sensitive health information. The custodians must ensure that there is a written agreement between the custodian and the information manager. These agreements are known as “Information Manager Agreements.” This requirement is stated in the HIA section 66(2).

The Information Manager Agreement (IMA) is one of three crucial agreements a healthcare practice must have in place.

If You Don’t Have an IMA

If you are a custodian who uses vendors as part of your business and you do not have an IMA with that vendor…

  • You are in breach of the HIA.
  • You may incur fines under the HIA.
  • You may face sanctions and disciplinary actions from your professional regulatory college.
  • Almost certainly, you will encounter conflicts, poor communication, between yourself and the vendor(s) and the other participating custodians in your practice.
  • You may lose control of the health information as reported in the Investigation Report H2013-IR-01from the Alberta Office of the Information and Privacy Commissioner (OIPC).

In a press release from the Alberta OIPC in 2013, Information and Privacy Commissioner Jill Clayton noted that:

“The HIA allows custodians to disclose health information to IT service providers, such as EMR vendors, under an appropriate Information Manager Agreement. When custodians do not sign these agreements, they may find themselves in the unfortunate position of losing control over the health information they need to provide health services.”

Investigation Report H2013-IR-01 (https://www.oipc.ab.ca/news-and-events/news-releases/2013/investigation-report-h2013-ir-01.aspx)

Who Must Create the Information Manager Agreement?

The custodian is responsible to ensure that there is an appropriate IMA created and signed.

The information manager can assist the custodian by preparing templates of the IMA including specific details of the services that they will provide and the safeguards that the vendor will implement to protect personal health information.

Key Points About IMAs

A few important notes about IMAs.

  • IMA must be signed by the custodian.
  • Agreements signed by individuals who are not custodians are not valid under the HIA.
  • Custodians are required under the HIA to have an IMA with the vendor before disclosing health information. If there is no agreement in place, the custodian is in breach of the HIA.
  • Custodians are responsible for the health information that they collect, use, and disclose. Therefore, the custodian is responsible for the IMA and to ensure that the health information will be handled confidently and securely.

Key Points IMA

The custodian can select the best vendor and information manager for the job. The vendor who understands the requirements of the HIA and who can demonstrate that they have implemented the appropriate reasonable safeguards and can assist the custodian to develop an appropriate IMA is, in my opinion, demonstrating a significant competitive advantage.

All healthcare providers in a community practice should spend time when creating their business to establish good business practices, including developing written contracts and agreements to improve the efficiency of the business and to make things happen in the way that they are planned.

Here is a common example

Dr. Alice and Dr. Mark created a welcoming family medical practice in a new sub-division of their city. They each worked hard to attract new patients, hire and train staff, and develop a profitable business.

In the last few years, Alice and Mark had differences of opinion on how to grow their business. In the end, Alice decided that this type of practice wasn’t for her. She decided to leave and join a larger practice in a neighbouring subdivision. Alice wanted to take her patient’s records with her to her new practice and continue to see her patients at the new location.

Mark, who had signed the IMA with the EMR vendor, did not agree to Alice’s request to transfer her patient records to her new group practice.

Alice and Mark argued and eventually involved a professional mediator to help them resolve their business conflict. Hurt feelings between the providers and staff, costly delays in their business and expenses could have been avoided if Alice and Mark had established clear expectations in the event of the termination of their business partnership when they started their group practice. An IMA between custodians in a group practice is a recommended best practice.

When You Have Multiple Custodians in Your Healthcare Practice

When the practice has multiple providers, the owner and custodian frequently assumes responsibility for maintaining the contracts and IMAs with the vendors. Each of the participating healthcare providers may delegate the responsibility of maintaining the vendor arrangements to the custodian owner. This can be achieved with an IMA between the owner / custodian and each participating custodian.

Custodian Owner IMA

Each healthcare provider custodian is considered the custodian of the health information that they collect. The custodians can jointly agree to all use the same EMR. This provides continuity of care for the patients and economy of scale for the participants of the practice.

When the owner/custodian signs the agreement with the EMR, they become the signatory custodian. The EMR vendor takes their instructions from the signatory custodian.

The owner / custodian is now an information manager for all the participating custodians.  but does not become a custodian of the health information provided to them in their roles as an information manager.

For example,

Dr. Bill opened his medical practice, ABC Clinic. Later, additional physicians were recruited to work at ABC Clinic. The physicians are each custodians as defined by the HIA.

Dr. Bill assumes the responsibility for the operations of the clinic including the computer network and the contract with the EMR vendor. Dr. Bill is the information manager for the patient records at the clinic.

