White Guide and Orange Guide Formatting Project - Pfizer
White Guide and Orange Guide Formatting Project - Pfizer
White Guide and Orange Guide Formatting Project - Pfizer
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<strong>Orange</strong> <strong>Guide</strong> – Chapter 8: Privacy: Protecting Personal Information<br />
Key Points to Ensure Compliance<br />
<strong>Pfizer</strong> colleagues should not engage health fair attendees in discussions regarding their<br />
specific health status, symptoms, diagnosis or treatment. These discussions should occur<br />
between the patient <strong>and</strong> appropriate HCP.<br />
If <strong>Pfizer</strong>, a business partner or service provider receive Sensitive Personal Information or more<br />
extensive Personal Information than intended, expected or necessary for the business<br />
purpose, immediately notify your team attorney.<br />
Employ the same safeguards to protect the confidentiality of prescriber data as you would<br />
any other Personal Information. As a general rule, it should be used only for internal business<br />
purposes <strong>and</strong> not in dealings with <strong>Pfizer</strong>’s customers (such as the HCPs themselves) or<br />
external third parties.<br />
Any suspected breach of security of Personal Information or Sensitive Personal Information<br />
should be immediately reported. Lost or stolen computers or other devices containing <strong>Pfizer</strong><br />
data should be reported to the user’s local Service Desk / Help Desk. Any other incidents of<br />
potential unauthorized access to <strong>Pfizer</strong> data should be reported to the Global Security<br />
Operations Center at 212-733-7900 or GSOCwatchroom@pfizer.com.<br />
Laws Protecting Personal Data<br />
One of the most important federal healthcare laws in the area of privacy is called the Health Insurance<br />
Portability <strong>and</strong> Accountability Act of 1996 (HIPAA). HIPAA was significantly exp<strong>and</strong>ed by the Health<br />
Information Technology for Economic <strong>and</strong> Clinical Health Act (HITECH). HIPAA <strong>and</strong> HITECH impose<br />
strict limitations on the use <strong>and</strong> disclosure of Sensitive Personal Information by “covered entities” <strong>and</strong><br />
their “business associates.”<br />
Business Associate Agreements <strong>and</strong> Confidentiality Agreements<br />
Sometimes HCPs may incorrectly request that you sign a Business Associate Agreement (BAA). A BAA<br />
is an agreement that is entered into between a “covered entity” (e.g., an HCP or a health insurer) <strong>and</strong> a<br />
“business associate.” Generally, “business associates” are defined as entities or persons who perform<br />
138<br />
Rev. 09/12<br />
Page 5 of 18
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