White Guide and Orange Guide Formatting Project - Pfizer

Orange Guide – Chapter 8: Privacy: Protecting Personal Information
operation is hired to send the approved information to patients, an approved Pfizer Authorization for
Mailing must be signed by the health plan or pharmacy to ensure compliance with these principles.
All materials sent to patients must be approved by the appropriate Pfizer Review Committee (RC),
which will consider potential issues of patient privacy and patient consent as part of its review process.
Chart Reviews
Q. Is it permissible to conduct chart reviews as part of our collaborative
studies/programs with customers? If I sign a Business Associate Agreement,
would that make it allowable?
A. No. It is Pfizer policy that colleagues should never conduct a chart review. In
addition, as discussed earlier, Pfizer is not a Business Associate of an HCP and,
therefore, field-based colleagues must not sign Business Associate Agreements
under any circumstance.
Consumer Health Fairs and Screenings
Consumer health fairs and screenings may raise patient privacy concerns since Personal Information is
often obtained in the presence of sales representatives or other Pfizer colleagues attending the health
fair. Pfizer Colleagues should not engage health fair attendees in discussions regarding their specific
health status, symptoms, diagnosis or treatment. These discussions should occur between the patient
and an appropriate HCP. Should a patient attempt to initiate such a discussion, the Pfizer colleague
should make clear that he or she is not an HCP, is not providing medical advice, and should redirect the
patient to an HCP at the fair or to his or her physician.
Interaction with Consumers at Health Screenings by Pfizer Colleagues with Medical Background
Q. May a colleague with a medical background counsel consumers on how to
interpret their screening results at a Pfizer-sponsored health screening?
A. No. Pfizer colleagues are not permitted to counsel patients about screening
results, regardless of their education background or experience. The patient
should be referred to his or her HCP.
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Rev. 09/12
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