51.    Computer Information System Security / Protected Health Information

Computer equipment, including access to the Internet, is property of Touchstone services, Inc.  All data and other electronic messages within the system are the property of Touchstone Services, Inc.  Communication of trade secrets and/or proprietary confidential information via e-mail is prohibited.  Employees must treat this information, at all times, in a safe and secure manner and must not deviate from that obligation.

Employees should have no expectation of privacy in e-mail communications, whether to supervisors, co-workers, oe others.  Even if e-mail is delected from the screen, it is not deleted from the system, thus, e-mail is not private since the message can still be accessed.

The agency reserves the right to monitor any and all aspects of computer use and telecommunications to ensure compliance with this policy.  Computer and telecommunications resources belong to the agency and may be used in a manner consistent with service provision, research and administrative objectives of the agency.  Personal use of these resources should be limited to reasonable break times.  The term ‘reasonable’ refers both to time of day and length of time, keeping the provision of high quality services to program participants always in the forefront.  Touchstone Services, Inc. reserves the right to determine, at the agency’s sole discretion, what constitutes reasonable, permissible use.

The confidentiality and privilege sections of the Michigan Mental Health Code and Privacy Regulations related to HIPPA regarding consumer information apply to the transmission of information in internal and external e-mail resources.  Information should be made reasonably secure.  Identifying information should not be used on external e-mail.

E-mail messages are the equivalent of business memorandums and should therefore be used cautiously with words and messages prudently selected.  An employee should not commit to e-mail what s/he would not readily commit to a business memo.  Correspondence transmitted on the Internet is considered legal transmission of documents.  E-mails, for example, can be entered as evidence in a court of law.  Fraudulent, harassing, embarrassing, indecent, profane, obscene, intimidating or other  unlawful material may not be sent by e-mail or other form of electronic communication displayed or stored on agency computers.  Computer resources are not to be used in ways that violate legal, ethical or professional standards.  Misuse of e-mail may result in disciplinary action, including discharge from employment.  Some examples of behaviors that could result in disciplinary action are:

Ø  Illegally downloading electronic files, including those that might be copyrighted

Ø  Downloading transmission and/or possession of pornographic, profane or sexually explicit materials

Ø  Sending threatening messages/files

Ø  Sending racial, ethnic, religious, sexually harassing or offensive messages/files

Ø  Sending chain letters through e-mail

Ø  Attempting to access any computer system without proper authorization

Ø  Sending or posting proprietary or company confidential information

Ø  Using company time or resources for personal gain

Employees must receive permission from their supervisor before posting messages to electronic bulletin boards, list-servers or similar public posting forums on the Internet.  When posted, such messages must contain a disclaimer at the end of message stating, “The opinion expressed in this message are mine only and do not reflect the opinion or position of Touchstone Services, Inc.”

Internet activity may be monitored by Touchstone Services, Inc. and privileges may be changed/revoked at any time.

The Internet offers global access to information.  Not all sources on the Internet provide information that is accurate, complete or legal.  Touchstone Services, Inc. is unable to monitor or control the content of Internet information, which changes rapidly and predictably.  Agency users will need to evaluate for themselves the validity of information found.  The availability of this information via agency service does not constitute an endorsement of that information.  The Internet on Touchstone Services, Inc. workstations may contain information that is controversial, sexually explicit or offensive.  Employees use the Internet at their own risk.

Employees required to enter data / billing information are expected to limit their use of the system to only that which is required to enter proper billing and data information.

Each program required to enter data / billing information into the system will be issued a Unique User Identification password.  To protect the private healthcare information of members, employees will not share or post their login / password.

When an employee who is responsible for data / billing entry gives a two-week notice to leave employment, the Program Director will inform the Information Systems Department (IS) of the appropriate contracting agency of this impending departure.  This notification will be made no less than one week before the end of employment.  In cases of termination or immediate resignation of such staff, the Program Director will notify IS within four (4) hours.