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• no later than April 14, 2005 • on an ongoing basis, at the time of an individual ' s enrollment in the Plan, and • within 60 clays after a material change to the notice The Plan will also provide notice of availability of the privacy notice at least once every three years . 5. Complaints Complaints shall be made to the Privacy Official, Ann Rankin, Human Resources Department, 1840 25d' Street, Vero Beach, Florida, 32960, Phone : 772 . 567 . 8000, Ext 1448 and Fax: 772 . 770-5004. The Privacy Official is responsible for creating a process for individualsto lodge complaints about the Plan's privacy procedures and for creating a system for handling such complaints. A copy of the complaint procedure shall be provided to any participant upon request. 6. Sanctions for Violations of Privacy Policy Sanctions for using or disclosing PHI in violation of this HIPAA Privacy Policy will -be unposed in accordance with the County' s Disciplinary Procedures as referenced in the Personnel Policy and Procedure Manual; up to and including termination. 7. Mitigation of Inadvertent Disclosures of Protected Health Information The County shall mitigate, to the extent possible, any harmful effects that become known to it of a use or disclosure of an individual's PHI in violation of the policies and procedures set forth in this Policy. As a result, if an employee becomes aware of a use or disclosure of protected health information, either by an employee of the County or an outside consultant/contractor, that is not in compliance with this Policy, immediately contact the Privacy Official so that the appropriate steps to mitigate the harm to the participant can be taken. 8. No Intimidating or Retaliatory Acts ; No Waiver of HIPAA Privacy No employee may intimidate, threaten, coerce, discriminate against, or take other retaliatory action against individuals for exercising their rights, filing a complaint, participating in an investigation, or opposing any improper practice under HIPAA. No individual shall be required to waive his or her privacy rights under HIPAA as a condition of treatment , payment, enrollment or eligibility. 9 . Plan Document The Plan document includes provisions describing the permitted and required uses and disclosures of PHI by the County for plan administrative purposes . Specifically, . the Plan document requires the County to : 6