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AppendixD <br />MPHI Confidentiality Agreement <br />Confidentiality Agreement for Michigan Public Health Institute Staff <br />Assigned to Privacy-Sensitive Projects <br />As described in the Michigan Public Health Institute (MPHI) Employee Handbook, all MPHI <br />employees have the responsibility to maintain the accuracy, availability, completeness, and <br />confidentiality of the business information, trade secrets, and data to which they have access. <br />Due to the nature of its work, MPHI has access to, stores, uses , and discloses data (including <br />Protected Health Information as defined by the HIP AA Privacy Rule). Any or all of the <br />following factors may require that use and disclosure ofthese data be restricted in various ways : <br />1. Federal, tribal, state and local laws and regulations. Examples include: the HIPAA and <br />HITECH, which govern the privacy and security of health information and the Common <br />Rule that governs Institutional Review Boards and research with human subjects. <br />2 . MPHI policies, procedures and training, including project-specific protocols. 1 <br />3. Contractual agreements between MPHI and project partners and clients. <br />MPHI employees must annually sign this agreement to demonstrate that they are aware of their <br />obligations to protect the confidentiality and security of the data to which they have access. <br />By signing this agreement, I agree to the following: <br />1. I will comply with all laws, regulations, contractual agreements, MPHI policies and <br />procedures, and project-specific protocols related to my assigned duties . I understand <br />that I may be required to complete additional training related to these obligations. <br />2. I will safeguard and will not disclose my work related password(s), access code(s), or any <br />other work related authorization(s). I understand that MPHI may at any time revoke my <br />password(s), access code(s), other authorization(s), or access. <br />3. At all times during my employment, I will safeguard the confidentiality of all information <br />to which I have access. I will not carelessly handle information. I will not in any way <br />divulge, copy, release, sell, loan, review, alter, or destroy any information except as <br />properly authorized within the scope of my assigned duties at MPHI. <br />4. I will only access information for which I have a need to know and I will use that <br />information only as needed to perform my legitimate duties as an employee of MPHI. <br />5. I will not misuse information. <br />6. I will promptly report activities by any individual or entity that I suspect may <br />compromise the availability, integrity, security, or privacy of information held by MPHI. <br />I understand that reports made in good faith about suspect activities will be held in <br />confidence to the extent permitted. <br />7. I understand that I have no right or ownership interest in any information referred to in <br />this agreement. <br />11