EWCDHH Policy
Confidentiality~ of Protected Information Policy
Purpose: To insure that information about client, member, board, staff and volunteer matters is protected from disclosure otherwise than allowed by law.
Effective Date: Upon signature
Attachments:   A. Release of Information Revision Date (s):
                       B. Statement of Confidentiality
POLICY
The purpose of this policy is to protect the confidentiality of certain EWCDHH information. This policy will identify and explain the circumstances and mechanisms by which information obtained by EWCDHH may be disclosed both within EWCDHH and to third parties, as well as penalties for unauthorized disclosure. EWCDHH has a legal and ethical responsibility to
preserve the privacy and confidentiality of protected information. All EWCDHH staff (including
interns), board members, volunteers, and contractors will follow this policy - that informed
consent is required before EWCDHH shall release protected information except where a specific law or administrative need allows or requires EWCDHH disclosure without consent.
This policy shall be seen as consistent with any statutes governing protected information
obtained by EWCDHH, including activities of sign language interpreters. To the extent that this policy is inconsistent with any law, the law shall control activity regarding the disclosure of EWCDHH information. EWCDHH is not a health care provider, health care clearinghouse or health plan for purposes of the Health Insurance Portability and Accountability Act of 1996
(HIP AA).
DEFINITIONS
1) Protected Information: All financial, health or other identifying information which shall include any health information obtained by EWCDHH regarding a past, current or future client, member, staff, board or volunteer of EWCDHH. Any other information determined by EWCDHH or by law to be protected information.
PROCEDURES
 1) External Release: Protected information held by EWCDHH regarding past, current, or future clients is confidential and can only be released:
            - for treatment, payment and health care operations where there is a relationship among the requesting entity, EWCDHH and the person about whom information is requested
            - as the result of informed consent obtained in accordance with a signed release from the client or substitute decision maker ( by completing Attachment A).
            - in the event EWCDHH determines there is an emergency, or if the client may harm themselves or someone else
            - as required by reporting statutes governing abuse and neglect
            - in response to a warrant or court order

2) Internal Release: EWCDHH shall limit access to protected information to those staff or others with a need to know the information in order to deliver services, audit services or process payment information.
3) Requests for Information: Any request for protected information held by EWCDHH from third-party sources must be in writing and be specific as to the identity of the requester and the person whose information is being requested, purpose of the request, and the scope of information requested. Questions regarding requests for information will be directed to the Quality Assurance staff person for resolution. Disclosures will be limited to the minimum information necessary. EWCDHH may charge a reasonable fee for copying which shall be disclosed to the requester prior to processing the request for information. All information disclosed will be assessed for prohibitions on redisclosure, which shall be communicated, when necessary, to the requester.
4) Quality Management: EWCDHH shall account for any release of protected information, including denials, on an ongoing basis. Requests for Information shall be retained by EWCDHH for any period required by law or EWCDHH policy.
5) Training: EWCDHH shall make a good faith effort to ensure that all clients are notified of EWCDHH privacy practices concerning protected information. EWCDHH shall ensure members, staff (to include interns), volunteers, board members and contractors are aware of their obligations related to this confidentiality policy.
6) Enforcement: All supervisors are responsible for enforcing this policy. Human Resources staff shall ensure that a Statement of Confidentiality (Attachment B) shall be obtained from all staff, contractors, interns, volunteers and Board Members. Employees who violate this policy will be subject to discipline up to and including termination from employment. All violators including staff, volunteers, members, Board of Directors and contractors may be subject to criminal and civil penalties, as well as denial of future access to EWCDHH.
 

EWCDHH Policy

Confidentiality of Protected Information                    Policy ___________

Purpose:  To insure that information about client, member, board, staff and volunteer matters is protected from disclosure otherwise than allowed by law.

Effective Date:  Upon signature
Attachments:  A. Release of Information Revision Date(s):
B. Statement of Confidentiality

POLICY

The purpose of this policy is to protect the confidentiality of certain EWCDHH information. This policy will identify and explain the circumstances and mechanisms by which information obtained by EWCDHH may be disclosed both within EWCDHH and to third parties, as well as penalties for unauthorized disclosure. EWCDHH has a legal and ethical responsibility to preserve the privacy and confidentiality of protected information. All EWCDHH staff (including interns), board members, volunteers, and contractors will follow this policy – that informed consent is required before EWCDHH shall release protected information except where a specific law or administrative need allows or requires EWCDHH disclosure without consent.

This policy shall be seen as consistent with any statutes governing protected information obtained by EWCDHH, including activities of sign language interpreters. To the extent that this policy is inconsistent with any law, the law shall control activity regarding the disclosure of EWCDHH information. EWCDHH is not a health care provider, health care clearinghouse or health plan for purposes of the Health Insurance Portability and Accountability Act of 1996 (HIPAA).
 
DEFINITIONS

1)  Protected Information: All financial, health or other identifying information which shall include any health information obtained by EWCDHH regarding a past, current or future client, member, staff, board or volunteer of EWCDHH. Any other information determined by EWCDHH or by law to be protected information.

PROCEDURES

1. External Release: Protected information held by EWCDHH regarding past, current, or future clients is confidential and can only be released: