Chiropractic professionals and other individuals and organizations that collect, store, and use personal data in any capacity are facing challenging times.
Given stringent legal and regulatory obligations existing under HIPAA and other health-privacy legislation, you and other healthcare professionals have long recognized the importance of maintaining the privacy of health information. Even prior to the enactment of HIPAA, health professionals had legal obligations to protect patient privacy.
However, privacy is getting tougher to maintain, and consumers are expecting more guarantees from those in which they entrust their most private information.
As a result, it’s now more important than ever to have a solid, proactive privacy strategy. Yet few organizations actually do. Anecdotal evidence suggests many organizations continue to take a reactive approach to privacy, choosing to direct their privacy strategy toward addressing specific requirements of laws and responding to actual breaches when they occur as required by law.
In addition, studies and surveys confirm that many organizations predominantly view privacy as a risk to be avoided rather than as an opportunity to build consumer trust. Organizations that take a more holistic, proactive approach to privacy are likely to reap the rewards, with increased patient confidence and trust.
While there is no one-size-fits-all approach to adopting a privacy strategy, certain key steps apply to all organizations. The following recommendations are provided to guide practitioners through a checkup of their information privacy and security programs.
1. Conduct an initial and ongoing internal audit. Before an organization can provide its patients with useful information about its privacy policies and practices, it must first understand what they are.
To do this, conduct an internal audit to identify what data you are collecting, how you are using that data, with whom you are sharing that data, and how you are protecting that data.
Once you complete the initial audit, conduct additional compliance audits each 90 days to ensure compliance with law and your internal policies and procedures.
2. Develop a privacy policy. Once you have clarified your organization’s policies and plans for collecting and using patient data, develop and communicate formal policies internally and externally.
For covered entities, it is important to note that providers must have documented policies and practices clearly stating patient privacy and protected health information security. Patients must receive policies regarding consent, authorization, disclosure, and rights.
While HIPAA dictates much of what is to be included in a privacy policy, it will be essential to ensure that implemented policies reflect accurately what your organization does and will do with respect to patient information.