White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 8: Privacy: Protecting Personal Information
Information in its care in compliance with applicable privacy laws and regulations and Pfizer’s corporate
policies and procedures. Pfizer’s policy is to employ appropriate safeguards to protect all Personal
Information it receives and maintains, regardless of the form, format, location, or use. See Corporate
Policy 404 (Protecting the Privacy of Personal Information)
http://policysource.pfizer.com/Corporate/PDFDocuments/404.PersonalInformation.pdf.
Key Points to Ensure Compliance
Always disclose that you are a Pfizer employee when interacting with patients, such as at a
consumer health fair or during a mentorship by wearing your Pfizer name tag at all times.
Corporate Policy 404, (Protecting the Privacy of Personal Information)
http://policysource.pfizer.com/Corporate/PDFDocuments/404.PersonalInformation.pdf
requires all Pfizer colleagues to employ appropriate safeguards to protect Personal
Information they have access to, including the Personal Information of customers.
Do not request or collect Sensitive Personal Information for any reason unless you have
specific approval to do so.
Avoid situations likely to lead to the inadvertent disclosure of Sensitive Personal Information,
such as private conversations between HCPs and patients.
When setting up a mentorship or preceptorship, Pfizer colleagues must remind physicians
serving as mentors or preceptors that they have a legal obligation to obtain their patients’
written authorization before Pfizer colleagues may be allowed to observe any consultation,
examination, and/or treatment of any patient.
Pfizer usually does not perform work on behalf of an HCP or other “covered entity” under
HIPAA. Therefore, it is not appropriate for any field-based colleague to enter into a Business
Associate Agreement. If you are asked to sign a Business Associate Agreement, you must
consult with Legal.
Do not sign any non-Pfizer Confidentiality Agreement without consulting with with Legal.
Do not discuss with an HCP that you know their prescribing practices based on their prescriber
data.
Do not share an HCP’s prescriber data with anyone outside of Pfizer.
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