Each physician signs an IMA with Dr. Bill and agree that he will continue to manage the patient records on their behalf. Dr. Bill is operating as an information manager.

In his role of the information manager, Dr. Bill must follow the instructions from each physician, the custodian, as it relates to the management of their patients’ records.

2. Information Sharing Agreement (ISA)

When you have more than one physician in your practice, you need an agreement about how you will decide to manage the personal health information in your practice.

An Information Sharing Agreement (ISA) focuses on the internal decision making about all things related to personal health information whereas, an IMA is an agreement with a single vendor about the services that the vendor provides.

ISA IMA

An ISA may include things related to the services that a vendor provides but is not limited to just vendor services.

It also includes decisions about the process to ensure appropriate role based access to personal health information in the EMR, computer network, and paper formats; the regular review of health information privacy and security policies and procedures, ensuring privacy and security awareness training, the regular review of administrative, technical, and physical safeguards in the practice, and so on.

In larger organizations or when several smaller organizations participate in an information sharing initiative, a Data Management Committee may provide oversight and facilitate this process.

An ISA is a requirement of the College of Physicians and Surgeons of Alberta.

Identifying a successor custodian is also a requirement of the College of Physicians and Surgeons (CPSA).

3. Successor Custodianship Agreement

As a business owner, you need to plan a successor to the business. This might be an interim or short-term decision to ensure continuity during an absence or future retirement planning or unexpected illness or death.

In healthcare, physicians and custodians have the added responsibility as the ‘gatekeeper’ for patient records. In the event of a sudden inability to meet these responsibilities, physicians need to identify a successor custodian to ensure appropriate and continued access by patients to their health information for their continuing care and treatment and to ensure that the continuing confidentiality, security, and access to patient records continue to be fulfilled.

Have you identified a successor custodian? Each of the physicians in your group practice should also identify their own successor custodian.

This is a CPSA requirement and should also be included in the Privacy Impact Assessment if you have this information available. See CPSA, Patient Record Retention, s.5:

A regulated member acting as a custodian must designate a successor custodian to ensure the retention and accessibility of patient records in the event the regulated member is unable to continue as custodian. (Reference: Health Information Act Section 35(1)(q)

If you are a chiropractor, the Alberta College and Association of Chiropractors (ACAC) further requires its members to name a chiropractor as the successor custodian to maintain the status of ‘chiropractic’ records. (See the ACAC’s Standards of Practice s5.3 Custodianship of Health Records.)

A chiropractor, as a custodian of health records, is responsible for the care and control of the health records in their practices as required by the Health Information Act of Alberta. A custodian of active chiropractic files must be under the custody or control of an active, registered member of the ACAC.

Note that under the Health Information Act, a chiropractor may disclose files to another custodian who is not a chiropractor, and only a chiropractor may have custody or control of chiropractic files. Chiropractic files disclosed to a non-chiropractor should no longer be considered chiropractic files.

A custodian must implement technical and physical safeguards to protect the confidentiality of the information and privacy of individuals as well as protections against reasonably anticipated threats to the security or integrity of the information. A custodian must also defend against unauthorized uses, disclosures or modifications of the information. Safeguards must be periodically assessed and documented in policies and procedures.

If you are working in an owner/custodian scenario discussed above, clearly identifying a successor custodian becomes imperative. An unplanned absence of the owner / custodian can seriously jeopardize the business and the continuing care and treatment of patients.

The custodian can, but is not required to, name another custodian in the same practice to be their successor. Whatever your decision, ensure that this is well documented and easily accessible to the other custodians and key decision makers in your organization in the event of an emergency.

The best time to create IMA, ISA, and Successor Custodianship Agreements is when you start your healthcare business.

The second best time in now.

What are you waiting for?

If you need assistance, contact Jean L. Eaton, Your Practical Privacy Coach and Practice Management Mentor with Information Managers. I’m here to help you with your Practice Management Success.

Download the FREE Report – Top 3 Agreements Your Healthcare Practice MUST Have

If you are a member of Practice Management Success, login here to access the Top 3 Agreements.

 

When we know better, we can do better…

Jean L. Eaton is constructively obsessive about privacy, confidentiality, and security especially when it comes to the handling of personal health information. If you would like to discuss how I can help your practice, just send me an email. I am here to help you.

