Employee Manual 2023 - Flipbook - Page 70
APPENDIX D:
NOTICE OF PRIVACY PRACTICES
The following policy has been adopted by the City of Plymouth in compliance with the Health
Insurance Portability and Accountability Act of 1996 and the State of Michigan Social Security
Number Privacy Act of 2004.
The City of Plymouth is required by law to maintain the privacy of social security numbers and the
health information it collects through its employee health benefit plans. This health information is
also known as protected health information or “PHI”. To ensure the City’s compliance with privacy
laws, human resources is designated as the City’s Privacy Officer.
What is protected health information (PHI)?
Protected health information is current, past or future information about plan participants that is
created or received by the City through the City’s employee health benefit plans. It relates to
physical and mental conditions of health plan participants, as well as descriptions of the health care
given to a participant or payment for the health care given to a participant. Protected health
information includes names, addresses, telephone numbers, social security numbers, dates of
birth, and other information that may be used to identify an individual.
PHI does not generally include publicly available information, summarized reports containing
generalized information which could not be used to identify an individual, or information contained
as part of a participant’s employment file.
What is this Notice of Privacy Practices?
As part of the City’s commitment to maintaining the privacy of social security numbers and PHI, the
City is providing a copy of this Notice of Privacy Practices to all employees of the City of Plymouth.
This notice is intended to inform you and your dependents of the types of PHI we collect, how the
City utilizes social security numbers and PHI and when and to whom the City may disclose it.
The City is required by law to maintain the privacy of your social security number and PHI in
accordance with this Notice of Privacy Practices, as long as the Notice remains in effect. The City
may revise this notice or internal privacy practices as necessary. However, employees will be
notified prior to any significant revision to the Notice of Privacy Practices.
What types of PHI does the City collect?
The City collects PHI through the health benefit plans offered to employees and their dependents.
At times, the City may request PHI directly from the employee; however, the City may also collect
PHI from health care providers, health plan administrators, health insurers, and other agents or
affiliates of the City. If you receive health care benefits through the City’s health benefit plans,
including worker's compensation coverage, it is likely that the City will collect PHI which may
include name, address, telephone number, social security number, date of birth and general
information pertaining to health.
City of Plymouth Employee manual - Page 70 – March 2023