Mobile Device Security and Storage Media Management
LifeOmic recognizes that media containing ePHI may be reused when appropriate steps are taken to ensure that all stored ePHI has been effectively rendered inaccessible. Destruction/disposal of ePHI shall be carried out in accordance with federal and state law. The schedule for destruction/disposal shall be suspended for ePHI involved in any open investigation, audit, or litigation.
LifeOmic utilizes virtual storage repositories such as AWS EBS volumes and S3 buckets to store production data. Volumes and repositories utilized by LifeOmic and LifeOmic Customers are encrypted. LifeOmic does not use, own, or manage any mobile devices, removable storage media, or backup tapes that have access to ePHI.
LifeOmic policy requires that:
(a) All media, including mobile and removable media, storing LifeOmic company data must be encrypted.
(b) Critical data as defined in LifeOmic data classification model data-management, including but not limited to ePHI, may not be stored on mobile devices or removable media such as USB flash drives.
(c) All destruction/disposal of ePHI media will be done in accordance with federal and state laws and regulations and pursuant to the LifeOmic’s written retention policy/schedule.
- Records that have satisfied the period of retention will be destroyed/disposed of in an appropriate manner.
- Records involved in any open investigation, audit or litigation should not be destroyed/disposed of.
(d) All ePHI must rendered inaccessible in a forensically sound manner prior to media reuse or disposal.
(e) Mobile devices, including laptops, smart phones and tables, used in support of critical business operations shall be fully managed and/or audited by LifeOmic IT and Security.
(f) In the event an employee or LifeOmic believes that Customer Data may have been moved/copied/transferred to a mobile device owned by the employee, the employee agrees to and understands that:
- The employee shall notify LifeOmic Security.
- The employee shall provide the device to LifeOmic Security to confirm if a data leak has taken place.
- If needed LifeOmic Security will securely remove such data.
- This may require the device be wiped and/or restored to factory defaults.
- If prohibited data is confirmed on the device, the employee agrees to delete any backup of that data including any encrypted and cloud hosted backups.
Controls and Procedures
Media Disposal Process
IT and Security is responsible to ensure media containing critical / sensitive data (such as ePHI) is disposed securely in the following manner:
The methods of destruction, disposal, and reuse are reassessed periodically, based on current technology, accepted practices, and availability of timely and cost-effective destruction, disposal, and reuse technologies and services. This may include
- Secure wipe;
- Physical destruction;
- Destruction of encryption keys (if the data on the media is encrypted using a strong algorithm such as AES-256).
If the records have been requested in the course of a judicial or administrative hearing, a qualified protective order will be obtained to ensure that the records are returned to the organization or properly destroyed/disposed of by the requesting party.
All LifeOmic Subcontractors provide that, upon termination of the contract, they will return or destroy/dispose of all patient health information. In cases where the return or destruction/disposal is not feasible, the contract limits the use and disclosure of the information to the purposes that prevent its return or destruction/disposal.
In the cases of a LifeOmic Customer terminating a contract with LifeOmic and no longer utilize LifeOmic Services, data will be returned or disposed per contract agreement or LifeOmic Platform use terms and conditions. In all cases it is solely the responsibility of the LifeOmic Customer to maintain the safeguards required of HIPAA once the data is transmitted out of LifeOmic environments.
Use of USB Flash Drive and External Storage Device
Per LifeOmic corporate policy, confidential and critical data may not be stored on external devices such as USB flash drives. This includes and is not limited to ePHI. For definition of confidential and critical data, see LifeOmic Data Classification and Handling Policy.
Usage of USB flash drives for temporary transfer of confidential and critical data may be allowed on a case by case basis, when the following process is followed:
- Data is only allowed on encrypted flash devices approved by LifeOmic Security and the IT Manager (currently IronKey).
- The process starts with the submission of a ticket in Jira. The ticket must be approved by IT and Security.
- Upon completion of data transfer all sensitive data on the device must be completely removed.
- The device is to be returned to the IT Manager to double check that the data has been removed.
- The IT Manager will check the drive back in.
Support and Management of BYOD Devices
LifeOmic provides company-issued laptops and workstations to all employees.
LifeOmic currently does not require or support employees bringing their own computing devices.
The end-user computing devices are self managed. Each LifeOmic employee is responsible to
configure their laptop/workstation to meeting the configuration and management requirements; and
ensure the latest security patches are installed or auto-update is enabled.
IT and Security provides automated scripts for end-user system configurations and/or technical assistance as needed. Such configurations are audited daily using Kandji centrally managed by the Security team.