Email and HIPAA
For those looking into email issues specifically, please see HealthyEmail, www.healthyemail.org . It's a nonprofit, I'm on the board, and the point of the exercise is to get policy and procedural tools out to support the clinical (principally physician practice) use of email. The other advisors are heavy hitters in this area (Bill Braithwaite, Danny Sands who was principal author of the AMIA email guidelines, Paul Tang, etc.), and we have posted a non-proprietary primer addressing HIPAA and other risks (I am generally more concerned about those other risks, by the way), patient communications documents, etc. Disclosure: It's a nonprofit principally supported by a secure messaging vendor which is a client of mine. Well, does anybody know of a health system, governmental agency or academic body who's going to pay for any major new initiative these days? And this way I know who they're listening to for advice. You can judge the merits of their solution for yourself, if you like, or ping me off list for info. The HealthyEmail documentation itself is not tied to the vendor, and is designed to support any clinical use of email. Interested party or not, my take is that if there is reasonably affordable/reasonably easy to use encryption available, the addressable specification security rule analysis indicates it should be used if you send ePHI over the Internet with any frequency. John R. Christiansen Preston | Gates | Ellis LLP 925 Fourth Avenue, Suite 2900 Seattle, Washington 98104 *Direct: 206.370.8118 *Cell: 206.683.9125 * [EMAIL PROTECTED] Notice: Internet e-mail is inherently insecure. Unencrypted e-mail may be accessible to unauthorized viewers, content may be modified or corrupted, and headers or signatures may incorrectly identify the sender. If you wish to confirm this message or the identity of the sender, please contact me using a communications channel other than a reply to this e-mail. Secure electronic messaging is available and recommended for confidential or sensitive communications. -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] Sent: Monday, March 24, 2003 4:43 PM To: WEDI SNIP Privacy Workgroup List Subject: RE: New to this list, have two questions. We have been wrestling with this question of e-mail security here too. I am with a large integrated delivery system in New Mexico. Our position, however, is that we will not stop the e-mail until we can agree on a workable technical security approach. We will continue as we have been, while we simultaneously working on a technical security approach (I won't say solution, because there does not appear to be a great solution at this time.) We believe it is too risky from a patient care standpoint to completely stop all e-mail, for a couple of reasons: 1) Most of our clinical units use e-mail to communicate with other providers and with patients themselves regarding treatment and care management 2) There have not been any reported problems with security related to this so far (I understand that this doesn't mean there is no risk). Therefore in comparing the benefits and risks to the patient, we felt it was better to continue using e-mail for now. 3) We feel that the advantages of e-mail outweigh the security risks; specifically we see those advantages as: * speed, * written documentation of the communication, and * the fact that both parties don't have to be in communication at the same time (like the phone would require) 4) The best alternative to e-mail would be fax - but that really is not much safer than e-mail from a technical standpoint, and in many cases travels over the same lines. We don't feel like we are buying much in terms of additional security by forcing everyone to use fax. Also, many patients do not have home fax machines. We are currently working on developing a secure server approach. We feel that encryption is not realistic since the technology is not standard enough, nor easily usable by clinicians or patients. We see our biggest challenge with any technical approach, is not the technology, but getting our clinicians and administrative staff to adopt it. Most of our planning will be focused on piloting and adoption strategies for this type of technology, from a very practical standpoint. Is any body else seeing the adoption challenges of e-mail security technology? Julie Fulcher HIPAA Project Manager Presbyterian Healthcare Services Albuquerque, New Mexico 87125- (505) 923-6397 [EMAIL PROTECTED] -Original Message- From: Doug Webb [mailto:[EMAIL PROTECTED] Sent: Monday, March 24, 2003 1:45 PM To: WEDI SNIP Privacy Workgroup List Subject: Re: New to this list, have two questions. Gregory, Just to amplify on Judith's remarks, You are exposed to the risk NOW, not when the final Security Rule fully kicks in. You are accepting a huge risk anytime you expose PHI to the Internet. Remenber that any of the millions of computers on the
