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May 21, 2026

Workforce Policies, Acceptable Use & Sanctions

Workforce Policies, Acceptable Use & Sanctions

This module covers the company's acceptable use policy and the consequences of HIPAA violations.

Acceptable use policy

Company systems, credentials, and PHI access are granted for work purposes only.

Prohibited at all times:

  • Using PHI for personal purposes
  • Sharing access credentials with anyone (including colleagues)
  • Bypassing security controls (e.g., disabling encryption, logging in as another user)
  • Storing PHI on personal cloud services (Google Drive, Dropbox, iCloud) without approval
  • Using public AI/LLM APIs (ChatGPT, Claude.ai, Gemini) for tasks involving PHI
  • Accessing PHI outside your job scope (curiosity is not a HIPAA-permitted purpose)

HIPAA violation severity and sanctions

Level 1 — Inadvertent, corrected immediately (documented warning):

  • Single wrong-email disclosure, immediately recalled
  • Brief unattended screen in a low-risk area

Level 2 — Negligent or repeated (formal corrective action plan):

  • Repeated accidental disclosures
  • Accessing PHI beyond minimum necessary
  • Failure to report a known incident within 24 hours

Level 3 — Willful or malicious (immediate termination + regulatory referral):

  • Intentional unauthorized access to PHI
  • Knowingly failing to report a breach
  • Selling, copying, or disclosing PHI for personal gain
  • Sharing credentials that led to unauthorized access

Termination and offboarding

When your engagement ends (employment, contract, or project):

  • Return all company-owned devices within 24 hours
  • Confirm in writing that PHI has been deleted from personal devices
  • Your access credentials will be revoked by IT within 4 business hours of your last day
  • HIPAA confidentiality obligations survive termination indefinitely

Reporting violations

If you observe a potential violation — by yourself or a colleague — report confidentially to:

Retaliation against good-faith reporters is strictly prohibited and is itself a Level 3 violation.

Attestation

Completing this module confirms you understand acceptable use requirements and sanction consequences.


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