Privacy Officer's Roundtable

  • 1.  Who is involved in your investigation process?

    Posted 06-14-2022 05:18 AM
    Is Privacy the lead interviewer/investigator in your workplace? Are there any cases where you would allow the employees manager to handle all of this and just report the results to Privacy? And the second piece of my question is, do any of you have a very strict quick turnaround time for any investigation type like snooping? My human resources department eoukd like to create a standardized workflow for privacy that allows managers to perform the tasks of the privacy officer in a few instances such as family member:or coworker snooping.  And also create a "drop everything and interview starts now' type of workflow for Privacy to start and complete within three days. They would like this for things like Snooping, inappropriate disclosure, etc. We have a meeting to discuss their thoughts but I wanted to know ahead of time if anybody else does this.

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    Tara Yeaton, RHIT, CHPC
    Director of HIM Operations
    Deputy Privacy Officer
    MaineGeneral Medical Center
    Augusta, Me
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  • 2.  RE: Who is involved in your investigation process?

    Posted 06-14-2022 09:55 AM

    I am the Corporate Compliance & Privacy Officer and report directly to the CEO.  I am the lead interviewer/investigator, unless I delegate a task to a manager/director.  For example, a nurse I needed to talk to was working the night shift, and the manager was going to see her at shift change the next day, so I gave the manager the questions to ask her.  

     

    Our HR department would not dictate-anything about how I handle these investigations, unless I wanted them to.  I have my own policies/procedures, and my turn-around time depends on many things.  If you have a turn-around time of 3 days, you're just setting yourself up for failure.  What if you receive 5 privacy incidents in one day?  You may be able to handle that if you have a department of more than one or two people, but for privacy issues, I am a department of one and may not get all of that done in 3 days.  In addition, staff you need to interview may be out sick or on vacation.  There are many reasons why policies and procedures should be clear on the process, but should also be somewhat vague on time frames, unless it's a law, regulation, etc.

     

    Cinda

     

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  • 3.  RE: Who is involved in your investigation process?

    Posted 06-14-2022 10:56 AM
    Yes!  That's exactly what I was saying.  There are many times I cannot get to the person I need to. I had a meeting this morning with someone, that I couldn't get to for 7 days from the time it was reported because they were on vacation.   This forum rocks.  I am bringing all of the feedback with me to the meeting.  Hoping they understand all the ifs, ands, and buts that go with this process.

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    Tara Yeaton, RHIT, CHPC
    Director of HIM Operations
    Deputy Privacy Officer
    MaineGeneral Medical Center
    Augusta, Me
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  • 4.  RE: Who is involved in your investigation process?

    Posted 06-14-2022 11:35 AM
    I would echo everything that Cinda stated.  I'd also add that having this short time frame might mean you have to talk to an employee during their day off, which might mean overtime or adding back leave to their leave bank.

     

    David Garrison 

    Compliance/Privacy Officer 

    SEARHC Executive Offices

    P: 907.364.4466 F: 907.463.4075
    3100 Channel Drive, Suite 300 | Juneau, AK 99801


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  • 5.  RE: Who is involved in your investigation process?

    Posted 06-15-2022 07:30 AM
    Tara,  I agree with Cinda and David.  I do not have anything in writing as to the timeline for the investigative process.  However, it is my goal to have the investigation closed within 15 days.  There are reasons that this may get extended.  Please note that we are talking about a Privacy event that is being investigated, not an HR event.  Therefore, any workflow process developed, I believe should fall under the Privacy umbrella to dictate.  I understand every organization functions differently and HR may simply wish to have consistency with Privacy in the workflow and timeframes for how investigations are handled.

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    Debra Larkin
    Corporate Director of
    Compliance/Privacy Officer
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  • 6.  RE: Who is involved in your investigation process?

    Posted 06-16-2022 12:33 AM
    Attached is an excellent resource from NAVEX (14 pager):
    Becoming a Master Workplace Investigator eBook

    ADDITIONAL RESOURCES
    »» Harassment Investigation Checklist
    From deciding who to interview first, to implementing changes to existing harassment policies, make sure that you
    cover all 14 key steps to conduct an effective investigation.
    Download the Checklist

    »» The Impact of Workplace Investigations on Corporate Culture Webinar
    View this webinar on-demand to learn how to demonstrate to employees that workplace investigations can be
    trusted and what to do after an investigation to best support your organization and culture.
    Watch Webinar recording. See NAVEX webinar on-demand page - investigation webinars

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    Ximena Restrepo
    Compliance Audit Specialist
    Billings Clinic
    Billings,MT
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  • 7.  RE: Who is involved in your investigation process?

    Posted 06-16-2022 07:21 AM

    Thank you Ximena!

    Cinda

     

     

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  • 8.  RE: Who is involved in your investigation process?

    Posted 06-17-2022 09:24 AM
    I am the same as Cinda, as I am the Compliance Officer and HIPAA Privacy Officer.  I am also a department of 1 but will ask for assistance from the Director from time to time.  Also there are times I request the assistance of Risk if I have any concerns the situation may turn into a legal issue at some point.

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    Ann Dunham
    MBA, SPHR, CHC, CHRC
    Compliance Officer
    Hannibal Regional Healthcare System
    Hannibal, MO
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