Privacy Officer's Roundtable

NDA for employees working from home

  • 1.  NDA for employees working from home

    Posted 03-24-2020 02:29 PM
    I'm hearing some mixed comments about the need to have work at home employees sign NDA's.  Some say this is needed to address privacy (and security) concerns in the home environment.  Other says that if they didn't sign an NDA for their normal work station and the log in and log out procedures for work from home are the same, you don't need one.  Thoughts?

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    Lee Braem
    Sr Corp Counsel & Chief Comp Ofcr
    Evonik Corporation
    Parsippany,NJ
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    2020 SCCE Membership


  • 2.  RE: NDA for employees working from home

    Posted 03-24-2020 05:02 PM
    I signed a two-page document last week called "Temporary/Emergency Telecommuting Policy." It talks about the the purpose of the policy, its scope, and then the policy itself. It states what the employee is expected to do and not do as well as remind them about privacy and security issues. It covers the topics Internet Service, Work Area, Equipment & Supplies, Security of Company Assets, and finally Work Hours and Performance Expectations.

    I don't have a problem with it at all. I wonder about people that fight against it. It only took a couple of minutes to read and sign. So why would someone not want to agree to the policy? Do they know in advance they can't commit to following it, such as actually working when working at home?

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    Carl Russell
    Compliance Analyst, CHPC
    Delta Dental of Idaho
    Boise,ID

    Anything I say is my sole opinion and not of my company.
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    2020 SCCE Membership


  • 3.  RE: NDA for employees working from home

    Posted 03-24-2020 05:09 PM

    We learned a long time ago that you have three types of employees:

     

    §  Engaged Employees: The engaged employees are those who work with full passion and are emotionally attached to the organization. They are innovative and provide new ideas and consistent performance to move the organization forward. They personalize the company's goals and objectives, and always work above and beyond their job requirements for the betterment of the organization.

    §  Not Engaged Employees: Such employees do put in their time, but not passion and energy into their work. These are the ones who do only what is asked of them. These employees can hold either a negative or positive attitude towards the organization. They consider their job as a paycheck, nothing more.

    §  Actively Disengaged Employees: These employees are unhappy, resentful, and spread negativity within the organization. However, despite doing less than the minimum, these employees last longer in the firm by removing employees whom they perceive will attain higher positions soon.

     

    It's those actively disengaged that have to cause problems EVERY SINGLE TIME! Thanks for being one of the engaged, Carl! Not everyone gets it.

     

    Allie


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  • 4.  RE: NDA for employees working from home

    Posted 03-24-2020 05:15 PM
    CCCCCCCCCCCCCCC!

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    David Rothery, CHC, AWI-CH
    Compliance & Privacy Officer
    Marin County, CA


    These are my personal opinions and not those of the County of Marin
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    2020 SCCE Membership


  • 5.  RE: NDA for employees working from home

    Posted 03-25-2020 08:51 AM
    Here's a scan of the policy I signed. It's two attachments because I haven't figured out how to merge on my home printer/scanner.

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    Carl Russell
    Compliance Analyst, CHPC
    Delta Dental of Idaho
    Boise,ID

    Anything I say is my sole opinion and not of my company.
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    2020 SCCE Membership


  • 6.  RE: NDA for employees working from home

    Posted 03-25-2020 10:38 AM
    Thank you Carl, this is very much appreciated.

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    David Rothery, CHC, AWI-CH
    Compliance & Privacy Officer
    Marin County, CA


    These are my personal opinions and not those of the County of Marin
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    2020 SCCE Membership


  • 7.  RE: NDA for employees working from home

    Posted 03-26-2020 08:41 AM
    Thank you for sharing Carl.  I am struggling with the same issue as all of our employees sign a confidentiality attestation annually but that does not cover some of the things encountered when working remotely.  I am suggesting that we use something like this and also distribute it to our provider network and strongly encourage them to use something similar.  We also have allowed some providers to connect to our network with personal devices through a VPN until laptops can be purchased as they are in short supply right now which raises a whole new area of concern.  They must submit detailed plans for this that must be approved by our CIO and CEO.  The newest issue for at home/remote workers is the potential for "Alexa" (and other devices) to hear confidential conversations!

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    Diane Bennett
    QI/Compliance-Privacy Officer
    NorthCare Network
    Marquette,MI
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    2020 SCCE Membership


  • 8.  RE: NDA for employees working from home

    Posted 03-25-2020 10:54 AM
    While I do not beleive there is any legal requirement to have one, I would certainly recommend crafting some sort of telework agreement that addresses mulitiple points including the privacy and security of the home work space as Carl pointed out were in his agreement. I also signed an agreement with similar language this week. Our HR department controlled that entire process.

    Thanks and Good Luck!

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    Jamie Parker, JD, CHPC, CHRC
    Chief HIPAA / Medical Privacy Officer
    University of Alabama
    Tuscaloosa, AL
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    2020 SCCE Membership


  • 9.  RE: NDA for employees working from home

    Posted 03-27-2020 07:52 AM
    ​We had similar documentation that was sent first to all leadership and then second to all employees.  The information is available on-line to all employees.  We did not have employees sign this particular document.  Many of the elements of the document, including HIPAA, confidentiality, etc., are all part of our regular on-boarding/orientation, leadership education, and annual education for all employees - which is documented.  As we consider a broader work-from-home option (outside of the current emergency situation), I think some sort of contract or agreement is a good idea to consider.

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    Timothy Koob
    Compliance Officer & Director

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    2020 SCCE Membership