Data Sharing for Campus Health and Safety
Monkeypox Outbreak 2022[i]
As a university, Yale has an obligation to protect not only workforce health and safety but also to provide as safe an environment as possible for those living and studying on campus. Recent emergent diseases and public health emergencies have necessitated balancing employee and student health data privacy expectations and requirements with the need to share health information to mitigate the spread of contagious disease amongst the Yale community. This document intends to clarify data sharing practices at Yale in response to monkeypox which was declared a public health emergency on August 8, 2022[ii].
Employees are encouraged to report their status to Employee Health if they test positive for monkeypox or if they believe they have monkeypox but have yet to receive test results and were on campus during they time they were experiencing symptoms. Employee Health may be reached at email@example.com or 203-432-1811. Once reported to Yale, the information may be shared as necessary to protect the campus such as with Environmental Health and Safety to initiate cleaning protocols.
Please note that the HIPAA Privacy Rule prohibits your health care provider from directly notifying Yale of your diagnosis or suspected diagnosis. We are relying on our employees to respect their peers and the Yale community by notifying the university so that we can act quickly to minimize further spread of the disease.
Students who are identified as potentially infected with monkeypox via care provided at Yale Health Student Health will be offered the option to isolate at home or, if residing on campus, will be advised to move to university-provided isolation housing. As student health data is subject to the Family Educational Rights and Privacy Act (FERPA), Student Health may immediately share the information with appropriate university officials to protect campus health and safety. The university will notify Environmental Health and Safety to initiate cleaning protocols, the Campus Health and Safety Leader for that unit who may assist in managing the response, and the relevant Head of College and Residential College Dean. Due to the incubation and transmission pathways of monkeypox, students will be encouraged to notify their roommates, sexual partners, and other close contacts as soon they are aware that they may have monkeypox so that their close contact can act to protect their health and limit further spread of the disease. The Department of Health will also be notified to conduct contact tracing.
Students who are diagnosed and/or treated for monkeypox outside of Yale Health are asked to contact Student Health (203-432-0312) if they have been on campus during the time they were symptomatic so that the University can take appropriate steps to protect campus health and safety.
Other Members of the Yale Community:
Individuals affiliated with Yale who test positive or are believed to have monkeypox are asked to consider reporting their case to the Campus COVID Resource Line if they have been on campus during the time they were showing symptoms (203-432-6604) to allow us to take action to protect campus health and safety.
State Reporting Requirements and Yale Notification:
State law requires that clinicians and/or lab testing facilities report patients who test positive for monkeypox or who appear likely to have the disease to the Connecticut Department of Public Health (DPH). DPH will then contact the patient to identify individuals who may be at risk of developing monkeypox through contact with the patient in a process known as contact tracing. Where the patient is a Yale student, the DPH will notify Yale if and when the student is believed to have been on campus during the period for when they could have been contagious. Yale is notified so that we can take steps to reduce the spread of the disease such as decontaminate university spaces that may have been visited by the patient.
Confidentiality of Health Data Reported to Yale:
The university is committed to sharing identified monkeypox data only with those who have a legitimate need to know and to limiting the information shared to the minimum needed to protect campus health and safety. Those who may need to be aware include those responsible for cleaning exposed locations who may be provided with locations without naming the infected individual, health and safety leaders who manage our response to health emergencies, clinical staff who may assist in outreach to patients, campus isolation housing staff, and those responsible for oversight of campus health and safety. If you have questions on the privacy of monkeypox information, please contact the Privacy Office at firstname.lastname@example.org
[i] This document is directed toward the processes in place for the monkeypox public health emergency. For information related to Covid-19 data sharing see https://privacy.yale.edu/resources/covid-19