Privacy Program Management Flashcards

Under HIPAA, a covered entity's Privacy Officer receives a complaint from a patient who believes their PHI was improperly disclosed. What is the FIRST action the Privacy Officer should take?

Answer: Acknowledge the complaint and initiate an investigation according to the complaint management process

Upon receiving a privacy complaint, the Privacy Officer must acknowledge receipt and investigate according to the organization's complaint management procedures.

A healthcare organization implements a 'Privacy by Design' approach. Which principle best describes this concept?

Answer: Integrating privacy protections into the design and architecture of systems from the outset

Privacy by Design embeds privacy protections into systems and processes from the beginning of development rather than as an afterthought.

Which of the following BEST describes the concept of 'data minimization' in healthcare privacy program management?

Answer: Collecting and using only the minimum PHI necessary to accomplish the intended purpose

Data minimization means collecting, using, and retaining only the minimum PHI necessary for the specific purpose, consistent with HIPAA's Minimum Necessary standard.

A healthcare organization wants to share a patient's case study in a medical journal. Which is the MOST appropriate privacy approach?

Answer: De-identify the information to Safe Harbor standards before publication

Publishing de-identified case studies that meet the Safe Harbor standard removes HIPAA applicability entirely and is the most appropriate approach for journal publication.

Which of the following best describes the role of a Privacy Steering Committee in a healthcare organization?

Answer: A cross-functional body that provides governance, oversight, and strategic direction for the privacy program

A Privacy Steering Committee provides enterprise-level governance, aligning the privacy program with organizational strategy and ensuring cross-departmental accountability.

Under a comprehensive privacy program, which document maps the flow of PHI through an organization to identify privacy risks?

Answer: Data Flow Diagram or Data Map

A data flow diagram or data map visually represents how PHI moves through an organization, helping identify where it is collected, used, stored, and disclosed.