The Organization will maintain the confidentiality of information which is financial or health-related
information, including but not limited to “protected health information” (“PHI” as defined by HIPAA),
information on plan participants, employees, students, other employees, research, and financial and
business operations, and any other information that is deemed to be confidential by other laws or
Organization policies, “Confidential Information”.
Confidential information may be information in any form: e.g., written, electronic, oral, overheard or
observed. Access to all information is granted on a “need-to-know basis”. A “need to know” is defined
as information that is required in order to do your job.
During your daily work, you may be exposed to information that is considered strictly confidential.
This information should not be discussed with anybody, including; other co-workers, other families,
your family, and friends. You must be alert to others overhearing your discussions regarding a plan
participant’s Confidential Information. Any inquiries from the media concerning a covered participant
should be referred to the office of the Executive Director during normal working hours. Disclosure of
confidential information is grounds for disciplinary action up to and including termination. All
business records provided to you or in your possession must be returned to the Organization upon
termination of your employment.