It is now mandatory for healthcare organizations to specify and publish their privacy policies. This has made privacy management initiatives in the healthcare sector increasingly important. However, several recent reports in the public media and the research community about healthcare privacy [1,2] indicate that the use of privacy policies is not necessarily a strong indication of adequate privacy protection for the patient. These observations highlight the fact that the current state of privacy management in healthcare organizations needs improvement. In this paper, we present PRIMA, a PRIvacy Management Architecture, as a first step in addressing this concern. The fundamental idea behind PRIMA is to exploit policy refinement techniques to gradually and seamlessly embed privacy controls into the clinical workflow based on the actual practices of the organization in order to improve the coverage of the privacy policy. PRIMA effectively enables the transition from the current state of perceived to be privacy-preserving systems to actually privacy-preserving systems.