White Guide and Orange Guide Formatting Project - Pfizer

Seek Only De-Identified Data
Orange Guide – Chapter 8: Privacy: Protecting Personal Information
Under limited and specific circumstances, and in consultation with your Regional Attorney, it may be
appropriate for colleagues to receive certain “aggregated” or “de-identified” patient information from
an HCP or other third party. “Aggregated” data is information about multiple individuals that is
compiled and does not allow for the identification of any one individual. “De-identified” data is data
that cannot be attributed to any specific individual or used to identify any individual and usually has
been stripped of certain key identifiers which, either alone or in combination with other available
information, could link the information with a specific individual or be used to identify a specific
individual (including the individual’s name, many elements of the individual’s address, telephone
number, and social security number, among others). HIPAA regulations include strict standards for
what is “de-identified.” Accordingly, before assuming information is “de-identified,” consult Legal.
To assist in the collection of permitted data, Pfizer has approved surveys and screening tools that have
been designed specifically to collect only appropriate, de-identified patient information. Most of these
tools are approved for use only by field-based Medical Colleagues.
Obtain Patient Consent (via Signed Authorization) Where Appropriate
In certain circumstances, it may be appropriate or even necessary for Pfizer to receive Sensitive
Personal Information from patients or consumers as part of certain approved activities. You must
ensure that the appropriate patient consent has been obtained by the HCP or health plan prior to:
Engaging in approved Pfizer-sponsored third party communications;
Engaging in a mentorship or preceptorship involving patient contact;
Collecting Sensitive Personal Information as part of an approved survey, screening tool or
other similar activity that you have received advance approval to use;
Using or disclosing Personal Information from consumers in connection with coupon
programs or other consumer offerings; and
Collecting, using or disclosing Personal Information in connection with Pfizer patient
assistance programs.
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Rev. 09/12
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