Notice of Privacy
Tufts Occupational Health Services (OHS) offers onsite medical services to faculty, staff, and graduate students. Tufts OHS complies with the confidentiality and privacy requirements associated with applicable laws such as the Americans with Disability Act (ADA), the Family Medical Leave Act (FMLA), the Genetic Information Nondiscrimination Act (GINA), and the Family Educational Rights and Privacy Act (FERPA).
- Occupational health records are kept in our occupational health records system and are maintained separately from other personnel, employment, and educational records. Only Tufts OHS staff can access your occupational health records.
- Tufts University and Tufts OHS will not use your health information in a form that identifies you for any purpose other than the one for which it was collected. We may use highly aggregated reports for administrative purposes such as budgeting or safety planning, but those reports will not reveal information about individual patients.
- Tufts OHS will not disclose your medical information or other information from your occupational health records without your consent unless:
- the disclosure is necessary to protect your health or safety or the health or safety of others;
- the disclosure is required by law;
- the disclosure is required by a court order, subpoena, or warrant;
- the disclosure relates to your ability to perform the essential functions of your job, with or without reasonable accommodation;
- the disclosure relates to your ability to access educational programs at Tufts, with or without reasonable accommodation;
- the information is regarding compliance with legal or contractual requirements. In circumstances related to compliance with legal or contractual requirements, your information may be released to your supervisor, compliance officials, or human resources. For example, clearance to work with animals, to wear a respirator, or comply with university policy;
- If your job is safety-sensitive, information about medical conditions that may impact your safety and the safety of those around you may be released to your to supervisor, including but not limited to a seizure disorder, unstable diabetes, or other medical condition;
- the disclosure is about a work-related injury or illness and required to process a worker's compensation claim or other insurance or legal claim;
- the disclosure is required to consult with safety professionals and the supervisor to determine the cause of the illness/injury; or
- the disclosure is required to coordinate with the Office of Equal Opportunity (OEO) and the supervisor if accommodations are requested; or
- the information is requested by the Occupational Safety and Health Administration (OSHA) as part of the investigation of a reported workplace incident or audit; or
- a union representative requests the information in response to a member’s complaint or grievance.
- Suppose we are specifically aware that the results of a visit or consultation with OHS will be disclosed to an external third party. In that case, we will tell you about the disclosure requirement before we begin collecting your information.
- If we are required to disclose information, we will attempt to notify you and obtain your consent as soon as possible. Nevertheless, we may not be permitted to notify you in some cases, or it may be impractical to contact you before we disclose the information.
- We limit the information we disclose to the minimum necessary for the purpose of the disclosure and only disclose the information to those who need to know it. Similarly, if you consent to or direct us to disclose information, we will disclose only information that is covered by the consent form.
Types of records we collect and store
We collect and store information directly from you, from examination, test, and imaging results, from sources such as other medical professionals, incident reports, and inferences that we form based on this information. For example
- Personal and occupational health history;
- Medical questionnaires;
- Immunization records, vaccinations, and titer results;
- Opinions/written evaluations generated in the course of examination, diagnosis, and treatment (employment-related);
- Work-related exposures;
- Occupational illness or accident/injury information; and
- Same-day illness evaluation and treatment.
Frequently Asked Questions
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For technical reasons, the OHS program is not subject to HIPAA requirements. However, we apply similar security and privacy protections.
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We cannot promise complete confidentiality, but we treat this information as sensitive and private. As described above, there are cases in which we may be required to disclose information. If we know we may be required to disclose information when collecting it, we will inform you in advance. We will always do our best to notify you and obtain your consent before disclosing information about you.
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No. OHS is a voluntary service offered by Tufts. You are not required to visit us or participate in an examination unless the examination is job-related and necessary for our business or part of a legally-required medical surveillance program. Tufts may require medical information or certifications in some cases, but you are not required to be examined or treated by OHS to get them.
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Occupational Health records are kept for 30 years after the end of your employment.
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To request a copy of your medical record, please contact Tufts OHS at occupationalhealth@tufts.edu, or call 617-627-6500. We will ask you to sign a release form and give you a hard copy of your record.
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You may request an electronic copy of your record by the same mechanism above.
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Please contact the Associate Director of Tufts Occupational Health Services, Susan Willson-Goucher NP, MS, COHN-S at: susan.willson-goucher@tufts.edu.
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If you have any concerns about your privacy, please feel free to contact the Associate Director of Tufts Occupational Health Services, Susan Willson-Goucher NP, MS, COHN-S at: susan.willson-goucher@tufts.edu or the University Privacy Officer at: privacy@tufts.edu. If you prefer to report your questions and concerns anonymously, you can do so by filing online through EthicsPoint at https://secure.ethicspoint.com/domain/media/en/gui/7182/index.html or by calling the EthicsPoint hotline at 1-866-384-4277. EthicsPoint is the University’s reporting system for activities that involve unethical or otherwise inappropriate behavior.
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