Privacy Management Program (DRAFT)

1. Define the scope of the program: Clearly define the types of health data that will be covered
under the program, including what data will be collected, how it will be used, and who will have
access to it.
2. Identify data sources: Identify all sources of health data, including electronic health records,
insurance claims, and patient surveys.
3. Establish data governance policies: Develop policies and procedures for managing health data,
including data quality, data security, and data retention.
4. Implement data encryption: Encrypt all health data to ensure it is protected in case of a data
breach.
5. Train employees: Train all employees on the privacy management program, including how to
handle and protect health data.
6. Develop incident response procedures: Develop procedures for responding to data breaches
and other incidents that may compromise the privacy of health data.
7. Conduct regular audits: Conduct regular audits of the privacy management program to ensure
compliance with regulations and best practices.
8. Develop a reporting system: Develop a system for reporting privacy violations or concerns,
including a hotline or email address for employees to report incidents.
9. Establish penalties for violations: Establish penalties for violations of the privacy management
program, including disciplinary action and/or termination of employment.
10. Review and update the program regularly: Review and update the privacy management
program regularly to ensure it remains effective and compliant with changing regulations and
best practices.