Jean L. Eaton
Your Practical Privacy Coach
INFORMATION MANAGERS

 
Build a Strong Privacy Management Program for Your Clinic with These 5 Critical Modules

Build a Strong Privacy Management Program for Your Clinic with These 5 Critical Modules

Build a Strong Privacy Management Program for Your Clinic With These 5 Critical Modules

Many privacy officers in small healthcare practices have other roles—as a clinic manager, healthcare provider, computer network technician, or business owner. It is little wonder that new privacy officers can feel overwhelmed when trying to balance these responsibilities every day.

But that’s not the end of the problem. It actually gets worse!

You could continue to –

😮 Panic when a patient asks for their information for access or correction.

😔 Scramble when new employees and healthcare providers join your clinic . . .and suddenly realize that you never got around to providing privacy and cybersecurity awareness training.

😯 Hope that your practice will not be tapped on the shoulder for a practice review by your college or the OIPC.

🤐 Ignore privacy breach and hope no one else notices.

😒 Avoid difficult decisions with your owners / staff who insist on doing things their way – even when it is not privacy compliant.

😞 Never get ‘review privacy impact assessment’ and ‘review privacy policies and procedures’ off of your to-do list.

😥 Avoid discussing privacy and security with your EMR and computer networks managed service providers because you are unsure of what questions to ask and what types of answers you should receive.

If you don’t have a written privacy management program and action plan, you are missing the systems to monitor routine tasks that will protect privacy and alert you to potential problems before they become privacy and security incidents.

Carrying out the duties of a Privacy Officer correctly is vital to ensure your organization is safe from the consequences of a big privacy breach.

But did you know that those organizations who have a privacy officer and a privacy management program are:

  • Less likely to have a privacy or security incident
  • Increased staff satisfaction
  • Increased patient satisfaction and outcomes

We Know That Privacy Is Good For Business

​We know that having policies, procedures, and systems in place will improve your privacy compliance in your organization and help you make good business decision.

When we have consistent practices in place, it improves communication and prevents a multitude of problems.

I’d like to share with you what I believe are the 5 critical modules of a privacy management program

The 5 Modules of a Strong Privacy Management Program for Your Clinic includes

  1. Know Your Obligations
  2. Train
  3. Privacy Breach Management
  4. Document
  5. Access and Disclosure

We expect organizations which collect, use, or disclose health information to have key components of a privacy accountability program. These include:

Every healthcare and private organization that is subject to privacy laws must comply with them. A comprehensive privacy management program provides an effective way for organizations to create a culture of privacy in their practice, practice accountability for the collection, use, disclosure, and access of personal information, and show compliance with regulations.

Module 1—Know your Obligations

​Key accountability for your privacy management program starts with your healthcare provider(s). These are also known as “custodians”. They are ultimately responsible for the privacy, confidentiality and security of personal health information (PHI).

The key healthcare provider—physician, dentist, chiropractor, nurse—can assign or delegate a key person who is accountable to the custodian to implement and monitor a privacy management program. This is often known as a privacy officer. In many smaller healthcare practices, the clinic manager or practice manager is also the privacy officer.

The business owner (who might also be the healthcare provider) also has obligations to follow the privacy laws as it relates to the privacy of personal information of employee, customers, and general business information.

The healthcare provider, business owner, and privacy officer form a ‘trifecta’ of authority and responsibility in your practice to ensure that you comply with privacy legislation, professional standards of practice, and contractual commitments.

Knowing your obligations includes clear authority and accountability in your practice, inventory of identifying information that you have in your practice, and understanding how privacy legislation guides your business. Your privacy officer and custodians may require training in these areas to better understand their obligations.

Module 2—Training for Privacy Awareness

​Training is an important component of your privacy management program. The privacy officer in your organization ensures that privacy awareness, cybersecurity, and privacy breach management are provided in your healthcare practice.

There should be both a formal and an informal training plan. A pre-planned privacy awareness training must be available for everyone in your organization, including new and seasoned professionals. It is critical that you can provide and document that everyone in your organization completed consistent common training.

We can provide informal training throughout the year. For example, have a standing agenda item during your staff meeting to do something consistently for everyone in the organization throughout the year. Leverage activities like Data Privacy Day, Change Your Password Month, Cybersecurity Awareness Week to provide a variety of content.

A frequently missed trigger for additional training happens when an employee is promoted to a new position. This is a great opportunity for the privacy officer to meet with the employee and discuss their new role and how their responsibility, for example, of authorizing new users or supervising employees contributes to the confidentiality and security of PHI.

Remember to document who attended the training opportunities and keep copies of the training content to show your actions to protect privacy.

