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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.

Last updated on June 16, 2020
Manual: Health Care Staffing Services
Chapter: Information Management HSIM

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