White Guide and Orange Guide Formatting Project - Pfizer

Signing Customer Confidentiality Agreements
State and Other Privacy Laws
Orange Guide – Chapter 8: Privacy: Protecting Personal Information
Q. If an HCP insists that I sign a facility’s Confidentiality Agreement, even after I
sign and show him or her Pfizer’s Privacy Pledge and Patient Health
Information Confidentiality Agreement, can I sign what the HCP wants me to
sign?
A. Maybe. Sometimes these agreements are acceptable to sign, but you should
never do so unless your Regional Attorney has first reviewed and approved
the agreement.
Although many of Pfizer’s activities are not covered by HIPAA, some of our activities still may be
covered by other laws and regulations, including state privacy laws. Therefore, except as expressly
authorized by your manager or Regional Attorney, you must avoid collecting, maintaining, or
using Sensitive Personal Information. If you inadvertently come into contact with Sensitive Personal
Information or are asked to collect it, you should contact your Regional Attorney immediately to
discuss Pfizer’s policies regarding safeguarding such information.
Steps to Protect Patient Privacy
Avoid Intentional and Inadvertent Disclosure of Sensitive Personal Information
HCPs are subject to many restrictions regarding the use and disclosure of Sensitive Personal
Information. Generally, HCPs are not permitted to disclose a patient’s SPI to a third party unless they
receive prior written authorization from the patient. You must avoid situations in which you may be
exposed to SPI without an individual’s consent. In the event an HCP or other person exposes you to SPI,
you should not document or reproduce the information in any media or form. You must strictly
maintain the confidentiality of such information in accordance with Pfizer’s policy of safeguarding the
privacy of all patient-related data. Even if an individual has consented to a use or disclosure of SPI, such
as during a mentorship, you must still abide by the rules discussed in this Chapter and consult your
Regional Attorney to ensure compliance with Pfizer policies and applicable laws regarding the use,
disclosure, and destruction of any SPI to which you are exposed.
140
Rev. 09/12
Page 7 of 18