RE: NPP in Other Languages
Folks - The plain language requirement for the NPP incorporates regulatory requirements that include translation into other languages if they are a material element of the population you serve. I did the research well over a year ago so don't recall the citations, and don't have time to dig it up just now, but I believe it was available via an OCR webpage. There are criteria for determining what languages you need to include, and this would apply to any CE, not just an employer plan. John R. Christiansen Preston | Gates | Ellis LLP 925 Fourth Avenue, Suite 2900 Seattle, Washington 98104 *Direct: 206.370.8118 *Cell: 206.683.9125 * [EMAIL PROTECTED] Notice: Internet e-mail is inherently insecure. Unencrypted e-mail may be accessible to unauthorized viewers, content may be modified or corrupted, and headers or signatures may incorrectly identify the sender. If you wish to confirm this message or the identity of the sender, please contact me using a communications channel other than a reply to this e-mail. Secure electronic messaging is available and recommended for confidential or sensitive communications. -Original Message- From: David Ermer [mailto:[EMAIL PROTECTED] Sent: Tuesday, March 18, 2003 1:53 PM To: WEDI SNIP Privacy Workgroup List Subject: Re: NPP in Other Languages It strikes me as an attorney who represents ERISA governed health plans that the NPP can be considered a material modification to the health plan under the U.S. Labor Department's (DOL) rules. DOL, in contrast to HHS, has very specific rules on distributing a summary plan description or a summary of material modifications to a plan participant, i.e., hand delivery, first class mail (second or third class only if return and forwarding postage is guaranteed and address correction is requested), or electronic delivery under certain circumstances and on when you need to translate such plan documents into another language. If your covered entity is governed by ERISA, I suggest that you apply these rules. If you covered entity is not governed by ERISA, you still may find the guidance helpful. I have quoted the foreign language and mailing guidance below. Best regards, Dave Ermer 29 C.F.R. §2520.102-2 Style and Format of SPD: (c) Foreign languages. In the case of either-- (1) A plan that covers fewer than 100 participants at the beginning of a plan year, and in which 25 percent or more of all plan participants are literate only in the same non-English language, or (2) A plan which covers 100 or more participants at the beginning of the plan year, and in which the lesser of (i) 500 or more participants, or (ii) 10% or more of all plan participants are literate only in the same non-English language, so that a summary plan description in English would fail to inform these participants adequately of their rights and obligations under the plan, the plan administrator for such plan shall provide these participants with an English-language summary plan description which prominently displays a notice, in the non-English language common to these participants, offering them assistance. The assistance provided need not involve written materials, but shall be given in the non-English language common to these participants and shall be calculated to provide them with a reasonable opportunity to become informed as to their rights and obligations under the plan. The notice offering assistance contained in the summary plan description shall clearly set forth in the non-English language common to such participants offering them assistance. The assistance provided need not involve written materials, but shall be given in the non-English language common to these participants and shall be calculated to provide them with a reasonable opportunity to become informed as to their rights and obligations under the plan. The notice offering assistance contained in the summary plan description shall clearly set forth in the non- English language common to such participants the procedures they must follow in order to obtain such assistance. Example. Employer A maintains a pension plan which covers 1000 participants. At the beginning of a plan year five hundred of Employer A's covered employees are literate only in Spanish, 101 are literate only in Vietnamese, and the remaining 399 are literate in English. Each of the 1000 employees receives a summary plan description in English, containing an assistance notice in both Spanish and Vietnamese stating the following: ``This booklet contains a summary in English of your plan rights and benefits under Employer A Pension Plan. If you have difficulty understanding any part of this booklet, contact Mr. John Doe, the plan administrator, at his office in Room 123, 456 Main St., Anywhere City, State 20001. Office hours are from 8:30 A.M. to 5:00 P.M. Monday through Friday. You may also call the plan administrator's office at (202) 555- 2345 for assistance.'' 29 C.F.R
