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: '''DRAFT ''' <br />
Revised Date: '''05/22/17''' <br />
Reviewed Date: '''08/24/16'''
Reviewed Date: '''05/22/17'''
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<big>'''Retention and Destruction/Disposal of Private and Confidential Information Policy'''</big>
<big>'''Retention and Destruction/Disposal of Private and Confidential Information Policy'''</big>
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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.  
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, as well as where specific contract provisions specify record rentions requirements.  
 
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.  


If a preservation notice is received, the record retention schedule shall be suspended until the preservation notice terminates.  
If a preservation notice is received, the record retention schedule shall be suspended until the preservation notice terminates.  
===Disposal/Destruction===
===Disposal/Destruction===
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. All confidential waste containers will be secured on the dock areas or at the collection points designated by department policy. UNMC/Nebraska Medicine has contracted with a business associate to properly dispose of paper waste.  
All paper waste must be placed in a recycling container. UNMC will ensure that all confidential paper waste is secured from the time it is collected until the time it is shredded by the selected vendor.


Records scheduled for destruction/disposal should be secured against unauthorized or inappropriate access until the destruction/disposal of information is complete.
Records scheduled for destruction/disposal should be secured against unauthorized or inappropriate access until the destruction/disposal of information is complete.
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*is created or received by UNMC; and
*is created or received by UNMC; and
*relates to the past, present, or future physical or mental health or condition of an individual; the provision of health care to an individual; or the past, present, or future payment for the provision of health care to an individual.
*relates to the past, present, or future physical or mental health or condition of an individual; the provision of health care to an individual; or the past, present, or future payment for the provision of health care to an individual.
 
Records containing PHI, in any form, may not be deleted. PHI contained in the medical record must be accessible at all times.
Records containing PHI, in any form, are the property of UNMC. The PHI contained in the record is the property of the individual who is the subject of the record.  


==Additional Information==
==Additional Information==