Social Networking. Management Guide. Compliance and Legal Services
|
|
- Barry Chandler
- 6 years ago
- Views:
Transcription
1 Social Networking Management Guide Compliance and Legal Services
2 Table of Contents IU Health Policies... 3 ADM 1.13 Standards of Conduct for Business Practices ADM 1.98 Information Security Incident Response & Security Breach Notification ADM 2.05 Internet Social Networking ADM 2.07 Photography and Recordings HIPAA 2.01 Reasonable Safeguards for Privacy and Confidentiality of Protected Health Information HR 105 Corrective Action Consistently Manage Social Network Violations... 4 Initiate Documentation Template Obtain Screenshots Notification Interview Social Network Participants Consult Subject Matter Experts at IU Health Social Networking Investigation Documentation Tool... 6 Employee Education / Training... 8 New Employee Orientation Annual Mandatory HIPAA Privacy and Security Awareness Web Based Training In services Resources 9 Frequently Asked Questions 10 Contacts at IU Health. 13 2
3 IU Health Policies IU Health recognizes Internet social networking is a common way for people to interact socially and professionally. Participation on social networking sites carries the potential for breach of information. Workforce members have an ongoing obligation to protect the privacy and confidentiality of IU Health families and patients even when not at work. IU Health Policies and Procedures provide guidance and expectations for appropriate use of Internet social networking sites. The following policies are available to guide IU Health workforce members to appropriately engage in Internet social networking: ADM 1.13 Standards of Conduct for Business Practices.pdf ADM 1.98 Information Security Incident Response & Security Breach Notification.pdf ADM 2.05 Internet Social Networking.pdf ADM 2.07 Photography and Recordings.pdf HIPAA 2.01 Reasonable Safeguards for Privacy and Confidentiality of Protected Health Information.pdf HR 105 Corrective Action.pdf 3
4 Consistently Manage Social Network Violations IU Health maintains open communication to encourage personnel and others to report and/or seek guidance regarding potential or actual misconduct related to social networking. Department Management, Legal Services, Compliance Services, Information Services and Employee Relations will investigate each report of possible information breach using social networking sites. Tools and resources are available to consistently capture and document information. Corrective action will be consistently and fairly applied when applicable. Personnel may contact any member of the Management team, Compliance Services, Legal Services, Information Services, Safety and Security, etc. to report a possible social networking violation. The Management team of the involved personnel, with support of Compliance Services, Legal Services and Employee Relations, is responsible to: Initiate the Social Networking Investigation Documentation tool Obtain screenshots of the users profile from the social network site, the initial post in question and any subsequent comments o Information Services may be able to assist in the recovery of these documents depending on the user s security settings Immediately contact the Department Director, Employee Relations, Compliance Services and/or Legal Services o Management and/or Employee Relations may recommend suspension during investigation o Compliance Services and/or Legal Services will determine whether there is a potential breach and whether the incident is reportable to a government agency and/or law enforcement Interview each workforce member who participated in the posts o Personnel should be interviewed individually and systematically as soon as possible after the concern is identified Initiate the interview with an attempt to understand what the employee knows about the policies surrounding social networking and HIPAA 4
5 Determine whether the employee completed the annual mandatory HIPAA Privacy and Security Awareness training through elms o Request personnel remove the posts from their social networking sites Following personnel interviews, consult with Employee Relations to ensure the proper level of discipline for each person is given o Discipline may not be the same for all involved depending on the complexity of their involvement Determine the need for focused training in the department 5
6 Social Networking Investigation Documentation Tool Reported by: Contact #: Responsible Management: Contact #: Circumstances of the Social Networking concern: Type and Scope of Confidential Information on the Social Networking site: DATE DONE TASK RESPONSIBLE PARTY / CONTACT # Screenshots obtained of: the users profile from the social network site, Initial post in question Subsequent comments Department Director notified Employee Relations notified Compliance Services and/or Legal Services notified Others notified / reason: Notes 6
7 DATE DONE TASK RESPONSIBLE PARTY / CONTACT # Workforce members identified Workforce members removed posts from their social network site Workforce members interviewed Investigation notes reviewed by Management, Employee Relations, Compliance Services and/or Legal Services Corrective action types per employee established (list corrective action type(s)) Education needs established Training completed; if applicable Personnel records updated per HR policies Notes Note: Compliance Services and/or Legal Services will ensure government and law enforcement agencies are notified, when required, under Attorney Client Privilege. 7
8 Employee Education / Training IU Health workforce members receive HIPAA Privacy and Security training upon initial employment, volunteer work, student orientation, or third party contract; and annually thereafter or upon material changes to any corporate or department policies and procedures that regard the privacy, security, and confidentiality of individual health information. Specialized training / in service(s) to address specific concerns is available by request made to the Compliance Services Department. Documentation regarding training for the entity s workforce shall be retained for a period of at least six years from the date of its creation or the date when it was last in effect, whichever is later. The documentation shall be retained by Department Management. Documentation related to online training courses and the databases of employees completing the online courses shall be maintained by the Learning Solutions Department. 8