RE: Security Requirements
Not that knowing that is much help in figuring out what you need to do . . . John R. Christiansen Preston | Gates | Ellis LLP 925 Fourth Avenue, Suite 2900 Seattle, Washington 98104 (Direct: 206.370.8118 (Cell: 206.683.9125 * [EMAIL PROTECTED] Notice: Internet e-mail is inherently insecure. Unencrypted e-mail may be accessible to unauthorized viewers, content may be modified or corrupted, and headers or signatures may incorrectly identify the sender. If you wish to confirm this message or the identity of the sender, please contact me using a communications channel other than a "reply" to this e-mail. Secure electronic messaging is available and recommended for confidential or sensitive communications. -Original Message-From: KERBER, JEFF [mailto:[EMAIL PROTECTED]Sent: Thursday, March 13, 2003 10:32 AMTo: WEDI SNIP Privacy Workgroup ListSubject: RE: Security Requirements Yes, that's exactly how to read that. -Original Message-From: Daryn Thompson [mailto:[EMAIL PROTECTED]Sent: Thursday, March 13, 2003 12:18 PMTo: WEDI SNIP Privacy Workgroup ListSubject: Security Requirements In the final security document, you have standards. Some standards have implementation specifications and others do not. On the standards that do have them, they are REQUIRED or ADDRESSABLE. On the ones that do not have specifications, are they Required? Daryn Thompson Network/I.S. Coordinator (801) 468-2123 ---The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time.You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED]To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED]If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org ---The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time.You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED]To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED]If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org "This electronic message may contain information that is confidential and/or legally privileged. It is intended only for the use of the individual(s) and entity named as recipients in the message. If you are not an intended recipient of the message, please notify the sender immediately and delete the material from any computer. Do not deliver, distribute, or copy this message, and do not disclose its contents or take action in reliance on the information it contains. Thank you." --- The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at
RE: Any HIPAA Humor tools out there?
Who's doing this? Can you guess what law schools are promoting coursesin successful litigation under HIPAA regulations? Wehave at least one here in Florida I am aware of. Please let me know, I'd love to see the curriculum andfigure out the holes in it, perhaps work up articles to help judges reject HIPAA claims. Something like this would becounter-productive andwould require creative lawyering to develop strong private claims (or is the training is for prosecutors or OCR investigators?) By the way,this is one attorney who co-presented abouttwo dozen half-day statemedical association sponsored trainings for docs, including a thick compliance manual, for compensation that basically covered expenses, i.e.pro bono. And no, I don't get a lot of work from docs - a little from time to time, not much, doctors don't trust lawyers and don't want to spend money on them (and get mad at us when they messup legal matters trying to do it themselves and it costs them more to fix the problems they caused!) - not my client base, but a profession I respect and felt needed the help since nobody else was stepping up to the plate. Just a thoughtto keep lawyer slamming in perspective. John R. Christiansen Preston | Gates | Ellis LLP PLEASE NOTE OUR NEW ADDRESS AND PHONE NUMBERS EFFECTIVE TUESDAY, JANUARY 21: 925 Fourth Avenue, Suite 2900 Seattle, Washington 98104 (Direct: 206.370.8118 (Cell: 206.683.9125 * [EMAIL PROTECTED] Notice: Internet e-mail is inherently insecure. Unencrypted e-mail may be accessible to unauthorized viewers, content may be modified or corrupted, and headers or signatures may incorrectly identify the sender. If you wish to confirm this message or the identity of the sender, please contact me using a communications channel other than a "reply" to this e-mail. Secure electronic messaging is available and recommended for confidential or sensitive communications. --- The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-privacy as: archive@mail-archive.com To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
RE: Here is a good Privacy Issue that will cause problems
