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Personnel Records - Protected Health Information

Do personnel records of the staff need to be separated, with one for general information and the other with personal health information?  

Any examples are for illustrative purposes only.

It is up to the organization to decide whether to maintain one file or to separate the personnel file into two sections. The primary issue related to this decision is the organization's ability to maintain confidentiality for the protected health information of the staff. For paper files this is usually easier to accomplish with two files since the organization can better control who has access to the protected health information, while allowing staff to have access to the more general personnel information. In electronic files, this can be accomplished by controlling access through passwords for authorized office staff. For either form of record keeping, the information should only be available to authorized staff in accordance with law and regulation.

Manual: Health Care Staffing Services
Chapter: Information Management HSIM
Last reviewed by Standards Interpretation: February 08, 2022 Represents the most recent date that the FAQ was reviewed (e.g. annual review).
First published date: April 11, 2016 This Standards FAQ was first published on this date.
This page was last updated on February 08, 2022 with update notes of: Review only, FAQ is current Types of changes and an explanation of change type: Editorial changes only: Format changes only. No changes to content. | Review only, FAQ is current: Periodic review completed, no changes to content. | Reflects new or updated requirements: Changes represent new or revised requirements.

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