Privacy Ref Blog

Assess risk prior to collecting personal information

My saga of finding new doctors continued over the last few weeks. With each visit I continue to gain insight into privacy risks unknowingly being taken by small businesses. My experience tells me larger business make similar mistakes. This time the doctor collected unneeded personal information from many of his patients, but he did a risk assessment first.

One of my pet peeves is being asked to provide my social security number the first time I visit a doctor. When she sees this request, my wife gives me that “don’t go there” look, but it never helps. That I was carrying a Rebecca Herold book on HIPAA privacy and security to read at the time probably made matters worse.

After a few minutes of conversation, the doctor noticed the book prompting an interesting discussion on “all this HIPAA nonsense” (his words, not mine). I have to admit the doctor was well versed in the HIPAA Privacy Rule and had a well developed training program for his staff. I finally asked “but why do you need my social security number?”

Why risk collecting unneeded personal information?

“For payment” he responded. It turns out over 85% of his patients were on a government mediacl insurance plan (not unusual in southern Florida) which uses your social security number as your identification number. By asking for the number up front his practice immediately has most of what they need for billing. By asking for the number from everyone, his staff never forgets to collect it. If someone doesn’t want to supply it they are told to find another doctor.

This doctor understands the risk he is taking, both for data protection and lost business, by collecting unnecessary personal information. He assessed the risk against the benefits he perceived his practice was receiving and made an informed decision to accept that risk.

Unintentionally collecting unneeded personal information is easy to do

Other organizations I have met with have not been so thoughtful about the personal information they collect. Some have asked for a government ID when they do not need it just because they always have asked for it. Others have collected mobile phone numbers in case they decide to send out text messages in the future. In neither case was a risk-based decision made; one was “tradition-based” the other was “convenience-based”.

Prescribe a risk assessment before collecting personal information

Privacy professionals and business leaders must have their teams follow this doctor’s prescription; only collect the personal information you need or make an informed, risk-based decision to collect more personal information than necessary.

  • author's avatar

    By: Bob Siegel

    Bob Siegel, the founder and President of Privacy Ref, Inc., has extensive professional experience in the development and improvement of privacy policies and procedures, the definition of performance metrics to evaluate privacy maturity, and the evaluation of compliance. He utilizes a combination of alignment, adaptability, and accountability strategies to guide organizations in achieving their privacy goals.

    He is a Fellow of Information Privacy (FIP) and a Certified Information Privacy Professional, awarded from the International Association of Privacy Professionals, with concentrations in U.S. private-sector law (CIPP/US), US public sector law (CIPP/G), European law (CIPP/E), and Canadian law (CIPP/C). He is also a Certified Information Privacy Manager (CIPM) and Privacy Technologist (CIPT).

    Siegel is a member of the IAPP faculty, has served on the Certification Advisory Board for the CIPM program the Publications Advisory Board.

    Siegel also writes the blog “Operational Privacy” on CSOonline.com

  • author's avatar

  • author's avatar

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Privacy Ref provides consulting and assessment services to build and improve organizational privacy programs. For more information call Privacy Ref at (888) 470-1528 or email us at info@privacyref.com

Posted on October 3, 2013 by Bob Siegel
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