PURPOSE
Pacific University has adopted this Workforce Security Policy to ensure the confidentiality, integrity, and availability of all Protected Data we create, receive, maintain, or transmit as required by federal or state regulatory requirements, including but not limited to FERPA, GLBA, HIPAA, PCI, and other regional or local applicable laws and regulations.
University colleges, schools, and departments should follow these procedures to comply with the Workforce Security Policy, Policy Number POL-UIS4516.
PROCEDURE
Pacific University workforce members shall be screened as appropriate, prior to entering the workforce or when duties change in such a way that access to Protected Data becomes a requirement for the role. The procedure to confirm workforce member compliance will vary by workforce types listed below.
Employees
The Human Resources department will complete background checks for all newly hired employees as outlined in its background clearance policy and procedures document.
Contract workers
If working with PHI, the contracting department program dean/director or designee will evaluate and clear independent contractors holding a current Tax-ID # by confirming they are not on the exclusion list and, if applicable, checking licensure eligibility for enrollment in federal healthcare programs. This is generally done as part of the contract negotiation.
The contracting department dean/director or designee will evaluate and clear independent contractors by confirming applicable requirements, certifications or credentials are met to use non-clinic administrative systems. This should be completed as part of the contract negotiation.
Students
Academic programs with a clinical component are responsible for conducting a background check for student workforce members during the admissions process. The verification sheet will be kept in the student’s file. The HIPAA Privacy or Security officer may request a list of students who have completed a background check at any time.