White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 8: Privacy: Protecting Personal Information
work on behalf of a covered entity (e.g., certain types of vendors are considered “business associates”).
Because Pfizer does not perform work on behalf of HCPs, it is not appropriate for Pfizer or for you
to enter into a BAA.
Some HCPs will request a BAA when what they really are seeking is a confidentiality agreement to
protect their patients’ Sensitive Personal Information in the event it is inadvertently disclosed in your
presence. To address such requests, Pfizer has developed two Pfizer template forms, either of which
you are permitted to offer to the HCP as assurance of your intent to keep Sensitive Personal
Information confidential. The Privacy Pledge can be signed and provided to HCPs or customers who
might have general concerns about Pfizer’s position on HIPAA as it relates to its representatives. The
Patient Health Information Confidentiality Agreement can be signed and provided to an HCP or
institution that would like a specific agreement to cover situations where a Pfizer representative
inadvertently comes into contact with Sensitive Personal Information. No changes can be made to
these templates before signing them unless Legal has approved the change in advance.
A copy of the Privacy Pledge and Patient Health Information Confidentiality Agreement can be
downloaded from PfieldNet at http://PfieldNet.pfizer.com under the “Compliance” tab.
Business Associate Agreements
Q. What should I do if a physician insists that I sign a Business Associate
Agreement before I enter the patient clinic? Can I sign the Business Associate
Agreement to avoid being shut out?
A. No. You must not sign a Business Associate Agreement, even if required by an
HCP in order to be allowed access to a facility. Colleagues are able to sign the
Pfizer Privacy Pledge or Patient Health Information Confidentiality
Agreement template found on PfieldNet. Providing a copy of one of these
documents with your signature is usually enough to satisfy the HCP’s concerns
about patient privacy. If the HCP continues to insist on a Business Associate
Agreement, please promptly contact your Regional Attorney who may be able
to provide assistance to you.
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Rev. 09/12
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