9 Resources IU Health maintains a comprehensive, formal program of general compliance and HIPAA training to ensure that IU Health personnel are aware of their legal, moral and ethical responsibilities. Personnel have access to IU Health policies located on PULSE, the intranet site for IU Health. It is expected that IU Health personnel will abide by the ethical standards of the professions to which they belong. Additional resources: Social Networking: Frequently Asked Questions (attached) Contacts at IU Health (attached) Annual mandatory web based training through elms In services upon request 9
10 Social Networking Frequently Asked Questions Question: Is it okay to say where I work on my Facebook status? Answer: Once you post your place of employment and your role, it can be construed by some that you are always on duty. This opens the door for unsolicited requests for healthcare guidance. Posting your place of employment also allows viewers to identify persons or circumstances associated with your posts through association. If you post your place of employment on your profile, it is important to maintain constant awareness of your personal and professional boundaries. Posts that may be associated with your work should include a disclaimer that the post is your personal opinion and does not represent the opinion of IU Health. Question: Families sometimes ask me to be their friends on Facebook. I know we are strongly urged not to. How do I answer them without sounding rude? Answer: Let the requestor know you are honored that you were asked to befriend them, however professionally and ethically you may not accept their request. Question: My neighbor was my friend long before being a patient at IU Health. Is it okay to remain friends online? Answer: Yes. It is important to always remain conscious of your professional and ethical duty to maintain patient confidentiality regardless of personal relationships. It would be appropriate to advise friends that you will not comment on health related matters through a public site. Social networks are all public sites regardless of their privacy settings. Also be mindful of photos or recordings that associate a nurse/patient relationship. 10
11 Question: How do I know what kind of information is okay to post and not to post? Answer: It is never permissible to post any photographs, recordings or other information about a patient on a personal social networking site. Information posted for educational purposes on sites such as those created by IU Health or YouTube are done after a detailed consent is signed by the patient and permission granted from IU Health Corporate Communications. Use good judgment; if you are not certain about the appropriateness of posting, then do not post. See below for guidance related to professional networking sites. Question: Is it permissible to post a picture taken at a picnic where both employees and patients were present? My colleagues and I are the only people who know who the patients are in the photos. Answer: No, it is generally not appropriate to use photographs taken during IU Health related functions without obtaining the written permission of those in the photograph. You can never be certain that you and your colleagues are the only people who know the connection of those in the photographs. Question: My security settings are set so that only my family and friends can see what I post. How would my information be released to the general public? Answer: Even disclosures to friends and family are considered public. You are not allowed to share confidential patient information with friends and families, whether at home or through Internet postings. Also, remember that a family or friend can copy the content of your Internet site to share through their sites with people that you do not know. It is possible to see postings through friends of friends who are not as careful as you when setting security parameters and posting comments on a public forum. Question: What if someone tags me in a picture and it shows up on my personal network site? Answer: If it is a photograph that you believe to be inappropriate, ask the person who tagged you to remove you from the tag and remove the picture from 11
12 your site (and the other individual s site as well, if you believe it to be an inappropriate posting, such as a breach of privacy). Question: Is it okay to put a link to IU Health sites, such as for fundraising, on my personal network site? Answer: Yes, if the purpose is to guide individuals to a trusted site for information. Question: What about CaringBridge and similar sites? Answer: Pages on CaringBridge and other similar sites are typically set up by patients, guardians or significant others who share confidential information about themselves or their loved ones. Although healthcare personnel did not disclose confidential information, the healthcare personnel must continue to maintain their professional and ethical duties not to participate in healthcare related discussions on sites like CaringBridge. For example, it would be appropriate to post a caring note for the family or patient, but it would not be appropriate to post clinical information about the patient or that you know the patient because you are caring for the patient. Question: As a professional, is it ever appropriate to participate in social networking? Answer: Yes. Social networking sites and blogs are an excellent resource to learn about different treatment modalities, connect with other professionals and follow healthcare trends. Refer to IU Health ADM Policy 2.05, Appendix B: Internet Social Networking Guidelines for guidance. Also see IU Health ADM Policy 1.13 Standards of Conduct for Business Practices. 12
13 Contacts at IU Health for Privacy and Security Matters Name Department Phone Number Valita Fredland Privacy Officer / Legal Services Rasma Kancs Director Compliance Services / HIPAA Roxanne Binford Program Manager / HIPAA Brian Quick Security Officer / Information Services
St Philip Neri RC Primary School. Employee Social Media Policy
St Philip Neri RC Primary School Employee Social Media Policy Index The Policy Introduction Aim Definition Scope Responsibilities Personal use of social media at work Employee responsibilities when using
More informationInformation for registrants. Guidance on social media
Information for registrants Guidance on social media Contents Introduction 3 About this document 3 About us 4 Section 1: Top tips 5 Section 2: Using social media 6 Benefits of social media 6 Communicate
More informationPolicy for Use of Social Media
Policy for Use of Social Media Ref. TP080 Policy for Use of Social Media Page 1 of 13 1 DOCUMENT PROFILE and CONTROL. Purpose of the document:. To help staff understand their responsibilities when using
More informationHIPAA PRIVACY RULE IMPLEMENTATION WHAT S UP AFTER 4/14/03?
