Release of information (ROI) is typically a function that is managed by the HIM department, but privacy and security officers often play a critical role in ensuring records remain secure during transmission.
Q: Is there a sample risk analysis about how an enterprise or clinic might evaluate and determine if data-at-rest protection through encryption is reasonable and appropriate as defined in the HIPAA Security Rule?
A business case for resourcing a compliance assurance program for privacy and security should be possible solely on the basis of the need to respond to complaints made directly to a covered entity (CE) (or business associate (BA) acting as an agent of a CE). However, despite stepped-up enforcement and periodic audits required by HITECH, industry experts still anticipate that a more proactive process for compliance may not be taken until an untoward event occurs. Consequently, other avenues for substantiating the importance of privacy and security measures are necessary and readily available. Information privacy and security officials may find it necessary to go beyond information about HIPAA Privacy and Security Rule enforcement in making the business case. Monitoring the general security industry and relating those risks to healthcare privacy and security are important when doing so. Consider the following:
The healthcare industry is continuously evolving, and health information technology (HIT) is changing with it. Organizations should take advantage of the technology available to improve healthcare operations but must be aware of the risks that HIT can present.
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Q: As part of the audit controls policy at my organization, we hired an external security vendor to collect and review logs from several critical servers. The vendor creates tickets for our IT staff when a potential incident is discovered during the daily log review. This supplements our own activity reviews of internally generated reports, and the vendor then uses them for its own review. Our internal staff never sees the reports the vendor uses for its review. Do the reports the vendor uses fall under the HIPAA requirement for retaining logs for six years? Should we compel the vendor to retain these reports?
