PURPOSE

This policy was established to protect Faculty Members, Professional Staff Members, Students and patients against a breach of privacy and/or confidentiality.

APPLICABILITY

This policy applies to all eligible Faculty and Professional Staff Members, excluding Professional Staff Members affiliated with a collective bargaining unit.

IMPLEMENTATION

Implementation of this policy is the responsibility of the individual supervisor with guidance from the supervisor’s HR Partner.

ADMINISTRATIVE OVERSIGHT

The Executive Vice President, Treasurer and Chief Operating Officer is the Drexel University official responsible for the administration of this policy.

POLICY

The University protects the legal rights of Faculty Members, Professional Staff Members, Students and patients, against breach of confidentiality. Such information includes personnel and/or medical record data, salary and benefits information, peer review information, and other confidential statements and/or materials. Unauthorized accessing of medical records or other records (whether computerized or manual), divulging confidential information regarding a patient, medical staff member, Faculty Member, Professional Staff Member or student to an unauthorized third party, using confidential information for personal use, and/or inappropriately removing confidential information from organization premises are strictly prohibited and may result in disciplinary action, up to and including immediate termination. This policy is designed to limit exposure to allegations of breach of privacy and breach of the Faculty and Professional Staff Members duty of confidentiality, as well as to protect against compromising patient care and the University’s reputation.

DEFINITIONS

Faculty Member is defined as an individual employed by Drexel University in a tenured, tenure-track, non-tenured track or adjunct position who teaches at any college, school, center or institute in the University.  A Faculty Member also is deemed to be exempt under the provisions of the Fair Labor Standards Act (FLSA) and/or applicable state law.

Professional Staff Member is defined as an individual employed in any non-faculty category by Drexel University, including an individual who is deemed to be either exempt or non-exempt under the provisions of the Fair Labor Standards Act (FLSA) and/or applicable state law.

Student is defined as any person currently enrolled, whether part-time or full-time, in undergraduate or graduate courses or programs.  Undergraduate Student denotes any Student who is primarily enrolled in undergraduate courses or program and has not obtained a bachelor’s degree in such course of study or program.  Graduate student denotes any Student who is primarily enrolled in graduate courses or program who is working toward a graduate degree or certification after having earned a bachelor’s degree.

PROCEDURES

1. A healthcare organization’s duty to safeguard confidential information arises out of the privacy rights of patients, Faculty Members, Professional Staff Members, Students, medical staff, and others with whom there are relationships which impose special obligations. Among the types of information which raise special concern are: patient medical information, including medical condition, health status, treatment plans; personnel transactions, including compensation adjustments, performance evaluations, disciplinary actions, grievance procedures, employment demographic information, employment agreements, benefit plan information; appointment schedules both medical and administrative; telephone access and usage records; security access control logs and parking control logs; student academic records; medical staff and faculty credentialing; peer review and quality review information; faculty appointment, promotion and tenure records; insurance and litigation information.
2. Several offices of the University administer functions that require handling of Faculty Members, Professional Staff Members and Student personal data, including Social Security numbers. Data concerning such personal information can be shared among offices of the University under a strict need-to-know basis. However, any information containing Faculty Members, Professional Staff Members and Student personal information can be shared with entities outside the University, including auditors, benefits providers, and governmental agencies, only with the specific approval of the Vice President of the Human Resources Department.

AT-WILL EMPLOYMENT NOT AFFECTED

Notwithstanding anything to the contrary stated in this policy, nothing herein is intended to alter the at-will status of any Professional Staff Member.  Drexel University at all times retains the right to terminate any Professional Staff Member at any time for any lawful reason, or for no reason at all.