HIPAA PRIVACY RULE IMPLEMENTATION WHAT S UP AFTER 4/14/03? 8 th National HIPAA Summit Baltimore, MD March 8, 2004 Lynda A. Russell, EdD, JD, RHIA Privacy Manager Cedars-Sinai Medical Center Los Angeles,
More informationNational Volunteer Workforce Solutions Social Media Handbook Part 1: Introduction and Social Media Policies
National Volunteer Workforce Solutions Social Media Handbook Part 1: Introduction and Social Media Policies 2 Disclaimer The information contained in this handbook is for general guidance only on matters
More informationSocial Media Guidelines
March 2013 Social Media Guidelines The following provides employees with an understanding of FedEx guidelines about individual participation and personal comments in external internet social media sites
More informationWelcome to Northside Hospital s Annual / New Hire Compliance Training. 1 of 35
2015-2016 Corporate Compliance Training Welcome to Northside Hospital s Annual / New Hire Compliance Training 1 of 35 Goals of Session 1. Review Northside s Compliance Program and Code of Conduct 2. Emphasize
More informationSocial Media Policy. To provide guidance for staff, volunteers and contractors on the appropriate use of social media. Purpose.
Social Media Policy Solent NHS Trust policies can only be considered to be valid and up-to-date if viewed on the intranet. Please visit the intranet for the latest version. Purpose Document Type Reference
More informationJust cause terminations cannot be actioned unless due process is confirmed by the Deputy Minister, BC Public Service Agency.
Policy The objective of this administrative policy is to clarify the employer s roles, responsibilities and procedures with respect to just cause employment termination decisions under section 22(2) of
More informationSocial Networking Policy
Social Networking Policy Policy Number Target Audience Approving Committee SOCIAL001 CCG staff CCG Chief Officer Date Approved December 2015 Last Review Date July 2015 Next Review Date July 2017 Policy
More informationSocial Media Policy POLICY TITLE: UPDATED ON: 1 st July 2015 APPROVED BY BOARD ON:
POLICY TITLE: Social Media Policy UPDATED ON: 1 st July 2015 APPROVED BY BOARD ON: Purpose Social media offers the opportunity for people to gather in online communities of shared interest and create,
More informationGlobal Privacy Policy
Global Privacy Policy Table of Contents Introduction... 2 Policy Overview Scope Application of Local Laws Definitions.... 3 Data Protection Principles... 4 Security and Access... 5 Special Circumstances....
More informationSocial Media. Guide for employees
Social Media Guide for employees This guide outlines the standards of behaviour expected from all employees when using social media as part of their job for Royal Mail and also for personal use where it
More informationICHWC Code of Ethics (Updated February 1, 2017)
ICHWC Code of Ethics (Updated February 1, 2017) ICHWC is committed to maintaining and promoting excellence in coaching. Therefore, ICHWC expects all credentialed health and wellness coaches (coaches, coach
More informationPolicy 2 Workforce Security Policy and Procedure
Policy 2 Workforce Security Policy and Procedure Policy: 1. Authorization and/or Supervision The practice s Security Officer will determine which individuals are authorized to access electronic protected
More informationTop Social Media Policy Tips
Top Social Media Policy Tips 1. Have a strategy before you have a policy. 2. Good policies are built around trust, safety, and security. Use your social media policy to make those in your organization
More informationSocial Media Policy. Reference: HR th December Induction CD/ Sharepoint/ EDRMS HR Site/ Website
Social Media Policy Reference: Document Type: Status of Document: Policy Final Version: 1.2 Date Approved: 16 th December 2014 Approved By: Publication Date: Review Date Policy Owner Applies to: Document
More informationguide to using social media for NHS Staff in Blackburn with Darwen
guide to using social media for NHS Staff in Blackburn with Darwen Why should you read it? Why use social media? The guidelines are designed to help you get the best out of the social media tools available
More informationGUIDELINES FOR IMPLEMENTING A PRIVACY MANAGEMENT PROGRAM For Privacy Accountability in Manitoba s Public Sector
GUIDELINES FOR IMPLEMENTING A PRIVACY MANAGEMENT PROGRAM For Privacy Accountability in Manitoba s Public Sector TABLE OF CONTENTS INTRODUCTION... 2 Accountable privacy management 2 Getting started 3 A.
