Page 20 - Part 2 Navigating Electronic Media in a Healthcare Setting
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SVMIC Navigating Electronic Media in a Healthcare Setting


                   appropriate safeguard for a covered entity, the covered entity must
                   implement a mechanism to encrypt and decrypt ePHI.


                   In addition to maintaining all patients’ records in a secure, properly
                   encrypted fashion on the recording device, all HIPAA-compliant

                   apps and devices must be able to transfer any patients’ records

                   they contain via a secure method such as Secure Sockets Layer
                   (“SSL” or “https://”). Standard email or even file transfer protocols

                   such as “FTP” are not generally secure and, therefore, any transfer

                   of patient information, records or media via these methods is not
                   HIPAA compliant and, thus, unacceptable. The app should be able

                   to upload records to the cloud or your EHR using secure,
                   encrypted channels.


                   Business continuity and disaster recovery are certainly important

                   in any operation but, surprisingly, are some of the more commonly
                   overlooked elements of HIPAA’s security requirements. Any device

                   or app should include an integrated failsafe backup to secure
                   offsite storage such as in the cloud. Not only does HIPAA require

                   this backup to be encrypted using AES-256, should a third party be
                   responsible for this backup, you must also have a formal Business

                   Associate Agreement with the vendor where the secure backups

                   are stored. This means solutions such as Dropbox or Google Docs
                   are unacceptable and do not meet HIPAA’s requirements, as these

                   vendors will not sign an independent BA agreement with a

                   practice for anything stored on their servers.

                   One of the most common ways confidential patient records can be

                   exposed is the possibility that your device is lost or stolen. When
                   looking at any patient record solution, it is critical that you are able

                   to change your device and app password remotely, should you no

                   longer have physical possession of the device. As with a credit




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