Data Confidentiality Policy for Contractors

Originally Issued:

July 2015

Contacts:

Download Policy Document (PDF)

Policy:

ContractorsAn individual or company that is under agreement (i.e., hired or engaged in any way) to provide services to UNLV or engages with UNLV in a vendor demonstration that includes access to university data as part of the demonstration. who receive or are provided access to university dataThe observations and information collected or accessed during the performance of services, including protected information and images with a reasonable expectation of privacy. will use the dataThe observations and information collected or accessed during the performance of services, including protected information and images with a reasonable expectation of privacy. solely for the purposes for which they have been contracted. ContractorsAn individual or company that is under agreement (i.e., hired or engaged in any way) to provide services to UNLV or engages with UNLV in a vendor demonstration that includes access to university data as part of the demonstration. who are exposed to protected informationInformation provided at the direction of UNLV or to which access was indirectly obtained in the course of contractor's performance of services, that: is an education record, protected health information, or personally identifiable information; identifies any individual (by name, signature, address, telephone number, email address, or other unique identifier); can be used to authenticate any individual (including, but not limited to, any employee identification number, Social Security number, driver's license number or other government-issued identification number, passwords or PINs, biometric or health data, answers to security questions, or other personal identifiers); or, includes credit card, debit card, or other financial information. UNLV business contact information is not, by itself, protected information. during the scope of services will use and disclose protected informationInformation provided at the direction of UNLV or to which access was indirectly obtained in the course of contractor's performance of services, that: is an education record, protected health information, or personally identifiable information; identifies any individual (by name, signature, address, telephone number, email address, or other unique identifier); can be used to authenticate any individual (including, but not limited to, any employee identification number, Social Security number, driver's license number or other government-issued identification number, passwords or PINs, biometric or health data, answers to security questions, or other personal identifiers); or, includes credit card, debit card, or other financial information. UNLV business contact information is not, by itself, protected information. solely and exclusively for the purposes for which such information, or access to it, is provided in order to perform services. ContractorsAn individual or company that is under agreement (i.e., hired or engaged in any way) to provide services to UNLV or engages with UNLV in a vendor demonstration that includes access to university data as part of the demonstration. are fully responsible and liable for all acts, omissions, and work performed by their representatives or subcontractors.

ContractorsAn individual or company that is under agreement (i.e., hired or engaged in any way) to provide services to UNLV or engages with UNLV in a vendor demonstration that includes access to university data as part of the demonstration. hired through the UNLV procurement process are bound by the terms and conditions associated with the protection of university dataThe observations and information collected or accessed during the performance of services, including protected information and images with a reasonable expectation of privacy. included in the executed contract.

ContractorsAn individual or company that is under agreement (i.e., hired or engaged in any way) to provide services to UNLV or engages with UNLV in a vendor demonstration that includes access to university data as part of the demonstration. hired to work specifically with Protected Health InformationHas the meaning set forth in the Health Insurance Portability and Accountability Act of 1996 and any subsequent amendments (HIPAA, codified at 42 U.S.C. 1320(d); Protected data definition at 45 C.F.R. § 160.103). must complete a HIPAA Business Associate Agreement. 

All other contractorsAn individual or company that is under agreement (i.e., hired or engaged in any way) to provide services to UNLV or engages with UNLV in a vendor demonstration that includes access to university data as part of the demonstration. must comply with all provisions of the Contractor Confidentiality Agreement. The agreement can be modified with approval of General Counsel. 

Employees are responsible for ensuring contractorsAn individual or company that is under agreement (i.e., hired or engaged in any way) to provide services to UNLV or engages with UNLV in a vendor demonstration that includes access to university data as part of the demonstration. who receive or are provided access to university dataThe observations and information collected or accessed during the performance of services, including protected information and images with a reasonable expectation of privacy. comply with their responsibilities as set forth in this policy.

Related Documents

UNLV HIPAA Units

  • Dental School and any associated clinics
  • Student Health Center and Pharmacy
  • Student Wellness
  • Athletic Training Department
  • Center for Individual and Family Counseling
  • Center for Health Information Analysis
  • National Supercomputing Center for Energy and the Environment

Statement of Purpose:

The purpose of this policy is to:

  • Ensure employees understand their responsibilities when they contract with individuals or companies who may have access to campus dataThe observations and information collected or accessed during the performance of services, including protected information and images with a reasonable expectation of privacy. during their engagement with the university.
  • Ensure contractorsAn individual or company that is under agreement (i.e., hired or engaged in any way) to provide services to UNLV or engages with UNLV in a vendor demonstration that includes access to university data as part of the demonstration. understand their responsibilities for the protection of dataThe observations and information collected or accessed during the performance of services, including protected information and images with a reasonable expectation of privacy. during the performance of their contracted services.
  • Ensure contractorsAn individual or company that is under agreement (i.e., hired or engaged in any way) to provide services to UNLV or engages with UNLV in a vendor demonstration that includes access to university data as part of the demonstration. who access dataThe observations and information collected or accessed during the performance of services, including protected information and images with a reasonable expectation of privacy., directly or indirectly, are in compliance with all applicable laws and regulations, as well as relevant UNLV policies and procedures.

Entities Affected By Policy:

Entities affected by this policy include parties that enter into contracts with UNLV and UNLV representative(s) responsible for those contracts.


Who Should Read This Policy:

UNLV employeesFor purposes of this policy, university employees are defined as all individuals with an employment contract with the university of 90 days or more. who develop, manage, oversee, and/or execute contracts should read this policy. Additionally, any individual or company contracted by UNLV should read this policy.