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1. Generally: Personally -Identifiable Information shall not be obtained, used or <br />disclosed except as permitted or required by law. <br />2. Permitted and Required Uses and Disclosures: Personally -Identifiable Information <br />may or shall be disclosed as follows: <br />a) To the individual <br />b) To carry out TPO activities as allowed under HIPAA and/or pursuant to and in <br />compliance with a current and valid Authorization [Receipt. Use and Disclosure <br />ofPersonally-Identifiable Information1. <br />c) In keeping with a Business Associate Agreement (Business Associate <br />Agreementl. <br />d) As otherwise allowed or required under the HIPAA Rules or other federal <br />and/or state laws concerning privacy of information that is used by Virtru in <br />the course of its business operations. <br />3. Minimum Necessary: Generally, when obtaining, using or disclosing <br />Personally -Identifiable Information, or when requesting PII from another entity, <br />reasonable efforts must be made to limit the PII used or disclosed to the minimum <br />necessary to accomplish the intended purpose. However, the Privacy rules were not <br />intended to severely complicate business processes and Virtru may, where <br />appropriate, use a single format to provide data containing PII for our various <br />services (Minimum NecessaovStandardl. <br />4. De -identified Personally -Identifiable Information: PII may be considered not to be <br />individually identifiable in the following circumstances: <br />a) The following identifiers of the individual (and relatives, employers or <br />household members) are removed. (This is the "Safe Harbor" method that <br />Virtru will generally use.) <br />- Names <br />- Information relating to the individual's geographic subdivision if it <br />contains fewer than 20,000 people <br />- Elements of dates (except year) directly related to the individual <br />- All ages and elements of dates that indicate age for individuals over 89, <br />unless aggregated into a single category of age 90 and older <br />- Telephone numbers <br />- Fax numbers <br />N. <br />Rev.2015.8.25 <br />