More informationSocial Media Guidelines
Social Media Guidelines Protect proprietary business information Be thoughtful about helping our customers Remember, you are always visible on Social Media Acknowledge you are a Progressive employee Be
More information3.1. Breach Use of social media which contravenes Ermha s Social Media Policy, any other Ermha Policy, or the law.
PURPOSE Social media is a highly accessible and scalable publishing tool that brings many benefits as well as some risks. Social media is variously defined as a professional, public and private space,
More informationCHILD AND YOUTH RISK MANAGEMENT STRATEGY
CHILD AND YOUTH RISK MANAGEMENT STRATEGY CONTENTS 1. Statement of Commitment... 4 2. Code of Conduct... 5 3. Recruitment, selection, training and management... 6 4. Policies and procedures for handling
More informationInformation Governance Clauses Clinical and Non Clinical Contracts
Information Governance Clauses Clinical and Non Clinical Contracts Policy Number Target Audience Approving Committee Date Approved Last Review Date Next Review Date Policy Author Version Number IG014 All
More informationYour Guide to the Compliance Process
Your Guide to the Compliance Process Our Commitment and Your Responsibilities Disciplinary Action Guidelines Guidance for Managers Investigations Process Overview US Reporting Process Overview Corporate
More informationLawnswood Campus. Social Media Policy
Lawnswood Campus Social Media Policy Review Date: Local Agreement guidance followed for updates Please read Governors as Management Board Schools as PRUs Signed by the Chair of the Management Board:. Date:
More informationTerms of Engagement SW London Collaborative Staff Bank
Terms of Engagement SW London Collaborative Staff Bank In joining the South West London Collaborative Staff Bank, you agree to the following terms which govern the arrangements under which you may be offered
More informationGuidelines and Best Practices for Managing Social Media Tools, Both Personal and on Behalf of Barrier Islands Free Medical Clinic
Guidelines and Best Practices for Managing Social Media Tools, Both Personal and on Behalf of Barrier Islands Free Medical Clinic The following guidelines lay out general boundaries and best practices
More informationConflict of Interest. Purpose. Policy Statement. Applicability. Responsibility. Principles
Approved by: Conflict of Interest President and Chief Executive Officer Corporate Policy & Procedures Manual III-15 Date Approved April 13, 2016 Next Review (3 years from Effective Date) May 2019 Purpose
More informationLiving Our Purpose and Core Values CODE. Code of Business Ethics and Conduct for Vendors
Living Our Purpose and Core Values CODE Code of Business Ethics and Conduct for Vendors December 2016 HCSC Vendor Code of Business Ethics and Conduct Since 1936, Health Care Service Corporation, a Mutual
More informationHennepin County Sheriff s Office Policy Manual
Document Number: 1058 Document Name: Employee Speech, Expression and Social Networking Effective Date: February 9, 2016 Document Status: Approved 1058.1 PURPOSE AND SCOPE This policy is intended to address
More informationCelgene General Privacy Policy
Celgene General Privacy Policy 1. INTRODUCTION AND SUMMARY Our Privacy Commitment At Celgene we recognize the importance of, and are fully committed to protecting the privacy of, information related to
More informationSHRINERS HOSPITALS FOR CHILDREN CORPORATE COMPLIANCE PLAN
SHRINERS HOSPITALS FOR CHILDREN CORPORATE COMPLIANCE PLAN 1.0 INTRODUCTION Shriners Hospitals for Children ( SHC ) is committed to conducting itself according to applicable business ethical standards and
More informationCode of Conduct Policy
t Code of Conduct Policy [Type here] Approved 1 December 2015 INTRODUCTION... 3 BREACHES OF THIS CODE OF CONDUCT... 3 STATEMENT OF VALUES... 4 PERSONAL AND PROFESSIONAL BEHAVIOUR... 4 ATTENDANCE AND PUNCTUALITY...