tity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you have received this communication in error, please do not distribute it. Please notify the sender by E-Mail at the address shown and delete the original message. Thank you. AVISO DEL CONFIDENCIALIDAD: Este email es solamente para el uso del individuo o la entidad a la cual se dirige y puede contener información privilegiada, confidencial y exenta de acceso bajo la ley aplicable. Si usted ha recibido esta comunicación por error, por favor no lo distribuya. Favor notificar al remitente del E-Mail a la dirección mostrada y elimine el mensaje original. Gracias. -Original Message-From: Christiansen, John (SEA) [mailto:[EMAIL PROTECTED]] Sent: Thursday, January 16, 2003 7:09 PMTo: WEDI SNIP Privacy Workgroup ListSubject: RE: Here is a good Privacy Issue that will cause problems Hate to say it, but I disagree: Under HIPAA a pharmacist's job is to establish and comply with certain policies for privacy, security and electronic claims processing. It is a pharmacist's *professional* obligation to avoid (or mitigate) harm to individuals, and HIPAA is not intended to *interfere* with this. But HIPAA says nothing about mitigation of harm or professional standards. -Original Message-From: Matthew Rosenblum [mailto:[EMAIL PROTECTED]]Sent: Thursday, January 16, 2003 3:57 PMTo: WEDI SNIP Privacy Workgroup ListSubject: RE: Here is a good Privacy Issue that will cause problems Tim, I must respectfully disagree with your fundamental analysis of this scenario. Pharmacists (chemists) have, for more than 2000 years, been part of a triad (including physicians and nurses) engaged in an on-going clinical (NOT business) practice of ensuring that the correct medications and drugs are received by the correct patients. Whenever we remove one of those clinical disciplines from the decision-making process, medication errors and mistakes are likely to increase. It is NOT the intention of HIPAA to deter a good clinical practice. Unfortunately, when unscrupulous people get hold of blank-prescriptions, innocent people may get hurt. Under HIPAA, our responsibility then becomes mitigation of the harm. I hope that this helps. Your questions are always welcome. Matt Matthew Rosenblum Chief Operations Officer Privacy, Quality Management Regulatory Affairs http://www.CPIdirections.com CPI Directions, Inc. 10 West 15th Street, Suite 1922 New York, NY 10011 (212) 675-6367 [EMAIL PROTECTED] CONFIDENTIALITY NOTICE: This E-Mail is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you have received this communication in error, please do not distribute it. Please notify the sender by E-Mail at the address shown and delete the original message. Thank you. AVISO DEL CONFIDENCIALIDAD: Este email es solamente para el uso del individuo o la entidad a la cual se dirige y puede contener información privilegiada, confidencial y exenta de acceso bajo la ley aplicable. Si usted ha recibido esta comunicación por error, por favor no lo distribuya. Favor notificar al remitente del E-Mail a la dirección mostrada y elimine el mensaje original. Gracias. -Original Message-From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]] Sent: Thursday, January 16, 2003 6:00 PMTo: WEDI SNIP Privacy Workgroup ListSubject: RE: Here is a good Privacy Issue that will cause problems In my personal opinion, this practice - violating patient privacy, in the name of detecting abuse by private businesses - which is (it appears to me) unsupported by statute (unless mandated by DEA regulation) - is contrary to both many state laws and HIPAA. I agree the practice serves a valuable community need, as well as the needs of the abusing patient (intervention). However, as it (as I see it) is NOT a law enforcement reporting issue, but rather a "home grown" solution, that business simply do out of common sense, the practice will either have to be suspended, with suspects reported to law enforcement - cutting out the Sherlock Holms detectionengaged in by pharmacistsin the process - or get a state statute passed to support and require the activity. After all, it appears to me that what is really occurring here is abuse of privacy, and potentially serious defamation, and that a case mi
RE: Here is a good Privacy Issue that will cause problems
Hate to say it, but I disagree: Under HIPAA a pharmacist's job is to establish and comply with certain policies for privacy, security and electronic claims processing. It is a pharmacist's *professional* obligation to avoid (or mitigate) harm to individuals, and HIPAA is not intended to *interfere* with this. But HIPAA says nothing about mitigation of harm or professional standards. -Original Message-From: Matthew Rosenblum [mailto:[EMAIL PROTECTED]]Sent: Thursday, January 16, 2003 3:57 PMTo: WEDI SNIP Privacy Workgroup ListSubject: RE: Here is a good Privacy Issue that will cause problems Tim, I must respectfully disagree with your fundamental analysis of this scenario. Pharmacists (chemists) have, for more than 2000 years, been part of a triad (including physicians and nurses) engaged in an on-going clinical (NOT business) practice of ensuring that the correct medications and drugs are received by the