Retention and Destruction/Disposal of Private and Confidential Information: Difference between revisions

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Policy No.: '''6056'''<br />
Policy No.: '''6056'''<br />
Effective Date: '''03/17/03'''<br />
Effective Date: '''03/17/03'''<br />
Revised Date:<br />
Revised Date: '''12/15/15''' <br />
Reviewed Date:<br />
Reviewed Date: '''12/15/15'''
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<big>'''Retention and Destruction/Disposal of Private and Confidential Information Policy'''</big><br />
<big>'''Retention and Destruction/Disposal of Private and Confidential Information Policy'''</big>
'''NOTE''': These guidelines are provided to assist UNMC workforce, including those in the patient treatment areas of the Munroe-Meyer Institute, the College of Medicine Optical Shop, the Lions Eye Bank and the College of Dentistry, as applicable, comply with HIPAA regulations. Those departments and clinics which fall under the jurisdiction of  The Nebraska Medical Center and/or University Medical Associates should consult the policies and procedures of those entities for authoritative guidance.
== Basis for Policy ==
== Basis for Policy ==
Retention and subsequent destruction/disposal of proprietary and protected health information are governed by federal and state regulations and University policies and procedures. These regulations and guidelines include, but may not be limited to:
Retention and subsequent destruction/disposal of proprietary and protected health information are governed by federal and state regulations and University policies and procedures. These regulations and guidelines include, but may not be limited to:
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==Policy==
==Policy==
===Retention===
===Retention===
It is the policy of the University of Nebraska Medical Center (UNMC) and its affiliated entities to ensure the privacy and security of proprietary and protected health information in the maintenance, retention, and eventual destruction/disposal of such media. All destruction/disposal of patient health information media will be done in accordance with federal and state law and pursuant to the UNMC Record Retention Schedule. Records that have satisfied the period of retention will be destroyed/disposed of in an appropriate manner.  
It is the policy of the University of Nebraska Medical Center (UNMC) and its affiliated entities to ensure the privacy and security of confidential information in the maintenance, retention, and eventual destruction/disposal of such media. All destruction/disposal of confidential information media will be done in accordance with federal and state law and pursuant to the UNMC Record Retention Schedule. Records that have satisfied the period of retention will be destroyed/disposed of in an appropriate manner.  


The retention schedule for destruction/disposal shall be suspended for records involved in any open investigation, audit, or litigation. Individuals who know or suspect that confidentiality has been breached by another person or persons have a responsibility to report the breach to the respective supervisor or administrator or to the Human Resources Department. Employees should not confront the individual under suspicion or initiate investigations on their own, as such actions could compromise any ensuing investigation. All individuals are to cooperate fully with those performing an investigation pursuant to this policy.  
The retention schedule for destruction/disposal shall be suspended for records involved in any open investigation, audit, or litigation. Individuals who know or suspect that confidentiality has been breached by another person or persons have a responsibility to report the breach to the respective supervisor or administrator or to the Human Resources Department. Employees should not confront the individual under suspicion or initiate investigations on their own, as such actions could compromise any ensuing investigation. All individuals are to cooperate fully with those performing an investigation pursuant to this policy.  
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Department administration shall determine what information entrusted to their department is private and/or confidential and shall communicate methods of protecting that information through the destruction/disposal process to appropriate persons associated with their department.   
Department administration shall determine what information entrusted to their department is private and/or confidential and shall communicate methods of protecting that information through the destruction/disposal process to appropriate persons associated with their department.   


All paper waste must be placed in a recycling container. Environmental Services (EVS)is responsible for the security, transport and storage of confidential paper waste from internal customer locations. EVS will secure the confidential waste in locked containers provided by the UNMC Recycling Center. All confidential waste containers will be secured on the dock areas or at the collection points designated by department policy. As recycling containers are transported on the trucks to the Recycling Center, they will be the responsibility of the UNMC Recycling Center staff. The UNMC Recycling Center will be responsible for disposing of the recycled material in a secure manner and ensuring that all documentation necessary for demonstrating compliance with regulations is maintained. Failure to appropriately dispose of/destroy private or confidential information may result in sanctions, civil or criminal prosecution and penalties, scholastic or employment corrective action which could lead to dismissal or, as it relates to health care professionals or others outside of UNMC, suspension or revocation of all access privileges.  
All paper waste must be placed in a recycling container. Environmental Services (EVS) is responsible for the security, transport and storage of confidential paper waste from internal customer locations. EVS will secure the confidential waste in locked containers provided by the UNMC Recycling Center. All confidential waste containers will be secured on the dock areas or at the collection points designated by department policy. As recycling containers are transported on the trucks to the Recycling Center, they will be the responsibility of the UNMC Recycling Center staff. The UNMC Recycling Center will be responsible for disposing of the recycled material in a secure manner and ensuring that all documentation necessary for demonstrating compliance with regulations is maintained. Failure to appropriately dispose of/destroy private or confidential information may result in sanctions, civil or criminal prosecution and penalties, scholastic or employment corrective action which could lead to dismissal or, as it relates to health care professionals or others outside of UNMC, suspension or revocation of all access privileges.  
===Definitions===
===Definitions===
'''Information''' is data presented in readily comprehensible form.  (Whether a specific message is informative or not depends in part on the subjective perceptions of the person who receives it.)  Information may be stored or transmitted via electronic media, on paper or other tangible media, or be known by individuals or groups.  Information generated in the course of University operations is a valuable asset of the University and belongs to the University.  
'''Information''' is data presented in readily comprehensible form.  (Whether a specific message is informative or not depends in part on the subjective perceptions of the person who receives it.)  Information may be stored or transmitted via electronic media, on paper or other tangible media, or be known by individuals or groups.  Information generated in the course of University operations is a valuable asset of the University and belongs to the University.  
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==Additional Information==
==Additional Information==
*Contact the Privacy Officer
*Contact the [mailto:infosecurity@unmc.edu Information Security Office]
*UNMC Privacy, Confidentiality and Information Security Procedures
*Procedure No. 6056, [http://www.unmc.edu/its/security/procedures/destruction-confinfo.html Destruction of Private and Confidential Information]
*UNMC Destruction of Private and Confidential Information Procedures
 
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