More informationData Protection Policy
Data Protection Policy StCH Data Protection Policy - POL 53 vs1 - July 2016 1 Document Control Table Document Title: Data Protection Policy Document Ref: POL 53 Author (name and job title): Karen Anderson,
More informationSSAB s Recruitment privacy statement
Recruitment Privacy NA Information 2018-05-22 1(5) SSAB s Recruitment privacy statement This Privacy informs why and how SSAB AB including its affiliates, and partners ("SSAB") collects, uses or shares
More informationGUIDELINES. Corporate Compliance. Kenneth D. Gibbs President & Chief Executive. Martin A. Cammer Senior Vice President & Corporate Compliance Officer
GUIDELINES Corporate Compliance Kenneth D. Gibbs President & Chief Executive Martin A. Cammer Senior Vice President & Corporate Compliance Officer Joyce Leahy Executive Vice President for Legal Affairs
More informationSocial Media Policy. Planning for Success
Social Media Policy Planning for Success Panelists Julia Montgomery, Technology Projects Manager, Arent Fox LLP Karen M. Sheehan, Head of PLC Law Department at Practical Law Company, Inc. V. Mary Abraham,
More informationInformation Sharing Policy
Information Sharing Policy DOCUMENT CONTROL: Version: 1 Ratified by: Risk Management Sub Group Date ratified: 19 December 2012 Name of originator/author: Information Governance Manager Name of responsible
More informationDevelopmental Delay Rehabilitation Services Inc.
Developmental Delay Rehabilitation Services Inc. Corporate Compliance Plan Terence Blackwell, CEO Nathan Cohen, CCC/SLP, President Corporate Compliance Officer Table of Contents Section Name I. Corporate
More informationCode of Conduct. V November 2017
Code of Conduct V. 2.0 - November 2017 A word from our CEO Marcos França CEO Lhoist Group Dear all, For more than 125 years, our family-owned business in lime, dolime and mineral products has been combining
More informationDATA PROTECTION POLICY
1. Introduction This policy is intended to provide information about how the School will use (or process ) personal data about individuals including: Current, past and prospective pupils; Parents, carers
More informationAuckland Council Social Media Policy. Part two: policy for using social media
Auckland Council Social Media Policy Part two: policy for using social media Disclaimer: The Social Media Policy should be read in conjunction with the Social Media Guidelines Contents Media Policy and
More informationGIRL GUIDES AUSTRALIA (GGA) SOCIAL MEDIA POLICY
ACN 070 581 770 GIRL GUIDES AUSTRALIA (GGA) SOCIAL MEDIA POLICY This policy is to be provided to all employees, adult and youth members, and volunteers of GGA, its member State Girl Guide Organisations
More informationQuick reference guide to problem solving at work discipline, grievance and appeals
Quick reference guide to problem solving at work discipline, grievance and appeals If you ve been invited to a disciplinary hearing or have a problem at work then read on this leaflet is designed to give
More informationPart of the Workplace Violence Prevention Program. Promoting an Atmosphere of Respect, Cooperation and Professionalism
Part of the Workplace Violence Prevention Program Promoting an Atmosphere of Respect, Cooperation and Professionalism Code of Conduct Part of the Workplace Violence Prevention Program Table of Contents
More informationCoca-Cola Amatil SOCIAL MEDIA POLICY
Coca-Cola Amatil SOCIAL MEDIA POLICY September 2012 Policy: Social Media Policy Approval Date: 17th September 2012 Approved By: Sally Loane Version: 1.2 Amendments: Minor change Previous Version: 1.1 Previous
More informationTriple C Housing, Inc. Compliance Plan
Triple C Housing, Inc. Compliance Plan Adopted by Board of Directors on draft November 13, 2014 Overview Triple C Housing, Inc. is committed to its consumers, employees, contractual providers, vendors,
More informationCODE OF ETHICS AND CONDUCT
CODE OF ETHICS AND CONDUCT PREFACE Green Mountain Power s Code of Ethics and Conduct is about doing the right thing acting honorably, treating each other with respect, and following the law. It s built
More informationCompliance Code Conduct
Compliance Code Conduct O F COMPLIANCE CODE OF CONDUCT Table of Contents A Message from our CEO...1 Foreword................................................................................2 Our Mission...
