A doctor sends patient records to another company for data entry services. A bonded delivery service is used for the transfer. The records are returned to the doctor after entry is complete, using the same delivery service. The entry facility and the network they use are secure. The doctor is named as his own Privacy Officer in written policies. The doctor has written procedures for this process and all involved parties are documented as having been trained in them The doctor does not have written authorizations to disclose Protected Health Information (PHI). Is the doctor in violation of the Privacy Rule?