Data Security Policy

• Protect PHI and sensitive information from unauthorized access, use, or disclosure
• Ensure secure handling of healthcare data throughout its lifecycle
• Maintain compliance with HIPAA, HITECH, and contractual obligations
• Establish clear security responsibilities and controls
• Reduce the risk of data breaches, loss, or misuse

• All employees, contractors, and authorized personnel
• All systems, networks, applications, and infrastructure
• All data processed, stored, or transmitted during service delivery
• All physical and electronic environments used by the Company

Each category is protected according to its sensitivity and regulatory requirements.

• Protected Health Information (PHI): Individually identifiable health information received from Covered Entities and handled under a Business Associate Agreement.
• Confidential Client Data: Business, operational, and contractual information belonging to clients.
• Internal Business Information: Company operational, financial, and administrative data.

• Documented security and privacy policies
• Defined access authorization procedures
• Workforce background verification where applicable
• Mandatory HIPAA and data security training
• Confidentiality and non-disclosure agreements
• Defined roles and responsibilities for data protection
• Incident response and escalation procedures
• Periodic security risk assessments

• Role-based access control (RBAC)
• Minimum necessary access principle
• Unique user IDs and credentials
• Secure authentication mechanisms
• Immediate access modification or revocation upon role change or termination
• Restricted administrative and privileged access
• Only authorized personnel may access sensitive data required for their job function.

These safeguards help prevent unauthorized access and data compromise.

• Encryption of data in transit and at rest
• Secure system configurations and hardened environments
• Firewalls and intrusion prevention mechanisms
• System monitoring and activity logging
• Audit trails for access and system usage
• Regular patching and system updates
• Secure backup and disaster recovery processes

• Restricted access to office premises
• Controlled workstation access
• Secure server and network environments
• Visitor access controls where applicable
• Protection of physical records and devices

• PHI is transmitted only through authorized, secure channels
• Encrypted file transfer methods are used
• Unsecured communication platforms are prohibited for PHI
• Email usage is restricted and monitored where applicable
• Visitors and clients are advised not to transmit PHI through unsecured channels.

• Personal devices are not permitted for PHI handling unless explicitly authorized
• Workstations are secured with authentication controls
• Storage devices are restricted and monitored
• Device usage follows internal security policies

• System access and activity logs are maintained
• Regular internal security audits are performed
• Anomalies and unauthorized access attempts are investigated
• Audit results are used for corrective actions and improvements

• Immediate investigation and containment actions are initiated
• Affected systems and data are secured
• Clients are notified as required by contract and regulation
• Breach assessment and mitigation are conducted
• Corrective measures are implemented to prevent recurrence
• Breach notification obligations follow HIPAA and applicable laws.

• Data is retained only as long as necessary to fulfill contractual, legal, and regulatory obligations.
• Upon completion or termination of services, PHI is returned to the Covered Entity or securely destroyed.
• Secure deletion and disposal methods are applied.
• Retention and disposal follow the Business Associate Agreement and applicable law

• Vendors are assessed for appropriate security controls
• Access to sensitive data is restricted
• Contractual data protection obligations are enforced
• Compliance with HIPAA requirements is ensured where applicable

• Following security policies and procedures
• Protecting access credentials
• Reporting suspected security incidents
• Completing required training and awareness programs
• Failure to comply may result in disciplinary action.

This Data Security Policy is reviewed periodically and updated as necessary to reflect:

Changes in regulations

Evolving security risks

Operational or technology updates

Updated versions will be published with a revised effective date.