More informationHuman Resources Policy No. HR65
Human Resources Policy No. HR65 Occupational Health Service Additionally refer to: HS01 Health & Safety Policy HR06 Maintaining High Standards of Performance HR07 Disciplinary Policy for Doctors and Dentists
More informationCorporate Code of Business Conduct and Ethics
Corporate Code of Business Conduct and Ethics A MESSAGE FROM OUR CHAIRMAN, PRESIDENT AND CHIEF EXECUTIVE Honesty and integrity are paramount values at TRC. Our commitment to strict ethical standards has
More informationSample Cell Phone/Social Media Policy
Sample Cell Phone/Social Media Policy Use of PERSONAL CELLULAR PHONES/ SMART PHONES While at work employees are expected to exercise the same discretion in using personal cellular phones/smart phones as
More informationDATA PROTECTION POLICY 2016
DATA PROTECTION POLICY 2016 ADOPTED FROM BRADFORD METROPOLITAIN COUNCIL MODEL POLICY AUTUMN 2016 To be agreed by Governors on; 17/10/16 Signed by Chair of Governors: Statutory policy: Yes Frequency of
More informationThe Art of Positive Termination
The Art of Positive Termination Being Proactive During a Reactive Situation A part of the Education at Work Professional Development Series Agenda! Key Words & Phrases Termination To Do List for Employers
More informationSpeak Up & Reporting Policy of AMG ADVANCED METALLURGICAL GROUP N.V. Strawinskylaan XX Amsterdam The Netherlands
Speak Up & Reporting Policy of AMG ADVANCED METALLURGICAL GROUP N.V. Strawinskylaan 1343 1077 XX Amsterdam The Netherlands Speak Up & Reporting Policy At AMG Advanced Metallurgical Group ( AMG ) we all
More informationDirector s Draft Report
Office of Audit and Evaluation March 2, 2017 Director s Draft Report Protected B Table of contents Executive summary... i Introduction... 1 Focus of the audit... 2 Statement of conformance... 2 Observations...
More informationGovernment Auditing Standards
United States Government Accountability Office GAO By the Comptroller General of the United States August 2011 Government Auditing Standards 2011 Internet Version CONTENTS CHAPTER 1... 1 GOVERNMENT AUDITING:
More informationPROFESSIONAL BOUNDARIES POLICY AND GOOD PRACTICE GUIDELINES
DD# PROFESSIONAL BOUNDARIES POLICY AND GOOD PRACTICE GUIDELINES SCOPE This document sets out Premier Care (Plymouth) Limited s policy principles and good practice guidelines on professional boundaries
More informationHollyfield Primary School Social Media Policy
Hollyfield Primary School Social Media Policy Learning Trust for Excellence Contact Person: Committee: Head Teacher Full Governing Body Date of Approval: 13.5.15 Date Last Amended: 13.5.15 Review Date:
More informationData protection (GDPR) policy
Data protection (GDPR) policy January 2018 Version: 1.0 NHS fraud. Spot it. Report it. Together we stop it. Version control Version Name Date Comment 1.0 Trevor Duplessis 22/01/18 Review due Dec 2018 OFFICIAL
More informationIntroduction DO NOT E-SAFETY
E-SAFETY Introduction Digital technology has become an important part of everyday life and offers exciting opportunities. However the increasing number of cases where workplace practice has highlighted
More informationC. MCCMH Hardware and Systems: MCCMH owned or leased equipment, facilities, internet addresses or domain names registered to MCCMH.
protect MCCMH Staff s First Amendment rights to Freedom of Speech, Michigan s Internet Privacy Protection Act (IPPA), and the Michigan Public Employment Relations Act (PERA). B. Confidential Information:
More informationINFORMATION GOVERNANCE STRATEGY IMPLEMENTATION PLAN
INFORMATION GOVERNANCE STRATEGY & IMPLEMENTATION PLAN 2015-2018 Disclaimer The latest version of this document is located on PTHB intranet. Please check the review date and if there are any doubts contact
More informationAMA SKILLS TRAINING. PRIVACY Policy & Procedure
AMA SKILLS TRAINING PRIVACY Policy & Procedure Objective This policy describes the practices and procedures by which AMA Skills Training will ensure the compliance with the relevant privacy legislation
More informationDATA PROTECTION POLICY
DATA PROTECTION POLICY Document Control History Title Data Protection Policy Version no. 1.0 Date of publication May 2018 Author(s) Amanda Cramb, HR Manager Next review date May 2021 Page 1 Introduction
More informationThe Role of HIPAA in Your Social Media Guidelines
The Role of HIPAA in Your Social Media Guidelines Jennifer Maggiore ceo, red balloon inc I m not an attorney All data and information provided in this document is for informational purposes only. and Jennifer
More informationACCOUNTABILITY FRAMEWORK FOR HUMAN RESOURCE MANAGEMENT
ACCOUNTABILITY FRAMEWORK FOR HUMAN RESOURCE MANAGEMENT All Deputy Ministers, Associate Deputy Ministers, Executives, Senior Officials, supervisors, and human resource professionals in the BC Public Service
More informationSERBA DINAMIK GROUP BERHAD INTERNAL AUDIT CHARTER
SERBA DINAMIK GROUP BERHAD INTERNAL AUDIT CHARTER 1) 2) 3) 4) 5) 6) 7) 8) 9) 10) 11) 12) 13) CONTENT ILLUSTRATION INTRODUCTION & PURPOSE OF THE INTERNAL AUDIT CHARTER INTERPRETATION OBJECTIVES MISSION
More informationKentucky State University Office of Internal Audit
Draft for Discussion Only P&P Manual Section - Policy# I. Function and Responsibilities MISSION Mission Statement Definition of Internal Auditing PURPOSE, AUTHORITY, RESPONSIBILITY Audit Charter STANDARDS
More informationCORPORATE COMPLIANCE PROGRAM CODE OF CONDUCT PLEDGE OF PRINCIPLES
CORPORATE COMPLIANCE PROGRAM CODE OF CONDUCT PLEDGE OF PRINCIPLES 2015 1 THE CODE OF CONDUCT Our code of conduct, the Pledge of Principles, was developed to help guide the behavior and performance of employees
More informationE. FOCUS: The electronic medical record system and billing platform utilized by MCCMH.