correct patients. Whenever we remove one of those clinical disciplines from the decision-making process, medication errors and mistakes are likely to increase. It is NOT the intention of HIPAA to deter a good clinical practice. Unfortunately, when unscrupulous people get hold of blank-prescriptions, innocent people may get hurt. Under HIPAA, our responsibility then becomes mitigation of the harm. I hope that this helps. Your questions are always welcome. Matt Matthew Rosenblum Chief Operations Officer Privacy, Quality Management Regulatory Affairs http://www.CPIdirections.com CPI Directions, Inc. 10 West 15th Street, Suite 1922 New York, NY 10011 (212) 675-6367 [EMAIL PROTECTED] CONFIDENTIALITY NOTICE: This E-Mail is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you have received this communication in error, please do not distribute it. Please notify the sender by E-Mail at the address shown and delete the original message. Thank you. AVISO DEL CONFIDENCIALIDAD: Este email es solamente para el uso del individuo o la entidad a la cual se dirige y puede contener información privilegiada, confidencial y exenta de acceso bajo la ley aplicable. Si usted ha recibido esta comunicación por error, por favor no lo distribuya. Favor notificar al remitente del E-Mail a la dirección mostrada y elimine el mensaje original. Gracias. -Original Message-From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]] Sent: Thursday, January 16, 2003 6:00 PMTo: WEDI SNIP Privacy Workgroup ListSubject: RE: Here is a good Privacy Issue that will cause problems In my personal opinion, this practice - violating patient privacy, in the name of detecting abuse by private businesses - which is (it appears to me) unsupported by statute (unless mandated by DEA regulation) - is contrary to both many state laws and HIPAA. I agree the practice serves a valuable community need, as well as the needs of the abusing patient (intervention). However, as it (as I see it) is NOT a law enforcement reporting issue, but rather a "home grown" solution, that business simply do out of common sense, the practice will either have to be suspended, with suspects reported to law enforcement - cutting out the Sherlock Holms detectionengaged in by pharmacistsin the process - or get a state statute passed to support and require the activity. After all, it appears to me that what is really occurring here is abuse of privacy, and potentially serious defamation, and that a case might be made for damages if a person is placed on these distribution lists wrongly. However, as I am not an attorney I can not pass on a formal opinion. Just keep in mind that a person DOES NOT LOOSE ANY RIGHTS just because a pharmacist suspects abuse!!! It is up to statutory law enforcement of investigate, and a court to determine if a crime has been committed, NOT A CE, regardless of their practices. I am frankly amazed that we have not heard more litigation on this issue. Regards, Tim McGuinness, Ph.D.Consulting Specialist in Regulatory Privacy, Security, and Application Compliance---The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a
RE: general question- help to get started!
I can send you a copy of a presentation I did on employer compliance obligations as plan sponsors, etc., if you like but we should do so off-list. Let me know. From: John R. Christiansen Preston | Gates | Ellis LLP 701 Fifth Avenue, Seattle, Washington 98104 *Direct: 206.613.7118 - *Cell: 206.799.9388 * [EMAIL PROTECTED] Reader Beware: Internet e-mail is inherently insecure. Unencrypted e-mail may be accessible to unauthorized viewers, e-mail content may have been modified or corrupted, and e-mail headers or signatures may incorrectly identify the sender. If you wish to confirm the contents of this message or identity of the sender, or wish to arrange for more secure communication please contact me using a communications channel other than a reply to this e-mail. Thank you. -Original Message- From: Susan Butters [mailto:sbutters;psd.k12.co.us] Sent: Friday, October 25, 2002 1:45 PM To: WEDI SNIP Privacy Workgroup List Subject: general question- help to get started! I hope that I have got the right group of people to ask- but here it goes! I apologize in advance if I don't. Any help would be appreicated. I am new to the HIPAA compliance project and am working with a school district that is self funded for health benefits and also has an internal EAP. Unique I think in the way that we are a plan sponsor and also a provider. Any insight or suggestions on the best resources to follow to get started and to follow? -- Susan Butters HIPAA Compliance Specialist Poudre School District, Ft. Collins, CO [EMAIL PROTECTED] 970-490-3545 --- The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org --- The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-privacy as: archive@jab.org To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
