Campus Privacy Officer

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Campus Privacy Officer
The candidate develops, guides, and assists in the identification and maintenance of the University healthcare information privacy policies and procedures working collaboratively with the health sciences unit’s leadership (i.e., University Health Services, School of Optometry, Psych Clinic), to help ensure compliance with University policies, federal and state laws and the protected health information privacy practices. Additionally, in accordance with the UCOP systemwide HIPAA Taskforce recommendations, whereby each chancellor shall designate one or more individuals in the coordinating role regarding HIPAA compliance, university has assigned the HIPAA liaison responsibility to the campus Privacy Officer. Supports the Deputy Associate Chancellor/Compliance Officer and university’s commitment to protecting the privacy of personal information of research subjects, faculty, staff, students and other members of the community. Regularly work on highly variable and complex privacy issues where analysis of situations or data requires an in-­-depth evaluation of multiple factors. Work on privacy related projects of diverse scope that require the development of innovative strategies for implementing compliance communication, training, and policies and procedures in the area of privacy. Directs, delivers, or ensures delivery of privacy and healthcare compliance training and orientation to appropriate clinical practice personnel and management faculty and students, and other appropriate third parties. Works collaboratively with the clinical units and other applicable organization units in overseeing patient rights to inspect, amend, and restrict access to protected health information when appropriate. Establishes and administer a process for receiving, documenting, tracking investigating, and acting on all complaints concerning the HIPAA and privacy policies and procedures in coordination and collaboration with other similar functions and, when necessary, legal counsel. Cooperates with the U.S. Department of Health and Human Service's Office for Civil Rights, State regulators and/or other legal entities in any compliance reviews or investigations. Serves as UC systemwide Privacy Officer designee.
Assessment and reporting of privacy risks at the campuswide, control unit, or Department levels. Includes identifying and assessing new or emerging risks as well as monitoring how campus risks are changing over time. Also includes performing control-­-gap analyses to help in management’s risk response. Performs initial and periodic information HIPAA and privacy risk assessments and conduct related ongoing compliance monitoring activities in coordination with health entities and other compliance and operational assessment functions.
Works with administration, legal counsel, faculty and other related parties to represent the organization's information privacy interests with external parties (state or local government bodies) who undertake to adopt or amend privacy legislation, regulation, or standard. Performs required breach risk assessment, documentation, and mitigation. Works with appropriate officials to ensure consistent application of sanctions for privacy violations. Directs and coordinates HIPAA or privacy breach and incident notification activities.
Leading and Monitoring of the campuswide Privacy Program as well as of risk response programs in place at the control unit and department levels. Includes preparing reports for the Compliance, Enterprise Risk Committee (CERC) and Information Risk Governance Committee (IRBC). Co-chairs the Information Risk Governance Committee and General Data Protections Regulations working group. Oversees Privacy and Online Monitoring Policy to ensure monitoring policies are enforced and do not deviate from best practices and established norms. Directs and participate in the development, implementation, and ongoing compliance monitoring of various agreements, to ensure all privacy concerns, requirements, and responsibilities are addressed. Establishes with management and operations a mechanism to track access to protected health information within the purview of the University of California System as required by law and to allow qualified individuals to review or receive a report on such activity. Advisory and facilitation support to control units and Departments in the development of their privacy risk response programs as well as in the incorporation of privacy risk assessments into their initiatives or projects. Works with University personnel involved with any aspect of release of protected health information, to help ensure full coordination and cooperation under university ’s policies and procedures and legal requirements. Works within the organization and system-wide to attain a coordinated approach responsive to organization needs. Assists departments with building expertise in privacy laws, policies and best practices. Maintains and grows expertise on privacy issues relevant to universities. Networks with colleagues at other like institutions to understand and promulgate best practices. Serves as a resource on good privacy configurations and controls. Communicates complex privacy Principles, concepts and regulations in simple and actionable terms. Administers, evaluates, and continuously refines the campus Information, Privacy, and Records Management Program that includes policy, procedures, best practices, and training modules to enhance campus compliance with the Information Practices Act (IPA), Freedom of Information Act (FOIA), Family Education Records Privacy Act (FERPA), Health Insurance Portability and Accountability Act of 1996 (HIPAA), and other legislation and University policy pertaining to the access to and privacy, integrity and disposition of, information and records under university 's stewardship. Serves as a consultant for campus departments evaluating their record management, retention and disposition practices. Provides relevant tools and resources for Business Officers and record proprietors. Interprets information management policy and legislation, providing advice to senior management, faculty, managers, supervisors, information technology/systems developers and administrators, academic and nonacademic staff, students, media, and the public. Stays current in information and records management principles, regulations, and best practices for higher education through reading, professional associations, collaboration, and training. Acts as University of California Electronic Communications Policy (ECP) designated campus officer. Partners with IT in the administration of the campus- privacy implementing guidelines for the ECP. Provides interpretative guidance to the campus on ECP. Direct the nonconsensual access review process, ensuring 1) access complies with policy and law and 2) appropriate notifications are sent. Coordinates with General Counsel on ECP issues as appropriate. Serves as a subject matter expert to local Practice HIPAA Officers of health entity on Privacy and Security compliance internal controls, policies, procedures and best practices. Performs periodic information privacy risk assessments and conduct related ongoing compliance monitoring activities. Serves on Healthcare and Security Compliance committee in the review of annual “checklist of HIPAA compliance activities” and reporting responsibilities. Serves as UC systemwide HIPAA Privacy Officer designee. Determines significant operational and control risks, implements appropriate process improvements and best practices, and manages campus communications structure to improve control environment. Assesses and inventories data access/use policies and practices of the campus on a rolling basis at the campus, unit, or department level, as appropriate. Proposes, leads and / or participates on policy and planning committees and working groups. Stays abreast of activities and initiatives across campus that may have the potential to affect the campus risk profile. Collaborates with Chief Information Security Officer (CISO) and others regarding information systems and electronic systems.

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