IV. Definitions A. Appropriate Access: Access to read, write, modify, or communicate EPHI via FOCUS, in the amount minimally necessary in light of an individual s role within the organization, and consistent
More informationDeveloping and Managing an Effective Compliance Program
Developing and Managing an Effective Compliance Program Pete Driscoll, Chief Risk and Strategy Officer U.S. Securities and Exchange Commission Office of Compliance Inspections and Examination National
More informationCORPORATE GOVERNANCE POLICY
CORPORATE GOVERNANCE STATEMENT Atlantic is committed to building a diversified portfolio of resources assets that deliver superior returns to shareholders. Atlantic will seek to achieve this through strong
More informationa physicians guide to security risk assessment
PAGE//1 a physicians guide to security risk assessment isalus healthcare isalus healthcare a physicians guide to security risk assessment table of contents INTRO 1 DO I NEED TO OUTSOURCE MY SECURITY RISK
More informationLetter From Crown s President
Code of Conduct Letter From Crown s President Crown s reputation for integrity is built not only on the quality of Crown s products and services but also on Crown s employees history of honest, ethical
More information1.4. Ermha adheres to a progressive discipline approach as a means of ensuring a method which is fair and responsive.
PURPOSE 1.1. Ermha is committed to providing a high quality system that supports Ermha s organisational objectives, vision and mission and does so through linking those objectives with staff goals, achievements
More informationContents. NRTT Proprietary and Confidential - Reproduction and distribution without prior consent is prohibited. 2
Privacy Policy Contents INTRODUCTION... 4 PROCESSING PRINCIPALS... 5 FAIRNESS AND LAWFULNESS... 5 RESTRICTION TO A SPECIFIC PURPOSE... 5 DELETION... 5 CONFIDENTIALITY AND DATA SECURITY... 5 RELIABILITY
More informationInternal Audit Policy and Procedures Internal Audit Charter
Mission Statement Internal Audit Policy and Procedures Internal Audit Charter The mission of the Internal Audit Department is to provide independent and objective reviews and assessments of the business
More informationCompliance with Laws, Rules and Regulations
R1 RCM Inc. (hereafter, R1 or the Company ) is committed to the conduct of its business in an ethical, legal, and transparent manner. In turn, the Company expects that all employees, contractors and vendors
More informationPrivacy Incident Response & Reporting: Pre and Post HITECH
Privacy Incident Response & Reporting: Pre and Post HITECH Erika Riethmiller-Bol, Director, Corporate Privacy-Incident Program, Anthem, Inc. HCCA Managed Care Compliance Conference February 16, 2015 Objectives
More informationInstitutional Compliance Awareness. Updated 2/23/18
Institutional Compliance Awareness Updated 2/23/18 Institutional Compliance Plan Approved by the Board of Trustees Outlines key elements of the compliance structure: Risk and Compliance Oversight Council
More informationETHICS: WHERE DOES YOUR RESPONSIBILITY END?
ETHICS: WHERE DOES YOUR RESPONSIBILITY END? Understanding the relationship between professional ethics and legal liability PRESENTED BY: Steven M. Henderson, P.E., Esq. KSPE Annual Convention April, 2011
More informationMODA HEALTH CODE OF CONDUCT
MODA HEALTH CODE OF CONDUCT I. Introduction Moda Health has a longstanding tradition of caring for our members, communities, and employees. We strive to act with absolute integrity in the way we do our
More informationABSENCE MANAGEMENT POLICY
ABSENCE MANAGEMENT POLICY Policy Folder & Policy Number Human Resources Folder 1: Policy No. 1.1 Version: 1 Ratified by: Stoke CCG Governing Body Date ratified: 24 th September 2013 Name of originator/author:
More informationSOCIAL MEDIA AND THE WORKPLACE
SOCIAL MEDIA AND THE WORKPLACE Presented By: Ronni M. Travers, SPHR, President Public Sector HR Consultants LLC Office: (518) 399-4512 Email: rtravers@publicsectorhr.org Quick Survey of Attendees 1. Who
More informationDeath in Service Policy & Procedure
Policy: D10 Death in Service Policy & Procedure Version: D10/01 Ratified by: Trust Management Team Date ratified: 11 th January 2012 Title of originator/author: HR Business Manager Title of responsible
More informationWhat is GDPR and Should You Care?
