A suspected confidentiality violation may be reviewed by the appropriate combination of the PA Program Director, Director of Clinical Education, PA faculty, the Clinical Education Committee, the Student Evaluation and Progress Committee, NLU Student Affairs, NLU Information Technology/Security, NLU Privacy/Legal personnel, clinical- affiliate leade rship, and/or other appropriate University officials. Depending on the circumstances, corrective actions may include counseling, remediation, additional HIPAA/privacy training, restriction of clinical or EHR access, professionalism intervention, removal from a clinical activity, referral to the Student Evaluation and Progress Committee, academic consequences, disciplinary action under NLU policy, and/or clinical-site action. Nothing in this policy limits consequences required by law, University policy, or a clinical- affiliate agreement. 28. Education and Training Before students participate in activities involving patient information, the Program will provide instruction regarding HIPAA, patient confidentiality, privacy, FERPA, information security, appropriate EHR use, social media, photography, text messaging, email, electronic communications, clinical documentation, incident reporting, and clinical- affiliate confidentiality requirements. Training may occur through orientation, course instruction, clinical preparation, clinical-site orientation, annual training, online learning modules, and just-in-time education when required. Students may be required to complete clinical-site- specific HIPAA/privacy training before beginning an SCPE. 29. Student Acknowledgment Prior to participating in activities involving protected or confidential information, students must acknowledge that they understand and agree to comply with this policy, including that patient information is confidential; student educational records are protected; access to information is limited to authorized purposes; personal devices may not be used improperly to capture or transmit protected information; social media may not be used to disclose protected information; patient photographs and recordi ngs are prohibited unless specifically authorized; confidential information may not be disclosed through text, email, telephone, blogs, vlogs, podcasts, or other media; suspected breaches must be reported promptly; and confidentiality obligations continue after graduation or separation from NLU. 30. Continuous Quality Improvement The PA Program will review this policy annually, evaluating HIPAA/privacy training completion, reported confidentiality incidents, clinical -site and preceptor feedback, student evaluations, EHR-access concerns, social-media concerns, privacy complaints,
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