Listen to the podcast How To Keep Privacy Awareness Top Of Mind | Episode #093 for more tips and resources to help you plan training throughout the year.

Module 3 – Effective Privacy Breach Management

​Ensure that a written privacy breach management procedure is part of your overall privacy management program. The privacy officer will document your privacy breach management policies and procedures, sanctions policies and procedures, and train all employees to identify a privacy breach and report it to their supervisor. The privacy officer will manage a (suspected) privacy breach and ensure notification to their custodians, individuals affected by the breach, and others as needed.

The privacy officer will manage mandatory privacy breach notification requirements under the health privacy legislation like the Alberta Health Information Act (HIA), Ontario Personal Health and Information Protection Act (PHIPA) and the Personal Information Protection of Electronic Documents Act (PIPEDA) and other province’s legislation.

See Understanding a Privacy Breach for more tips.

Module 4—Documentation: The Backbone of Privacy Compliance

​I think most people in healthcare are familiar with the adage, “If it is not documented, it didn’t happen.” This applies to your privacy management program, too. Your program should include written:

  • Health Information Privacy and Security Policies, Procedures
  • Risk Assessment – Safeguards
  • Practical Privacy Review
  • Privacy Impact Assessment
  • Information Management Agreement
  • Information Sharing Agreement
  • Successor Custodian
  • Training plan

These actions will help you protect the PHI of your patients and your business. They help to demonstrate your compliance with your privacy and security obligations. Review and update these key documents annually.

See Privacy Impact Assessment for more tips.

Module 5 – Access and Disclosure: Ensuring Patient Rights

​When you collect PHI from patients and PI from employees and customers, you must ensure that they can access, correct, and authorize disclosure of their information.

Release of information (ROI) policies and procedures is a critical module of your privacy management program. Your privacy officer is tasked with ensuring that your ROI plan is written, understood, includes specific training to your employees, and follows legislated standards and professional college standards of practice. When you meet your ROI obligations, you avoid complaints and breaches, work efficiently, and improve the trust of your patients.

Struggling to Learn Your Role As A Privacy Officer On Your Own?

If you are a privacy officer in a healthcare practice who needs practical privacy management strategies to protect your patients and your healthcare business but aren’t sure how to get started, register for the Practical Privacy Officer Strategies training here.

The training starts on April 11, 2024.

Not sure if this is for you?

Send me an email and ask me! I’m happy to mentor you and help you assess your practice management and privacy compliance priorities.

Listen to the replay of my recent LinkedIn Live Event here.

 
Do You Want To Be A Confident Healthcare Privacy Officer?

Do You Want To Be A Confident Healthcare Privacy Officer?

 

Understanding the Role: What Is a Privacy Officer?

A privacy officer is a key employee in a healthcare organization who is named by the healthcare provider (custodian) and assigned the responsibility to oversee all activities related to the implementation of, and adherence to, the organization’s privacy practices, and to ensure operational procedures are in compliance with relevant privacy laws. The Privacy Officer monitors employees and systems about how information is collected, used, and disclosed and access to identifying information.

A privacy officer may be known by other titles like privacy compliance officer or a security officer.

If your healthcare business involves the collection, use, and disclosure of your clients’ and patients’ personal health information, a privacy officer is necessary in order to meet legislated requirements.

Consequences of Operating Without a Privacy Officer

Healthcare practices without a privacy officer often experience confusion about how patients’ personal health information should be collected, used, and disclosed. Patients may complain about lack of access to their personal health information. Without a named privacy officer to assume the responsibility to implement and monitor reasonable administrative, technical, and physical safeguards you are more likely to experience privacy and security incidents, privacy breaches, investigations, fines, and charges under the privacy legislation!

Case Studies: Real-world Implications of Privacy Officer Absence

In 2019, the British Columbia Office of the Information and Privacy Commissioner (OIPC) conducted a privacy audit of 22 medical clinics. OIPC auditors examined 22 clinics and found gaps in privacy management programs at several clinics, including the absence of a designated privacy officer, a lack of funding and resources for privacy and a failure to ensure that privacy practices keep up with technological advances.

Here’s another example. A complaint was made against a medical clinic with an employee suspected of accessing health information for an unauthorized purpose. The Alberta OIPC investigated and revealed confusion around the roles and responsibilities of privacy compliance among the custodians and the privacy officer. The OIPC determined that the custodian was in contravention of the regulation which requires custodians to ensure that their affiliates are aware of and adhere to the all of the custodian’s administrative, technical, and physical safeguards with respect to health information. 

