By Schwarz H.-U.

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3]The information and opinions provided in this book do not constitute or substitute for legal or other professional advice. This document is created with the unregistered version of CHM2PDF Pilot Privacy Implementation Costs Exhibit 1 contains the Privacy Rule implementation activities that will likely involve costs. Use this table to estimate and keep track of your organization's Privacy Rule implementation costs. The estimated costs will vary greatly among organizations, depending on the type of CE, the size, the amount of computer systems used, the number of business associates involved, and other aspects unique to each organization.

E) (2) Implementation specifications: Business associate contracts. A contract between the covered entity and a business associate must: ii. Provide that the business associate will: A. Not use or further disclose the information other than as permitted or required by the contract or as required by law. B. Use appropriate safeguards to prevent use or disclosure of the information other than as provided for by its contract. C. Report to the covered entity any use or disclosure of the information not provided for by its contract of which it becomes aware.

Too often privacy is considered a purely legal issue, the responsibility for which is often handed to organizational legal counsel. Or, it is ignored altogether as a separate issue, and management assumes it will be addressed by all the various business units during the course of doing business. Security is too often viewed as a purely technical issue, and the responsibility for security is more often than not placed within the information technology or networking support area often buried beneath several layers of management.

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