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Hill-Rom Global Code of Conduct

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Q:<br />

Bianca works in <strong>Hill</strong>-<strong>Rom</strong>’s<br />

Accounts Receivable<br />

Department. Bianca’s job<br />

sometimes requires her to mail<br />

invoices and other documentation<br />

containing patient information. Bianca<br />

mailed an invoice containing patient<br />

information to the wrong patient by<br />

accident. What should she do?<br />

A:<br />

Bianca should notify her<br />

manager and the <strong>Hill</strong>-<strong>Rom</strong><br />

Privacy Officer immediately.<br />

<strong>Hill</strong>-<strong>Rom</strong> may have legal obligations to<br />

notify the patient that his or her<br />

information was accidentally provided<br />

to another patient. Bianca should<br />

ensure that she provides all relevant<br />

information, such as the date the<br />

error occurred and when she became<br />

aware the information was accidentally<br />

disclosed, to the Privacy Officer.<br />

The <strong>Hill</strong>-<strong>Rom</strong> Privacy Officer<br />

can be reached by telephone<br />

at 812-931-2246, or via email<br />

at privacy_<strong>of</strong>ficer@hill-rom.com<br />

<strong>Hill</strong>-<strong>Rom</strong> <strong>Global</strong> <strong>Code</strong> <strong>of</strong> <strong>Conduct</strong> 18<br />

Data Privacy<br />

We must appropriately safeguard the privacy <strong>of</strong> all personal information<br />

concerning patients, customers, suppliers, contractors, vendors, and<br />

others that we receive in the course <strong>of</strong> our work.<br />

Patient Information<br />

We must adequately safeguard the privacy <strong>of</strong> medical records and<br />

other patient information that we receive or access while performing<br />

our jobs. As a medical device and technology company, we are<br />

subject to various health information privacy laws, and we must<br />

understand and fully comply with them.<br />

What is Patient Information?<br />

Patient information is any information about health status,<br />

the provision <strong>of</strong> health care, or payment for health care that<br />

can be linked to a specific individual. It includes any information<br />

related to a patient’s health condition, services received,<br />

invoices, medical charts, and insurance coverage information.<br />

Violations <strong>of</strong> health information privacy laws can result in criminal<br />

or civil liability and/or fines. If you need further information about<br />

health information privacy laws, please contact the <strong>Hill</strong>-<strong>Rom</strong><br />

Privacy Officer or the Legal Department.<br />

Customer and Supplier Information<br />

We must also protect confidential information belonging to our<br />

customers, suppliers, contractors, and vendors. Confidential<br />

information may include business records or data, personal<br />

and financial information, personal identification numbers,<br />

bank records, trade secrets, and proprietary information.<br />

If you have access to or otherwise come into contact with this<br />

type <strong>of</strong> information, you must ensure that it is handled according<br />

to our Policy on Confidential Information and Non-Disclosure<br />

Agreements, as well as any confidentiality obligations we have<br />

in agreements with third parties. For more information, please<br />

contact the Privacy Officer or the Legal Department.<br />

November 2011<br />

<strong>Hill</strong>-<strong>Rom</strong> <strong>Global</strong> <strong>Code</strong> <strong>of</strong> <strong>Conduct</strong> 19

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