Duties of Privacy Officer

The Privacy Officer will supervise all ongoing activities related to the development, implementation, maintenance of, and adherence to the privacy Regulations and the Practice's privacy policies and procedures. The Privacy Officer shall report directly to the President.

The privacy Officer shall:

• · Assist in the development, identification, implementation, and maintenance of the Practice's privacy policies and procedures in coordination with the Practice's other management personnel and Practice counsel.

• · Perform initial and periodic privacy risk assessments and conduct ongoing compliance monitoring activities.

• · Work with Practice counsel and management personnel, key departments, and committees to ensure the Practice has and maintains appropriate privacy documents that incorporate current Practice practices and applicable legal requirements.

• · Participate in privacy training and orientation for all Practice personnel.

• · Develop, implement, and monitor all trading partner and business associate agreements.

• · Establish, with Practice management and Practice counsel, a mechanism for tracking and logging the disclosure of a Patient's PHI.

• · Establish and administer a process for receiving, documenting, tracking, investigating, and taking action on all complaints concerning the Practice's privacy policies and procedures.

• · Ensure compliance with privacy practices and consistent application of sanctions for failure to comply with privacy policies for all Patients in the Practice's workforce, extended workforce, and for all business associates, in cooperation with the Practice's management personnel and Practice counsel.

• · Initiate, facilitate and promote activities that foster privacy awareness.

• · Coordinate the Practice's system-wide information security and privacy efforts.

• · Work with staff Members, Practice counsel and other consultants to maintain current knowledge of applicable federal and state privacy laws and accreditation standards, and monitor advancements in information privacy technologies to ensure organizational adaptation and compliance.

• · Serve as information privacy consultant to the organization for all departments and appropriate entities.