Sanctions For Breaches of Security or Confidentiality

Goal - why is this important to us?

To protect the confidentiality and integrity of confidential medical and other sensitive information, establish sanctions for the violation of Dawn Farm policies protecting the confidentiality and integrity of its consumers' personal information, and comply with the Health Insurance Portability and Accountability Act of 1996, 42 CFR Part 2, other relevant laws, codes of professional ethics, and accreditation requirements.

Dawn Farm has adopted policies requiring all staff, contractors, students and volunteers in order to protect the integrity and confidentiality of medical and other sensitive information pertaining to its clients. Dawn Farm will not tolerate violations of those policies, and such violations will constitute grounds for disciplinary action up to and including termination, professional discipline, criminal prosecution, and or civil action to recover any fines or penalties levied against Dawn Farm that result from a failure to comply with those policies.

Ingredients - what do I need to get started?

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Timeframe - about how long will this take?

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Contacts - who do I need to let know?

Any breaches or suspected breaches of confidentiality should be reported to your Program Coordinator.

Steps - what do I do?

1. All Dawn Farm employees, contractors, students, and volunteers shall be apprised of policies and procedures protecting the confidentiality and integrity of its clients' personal treatment information, and other sensitive information and asked to sign a Confidentiality Statement.
2. Any Dawn Farm staff, contractor, student, or volunteer who believes that another staff member, contractor, student, or volunteer has breached the confidentiality or integrity of a client's personal treatment information, or other sensitive information shall immediately report that breach to his or her supervisor or to the Dawn Farm Privacy Officer (Project Manager).
3. The Dawn Farm Privacy Officer shall conduct a thorough and confidential investigation of the allegation and recommend corrective action to the Dawn Farm President.
4. Dawn Farm shall inform the complainant of the results of the investigation and any corrective action taken.
5. Dawn Farm will not retaliate against or permit reprisals against any staff, contractor, student, or volunteer who reports a suspected violation of its policies protecting the confidentiality and integrity of its clients’ personal medical information. Allegations not made in good faith, however, may result in discharge or other discipline.
6. Individuals who violate this policy are subject to discipline up to and including termination from employment, in accordance with the Employee Manual and Dawn Farm policies, professional discipline, or criminal prosecution in accordance with state and federal law. This policy does not mandate the use of progressive discipline or the imposition of lesser sanctions before Dawn Farm terminates an employee, contractor, student, or volunteer for violating its policies protecting the confidentiality and integrity of its clients’ personal treatment information.
7. Substantiated violations of Dawn Farm policies protecting the confidentiality and integrity of its clients' personal treatment information may constitute a criminal offense under the Health Insurance Portability and Accountability Act of 1996, or other federal laws. Any individual or contractor who violates such a criminal law will be reported to appropriate law enforcement personnel and Dawn Farm will cooperate with any law enforcement investigation or prosecution.
8. Further, substantiated breaches of confidentiality and violations of Dawn Farm policies protecting the confidentiality and integrity of its clients’ personal treatment information may constitute violations of professional ethics and be grounds for professional discipline. Any individual subject to professional ethics guidelines and/or professional discipline will be reported to the appropriate licensure/accreditation agencies and the Dawn Farm will cooperate with any professional investigation or disciplinary proceedings.

Follow-up - what loose ends do I need to wrap up?

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