Our organization has many subsidiaries. Are we required to designate a separate privacy officer for each subsidiary?
HIPAA Weekly Advisor, September 19, 2005
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Covered entities with multiple subsidiaries that meet the definition of covered entities are given the flexibility to decide whether they are each separate covered entities or are together a single covered entity. If only one covered entity is designated for the subsidiaries, only one privacy officer is needed. Further, the HHS commentary states that there is nothing to prohibit the privacy officer of one covered entity from serving as the privacy officer of another covered entity. For more information, see Section 164.530(a) Personnel Designations and Section 164.105 Organizational Requirements of the Bricker & Eckler Web site.
Editor's note: Attorneys from Bricker & Eckler, LLP, answered this question. This is not legal advice. Consult with your attorney for legal matters.
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