Chief Privacy Officer

The Chief Privacy Officer oversees all ongoing activities related to the development, implementation, maintenance of, and adherence to the organization’s policies and procedures covering the privacy of, and access to, patient health information in compliance with federal and state laws and the health care organization’s information privacy practices.

Responsibilities

• Provides development guidance and assists in the identification, implementation, and maintenance of organization information privacy policies and procedures in coordination with organization management and administration, the Privacy Oversight Committee, and legal counsel
• Works with organization senior management and corporate compliance officer to establish an organization-wide Privacy Oversight Committee
• Serves in a leadership role for the Privacy Oversight Committee’s activities
• Performs initial and periodic information privacy risk assessments and conducts related ongoing compliance monitoring activities in coordination with the entity’s other compliance and operational assessment functions
• Works with legal counsel and management, key departments, and committees to ensure the organization maintains appropriate privacy and confidentiality consent, authorization forms, and information notices and materials reflecting current organization and legal practices and requirements
• Oversees, directs, delivers, or ensures delivery of initial and privacy training and orientation to all employees, volunteers, medical and professional staff, contractors, alliances, business associates, and other appropriate third parties
• Participates in the development, implementation, and ongoing compliance monitoring of all trading partner and business associate agreements, to ensure all privacy concerns, requirements, and responsibilities are addressed
• Establishes with management and operations a mechanism to track access to protected health information, within the purview of the organization and as required by law, and to allow qualified individuals to review or receive a report on such activity
• Works cooperatively with the HIM Director and other applicable organization units in overseeing patient rights to inspect, amend, and restrict access to protected health information when appropriate
• Establishes and administers a process for receiving, documenting, tracking, investigating, and taking action on all complaints concerning the organization’s privacy policies and procedures in coordination and collaboration with other similar functions and, when necessary, legal counsel
• Ensures compliance with privacy practices and consistent application of sanctions for failure to comply with privacy policies for all individuals in the organization’s workforce, extended workforce, and for all business associates, in cooperation with Human Resources, the information security officer, administration, and legal counsel as applicable
• Initiates, facilitates, and promotes activities to foster information privacy awareness within the organization and related entities
• Works with organization administration, legal counsel, and other related parties to represent the organization’s information privacy interests with external parties (state or local government bodies) who undertake to adopt or amend privacy legislation, regulation, or standard

Qualifications

• Certification as a RHIA or RHIT with education and experience relative to the size and scope of the organization
• Knowledge and experience in information privacy laws, access, release of information, and release control technologies
• Knowledge in and the ability to apply the principles of HIM, project management, and change management
• Demonstrated organization, facilitation, communication, and presentation skills