Say No to Snooping: The Need for Privacy Enforcement

Employees are not aware of privacy requirements and engage in snooping into personal health information. Consequences of employee snooping include firing, charges under the Health Information Act and court ordered fines, jail time, probation, community service and more. 

say not so snooping animation of thief taking papers from folder

Roles and Responsibilities of a Healthcare Privacy Officer

So, what does a privacy officer do? The roles and responsibilities of a privacy officer in a typical healthcare practices include the following:

  • Identify privacy compliance issues for the business.
  • Ensure privacy and security policies and procedures are developed and keep them up to date.
  • Ensure that everyone working at your clinic and your vendors are aware of their privacy obligations.
  • Monitor your clinic’s ongoing compliance with privacy legislation like the Health Information Act (HIA) in Alberta.
  • Provide advice and interpretation of related legislation for the business.
  • Respond to requests for access and corrections to personal information.
  • Ensure the security and protection of personal information in the custody or control of the business.
  • Act as the primary point of privacy and access contact for staff, patients, vendors, regulators and other stakeholders.

Get the FREE Practice Management Success Tip, Privacy Officer Job Description Template.

 

 
Do You Need to Build a Privacy Awareness Training Plan in Your Healthcare Practice?

Do You Need to Build a Privacy Awareness Training Plan in Your Healthcare Practice?

One of the most frequent questions that I receive is “Jean, how often do we need to do privacy awareness training?”

Structured training should be available at least annually.  Just-in-time training and informal reminders can keep privacy top of mind year-round.

In the fast-paced world of healthcare, safeguarding patient privacy isn’t just a legal obligation—it’s a fundamental aspect of quality care delivery. However, ensuring that every staff member understands their role in maintaining confidentiality can be a complex challenge. This is where a robust privacy awareness training program comes into play.

When you have a written practical privacy awareness training plan, you will save clinic managers’ time, manage the risk of employee compliance, and motivate employees to become informed privacy advocates for your patients.

Not Just for New Employees

Privacy awareness training is more than a checklist when new employees are hired.

From receptionists to physicians, every member of a healthcare practice plays a pivotal role in protecting patient information. Contrary to common belief, privacy awareness training isn’t a onetime event; it’s an ongoing necessity. By conducting regular training sessions, staff members are kept up to date on regulations and best practices, which helps to prevent compliance breaches.

As an employer and health care provider, you are responsible for providing regular training to all your employees about privacy awareness.

The Vital Role of the Privacy Officer

The privacy officer spearheads the planning, implementation, and monitoring of privacy training initiatives. Their active involvement is crucial in protecting the organization from legal and reputational risks, through facilitating sessions and ensuring policy compliance.

Mitigating Risks and Ensuring Compliance

Without adequate training, healthcare providers face increased risks of privacy breaches. Ignorance of policies and procedures is not an excuse in the eyes of the law. Organizations that neglect privacy awareness training not only jeopardize patient trust but also expose themselves to severe penalties.

Protect Your Organization and Your Patients

Equip your staff with the information they need to confidently and correctly handle personal health information. Healthcare businesses who want employee and supervisor level privacy awareness training to support key policies, procedures and risk management programs need a privacy awareness training program.

Crafting Your Comprehensive Training Plan

Crafting an effective privacy awareness training plan need not be overwhelming. That’s why we’re excited to offer a **60-minute free webinar** designed specifically for clinic managers and privacy officers. In this webinar, you’ll learn how to design and implement a year-round training plan tailored to your practice’s needs.

Webinar Highlights

  • Practical strategies for developing a comprehensive training plan
  • Real-life scenarios and best practices for mitigating privacy risks
  • Tips for managing staff members who may struggle to grasp privacy concepts
  • Resources to kick-start your training initiatives immediately

 

Don’t miss this opportunity to elevate privacy standards within your healthcare practice. Register now for our **free 60-minute webinar** and equip your team with the knowledge and skills to safeguard patient confidentiality effectively.

When you invest in training, medical clinics show their commitment to protecting patient privacy and upholding the highest standards of professionalism. Join us for our upcoming webinar and take the first step towards fostering a culture of privacy excellence in your practice.

 

Build a Privacy Awareness Training Plan for Your Healthcare Practice

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What are you waiting for?

Click here to start your membership today and watch this training webinar right away!

 

This Webinar Includes

  • Live on-line training
  • Q&A with Jean Eaton, Your Practical Privacy Coach when you join the webinar live
  • Access to the replay for a limited time
  • Learning Resources Guide
  • Training Plan Template
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