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Title: Termination Procedures Policy: SEC 03.03
Category: HIPAA Compliance Authority: 45 CFR §
HIPAA Section: 164.308 (3) (ii) (C)
Standard: Workforce Security Standard Responsibility: Health Care Components
Effective Date: 04/20/2005 Page 1 of 1
Approved by: OSU Legal Counsel Revised:

Purpose
To ensure that all PHI is protected as required by HIPAA Privacy and Security rules
Policy

All employees who separate from OSU are required turn in all tools of access to buildings and other areas during the exit interview or as otherwise arranged. All access to electronic devices and computer media will be disabled immediately.

CHS Procedure 
  1. Supervisors will notify the Office of Human Resources regarding employee separation within 24 hours for voluntary separation. Notification will be immediately when separation is involuntary. The supervisor will follow the Employee Separation Procedure as dictated by the Office of Human Resources.


  2. Supervisors will notify the Compliance Office and OSU Security upon notice that an employee will be separating from the institution.
Reference
  • Human Resources Employee Separation Procedures
  • Employee Termination Checklist
UHS Procedure

Upon employment termination or resignation the following procedures will be reviewed and documented using the Employee Termination Security Check List.

Safe Combination Change: The following employees have access to the Business Office safe:
  • Business Manager
  • Sr. Administrative Associate
  • Financial Control Assistant
  • Sr. Account Clerk (1)

Upon employment termination or resignation by an employees listed above, the Business Office Safe combination will be changed. This request will be made by the Security Officer or their designee on the next business day and performed by the OSU Physical Plant. The new combination will be shared with employees that need access. This information will be documented on the Employee Termination Security Check List.

Access or Login Termination: Will be performed by the security officer on the next business day following the last day of employment for an employee who has been terminated or resigned.

Process

Staff identified on the Access to Information Flow Sheet to have access to PHI systems will have both Operating systems (identified as AIX) and Medical Manager logins locked/removed by the security officer using maintenance menus and instructions on the systems. In the absence of the Security Officer, the operating system login may be disabled by contacting the medical manager system administrator in OSU Information Technology. This information will be documented on the Employee Termination Security Check List.

Facility Access: Employees with exterior and/or interior facility keys will be required to return any keys to UHS Security Officer or Sr. Administrative Associate who maintains a facility key log. This information will be documented on the Employee Termination Security Check List.

The following documentation entitled “Employee Termination Security Check List” will be performed by the security officer or their designee and placed in the employee’s personnel record for storage. Employee’s personnel records are retained per Oklahoma State University Policies and Procedures 3.0190 and maintained indefinitely.

Revised
Revised April 6, 2005.
Summary of Revisions. Changed names of IT employees and the term CIS to IT or OSU Information Technology.

 

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