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: '''08/29/22 draft''' <br />
Revised Date: '''10/28/22 draft''' <br />
Reviewed Date: ''' '''
Reviewed Date: ''' '''
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Large volumes of CDs may be forwarded to Environment Services.
Large volumes of CDs may be forwarded to Environment Services.
|-
|-
| Cell Phones || Cell phones which are no longer in use shall be returned to Information Technology who will dispose of the equipment.
| Cell Phones || Cell phones which are no longer in use shall be returned to Information Technology which will dispose of the equipment.
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|-
| Computerized Data/Hard Disk Drives
| Computerized Data/Hard Disk Drives
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===Destruction of Paper===
===Destruction of Paper===
#Handling and Security Procedures
#Handling and Security Procedures
##Departmental management and Environmental Services should jointly develop a plan for the security, transport and storage of confidential materials from customer departments to the secured locked containers. The placement of the secured locked containers will be jointly developed between departmental management, [mailto:rboldt@unmc.edu Recycling Coordinator] and Environmental Services.
##Departmental management and Environmental Services should jointly develop a plan for the security, transport and storage of confidential materials from customer departments to the secured locked containers. The placement of the secured locked containers will be jointly developed between departmental management, [mailto:rhboldt@unmc.edu Recycling Coordinator] and Environmental Services.
##Locked containers should not be tampered with by unauthorized UNMC/Nebraska Medicine employees.
##Locked containers should not be tampered with by unauthorized UNMC/Nebraska Medicine employees.
##Environmental Services will be responsible for issuing and logging the keys for unlocking these containers.
##Environmental Services will be responsible for issuing and logging the keys for unlocking these containers.
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==Definitions==
==Definitions==
===Affiliated Covered Entity (ACE)===
===Affiliated Covered Entity (ACE)===
Legally separate covered entities that designate themselves as a single covered entity for the purpose of HIPAA Compliance. Current ACE members are: The Nebraska Medical Center, UNMC Physicians, UNMC, University Dental Associates, Bellevue Medical Center and Nebraska Pediatric Practice, Inc. ACE membership may change from time to time. The Notice of Privacy Practices lists current ACE members. Access and amendment rights apply to designated record sets throughout the ACE.
Legally separate covered entities that are affiliated and designate themselves as a single covered entity for the purpose of HIPAA Compliance. Current ACE members are: The Nebraska Medical Center, UNMC Physicians, UNMC, University Dental Associates, Bellevue Medical Center and Nebraska Pediatric Practice, Inc. d/b/a Children’s Specialty Physicians. ACE membership may change from time to time. The Notice of Privacy Practices lists current ACE members. Access and amendment rights apply to designated record sets throughout the ACE.  
===Business Associate===
===Business Associate===
A third party that performs services on behalf of Nebraska Medicine/UNMC (that involve the creation, receipt, maintenance or transmission of protected health information). Some examples of such services include claims processing, data analysis, data processing, practice management, utilization review, quality assurance, patient safety activities, billing, benefit management and repricing.  
A third party who performs services on behalf of Nebraska Medicine/UNMC that involve the creation, receipt, maintenance or transmission of PHI. Some examples of such services include claims processing, data analysis, data processing, practice management, utilization review, quality assurance, patient safety activities, billing, benefit management and repricing.
===Confidential Information===
===Confidential Information===
Individually-identifiable health information (protected health information) and proprietary information, including contracts, business plans and practices, financial information, employee records and meeting minutes.
Protected Health Information and proprietary information, including contracts, business plans and practices, financial information, employee records and meeting minutes.
===Protected Health Information (PHI)===
Individually identifiable health information including demographic information, collected from an Individual, whether oral or recorded in any medium, that:
*is created or received by UNMC/ACE; 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 and identifies the Individual or with respect to which there is a reasonable basis to believe the information can be used to identify the Individual. 
PHI includes genetic information, which includes information about the following items (and excludes information about an Individual’s sex or age):
*an Individual’s genetic tests; 
*the genetic tests of an Individual’s family members; or
*the manifestation of a disease or disorder in such Individual’s family members (i.e., family medical history); or
*any request for, or receipt of, genetic services (e.g., genetic test, genetic counseling, genetic education), or participation in clinical research which includes genetic services by the Individual or any family member of the Individual.
PHI excludes:
*individually identifiable health information of a person who has been deceased for more than fifty (50) years.
*education records covered by the Family Educational Rights and Privacy Act (FERPA); and
*employment records held by UNMC in its role as employer.
==Additional Information==
==Additional Information==
*Contact the [mailto:infosecurity@unmc.edu Information Security Office]
*Contact the [mailto:infosecurity@unmc.edu Information Security Office]
*Contact Director, Environmental Services, at 402-559-6118, '''(do you have a better number for them?)'''  
*Contact Director, Environmental Services, at 402-559-6118, '''(do you have a better number for them?)'''  
*Contact Human Resources – Records at 402-559-8962 or Human Resources - Employee Relations  
*Contact Human Resources – Records at 402-559-8962 or Human Resources - Employee Relations  
*Contact [mailto:rboldt@unmc.edu Recycling Coordinator]
*Contact [mailto:rhboldt@unmc.edu Recycling Coordinator]
*Contact [mailto:debrbishop@nebraskamed.com Privacy Officer]  
*Contact [mailto:debrbishop@nebraskamed.com Privacy Officer]  
*Contact PC Support Dispatch at 402-552-7777 ('''is there an email address for this dept?''')
*Contact PC Support Dispatch at 402-552-7777 ('''is there an email address for this dept?''')

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