This is the wiki for the development of the Privacy Set of Rules (SOR) that will be the basis for the Implementing Rules and Regulations (IRR) of the Privacy Guidelines AO. Healthcare facilities will also evolve their own Privacy Protocols (PP) based on this SOR.

The initial rules were consolidated outputs from privacy workshops in Bacolod, Davao, Palawan, Metro Manila (including subsequent discussions via the PEG Mailing List).

Stakeholders may help revise this document.

For questions and concerns that cut across sections, please use the Discussion area below to raise them.

See Introduction

See Consent Rules

See Point of Collection

See Identification of Patient

See Data to be Collected

See Information to be Shared

See Filing / Storage

See Access of Health Information

See Use and Disclosure of Health Information

See Administrative Security

See Physical Security

See Technical Safeguards

This subsection is deemed necessary for purposes of emphasis. See Use of Social Media

This section has been identified as one of the gaps left unaddressed in one place in any of the workshops. See Compliance, Incident Reporting and Response

• All candidates for employment, contractors and third party users shall be adequately screened,especially for sensitive jobs.
  
• Employees, contractors and third party users of information processing facilities shall sign an agreement on security roles and responsibilities.
  
• Security roles and responsibilities of employees, contractors and third party users should be defined and documented in accordance with the organization's information security policy.
  
• Security roles and responsibilities should include the requirement to:
  

(a) implement and act in accordance with the organization's information security policies;
(b) protect assets from unauthorized access, disclosure, modification, destruction or interference;
© execute particular security processes of activities;
(d) ensure responsibility is assigned to the individual for actions taken; (e) report security events or potential events or other security risks to the organization;

• Security roles and responsibilities shall be defined and clearly communicated to job candidates during the pre-employment process.
  
• Job descriptions can be used to document security roles and responsibilities. Security roles and responsibilities for individuals not engaged via the organization's employment process, e.g. engaged via a third party organization, should also be clearly defined and communicated.
  
• Background verification checks on all candidates for employment, contractors, and third party users shall be carried out in accordance with relevant laws, regulations and ethics, and proportional to the business requirements, the classification of the information to be accessed, and the perceived risks.
  
• Procedures should define criteria and limitations for verification checks (who is eligible to screen people, and how, when and why verification checks are carried out).
  
• A screening process should also be carried out for contractors, and third party users. Where contractors are provided through an agency, the contract with the agency should clearly specify the agency's responsibilities for screening and the notification procedures they need to follow if screening has not been completed or if the results give cause for doubt or concern. In the same way, the agreement with the third party should clearly specify all responsibilities and notification procedures for screening.
  

• See this discussion

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This section has been identified in the discussions as a gap that deserves separate treatment. See Privacy Team

New section; not originally from the workshops.

• See Health Data Privacy Board

See General Guidelines and Penalty Clause
This subsection will be archived soon. The provisions here will the incorporated into other “live” subsections.

• Consolidated Output from Bacolod Workshop
• Consolidated Output from Davao Workshop
• Consolidated Output from Palawan Workshop
• Consolidated Output from Angeles Workshop

• Privacy Guidelines
• Privacy Act of 2012
• Privacy Workshops
• PEG To Dos and Suggestions