What is HIPAA?
HIPAA (Health Insurance Portability and Accountability Act) is United States legislation that provides data privacy and security provisions for safeguarding medical information. The law has emerged into greater prominence in recent years with the many health data breaches caused by cyberattacks and ransomware attacks on health insurers and providers.
What is Protected Health Information?
Protected health information (PHI) is any demographic information that can be used to identify a patient or client of a HIPAA-beholden entity. Common examples of PHI include names, addresses, phone numbers, Social Security numbers, medical records, financial information, and full facial photos to name a few.
PHI transmitted, stored, or accessed electronically also falls under HIPAA regulatory standards and is known as electronic protected health information
or ePHI. ePHI is regulated by the HIPAA Security Rule, which was an addendum to HIPAA regulation enacted to account for changes in medical technology.
Purpose
The purpose of this policy is to provide guidance for workstation security for Landmark Associates, Inc. (hereinafter, “Landmark”) workstations in order to ensure the security of information on the workstation and information the workstation may have access to. Additionally, the policy provides guidance to ensure the requirements of the HIPAA Security Rule “Workstation Security” Standard 164.310(c) are met.
Scope
This policy applies to all Landmark employees, contractors, workforce members, vendors and agents with a Landmark-owned or personal-workstation connected to the Landmark network.
Policy
Appropriate measures must be taken when using workstations to ensure the confidentiality, integrity and availability of sensitive information, including protected health information (PHI) and that access to sensitive information is restricted to authorized users.
4.1 Workforce members using workstations shall consider the sensitivity of the information, including protected health information (PHI) that may be accessed and minimize the possibility of unauthorized access.
4.2 Landmark will implement physical and technical safeguards for all workstations that access electronic protected health information to restrict access to authorized users.
4.3 Appropriate measures include:
- Restricting physical access to workstations to only authorized personnel.
- Securing workstations (screen lock or logout) prior to leaving area to prevent unauthorized access.
- Enabling a password-protected screen saver with a short timeout period to ensure that workstations that were left unsecured will be protected. The password must comply with Landmark Password Policy.
- Complying with all applicable password policies and procedures. See Landmark Password Policy.
- Ensuring workstations are used for authorized business purposes only.
- Never installing unauthorized software on workstations.
- Storing all sensitive information, including protected health information (PHI) on network servers
- Keeping food and drink away from workstations in order to avoid accidental spills.
- Securing laptops that contain sensitive information by using cable locks or locking laptops up in drawers or cabinets.
- Complying with the Portable Workstation Encryption Policy
- Complying with the Baseline Workstation Configuration Standard
- Installing privacy screen filters or using other physical barriers to alleviate exposing data.
- Ensuring workstations are left on but logged off in order to facilitate after-hours updates.
- Exit running applications and close open documents
- Ensuring that all workstations use a surge protector (not just a power strip) or a UPS (battery backup).
- If wireless network access is used, ensure access is secure by following the Wireless Communication policy
Policy Compliance
- Compliance Measurement
The Infosec team will verify compliance to this policy through various methods, including but not limited to, periodic walk-thrus, video monitoring, business tool reports, internal and external audits, and feedback to the policy owner.
Exceptions
Any exception to the policy must be approved by the Infosec team in advance.
Non-Compliance
An employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.