What is GDPR and Should You Care? Ingram Micro Inc. 1 Overview of Privacy Climate & Concerns 2 2 Today We Live In A World Where Advertisers read key words in your Facebook posts and emails and decide what
More informationSocial Media Policy. Reader Panel (as described within this document) and Document Review Group
Social Media Policy Document Control: Document Author: Helen Cruess Document Owner: Document Review Group Electronic File ame: Social Media Policy dated March 2013 Document Type: Corporate Policy Stakeholder
More informationI. Mission. II. Scope of the Work
CHAPTER: I - ORGANIZATION Page: A.1 MANUAL Appendix A CHARTER FOR THE OFFICE OF THE INSPECTOR GENERAL I. Mission 1. The Office of the Inspector General (OIG) provides oversight of the programmes and operations
More informationSECTION: Human Resources - General. SUBJECT: Respectful Workplace Policy. Issue / Revise Date: Sept. 10, 2007 Effective Date: January 1, 2008
SECTION: Human Resources - General SUBJECT: Respectful Workplace Policy Issue / Revise Date: Sept. 10, 2007 Effective Date: January 1, 2008 POLICY STATEMENT: SaskPower is committed to make every practicable
More informationCode of Ethics for Financial Advisers
Financial Adviser Standards and Ethics Authority Code of Ethics for Financial Advisers Exposure Draft of Proposed Standard CONSULTATION OPEN Exposure Draft issued March 2018 Consultation closes 1 June
More informationDISCLOSING A CONFLICT OF INTEREST. Employee Guideline & Disclosure Form
DISCLOSING A CONFLICT OF INTEREST Employee Guideline & Disclosure Form Introduction and Purpose Employees in the BC Public Service are required under the Public Service Oath Regulation and Standards of
More informationNORTON SHORES POLICE DEPARTMENT Standard Operating Procedure
Subject NORTON SHORES POLICE DEPARTMENT Standard Operating Procedure Number Use of Social Media 81-03 Effective Date Revised Date Cancels October 28, 2010 Issued by Daniel R. Shaw, Chief of Police I. PURPOSE
More informationGDPR DATA PROCESSING NOTICE FOR FS1 RECRUITMENT UK LTD FOR APPLICANTS AND WORKERS
GDPR DATA PROCESSING NOTICE FOR FS1 RECRUITMENT UK LTD FOR APPLICANTS AND WORKERS What is the purpose of this document? FS1 Recruitment UK Ltd is committed to protecting the privacy and security of your
More informationA new era of transparency
TOMORROW S ADVICE PART 1 A new era of transparency 1 In this guide we will: 1. define transparency 2. distinguish between disclosure and true transparency 3. outline why transparency could lead to great
More informationWill Your Company Pass a Privacy Audit?
Will Your Company Pass a Privacy Audit? by Tammi K. Franke The Issue - Companies that collect personal information are under increasing scrutiny by both consumers and governments in the United States and
More informationDate of review: Policy Category:
Title: Disciplinary Policy Date Approved by: Approved: February JSPF 2015 March 2015 OD and Workforce Committee October 2016 JSPF Division/Department: Date of review: November 2018 Policy Category: Policy
More informationBroad Classification:
SOCIAL MEDIA POLICY Introduction: Social Media offers a promising opportunity to engage in sharing views, obtaining feedbacks, engaging in conversations/discussions with customers, suppliers, investors
More informationTHE INDEPENDENT PHARMACIST S GUIDE TO THE ON-SITE AUDIT Amanda C. Fields, General Counsel for American Pharmacies (APRx) American Pharmacies 2011
THE INDEPENDENT PHARMACIST S GUIDE TO THE ON-SITE AUDIT Amanda C. Fields, General Counsel for American Pharmacies (APRx) American Pharmacies 2011 Introduction As the Texas pharmacists know, audits by insurance
More informationAccessibility for Ontarians with Disabilities Act: Multi-Year Accessibility Plan
Accessibility for Ontarians with Disabilities Act: Multi-Year Accessibility Plan Last Revision Date: October 2017 Table of Contents Introduction Section One: Past Achievements to Remove and Prevent Barriers
More information