The purpose of the Commitment to Security Statement is to provide RLDatix Safety Solutions clients and prospective clients with an objective description of the system’s boundaries and security commitments.
Commitment to Security
Health information is an important asset to our company and RLDatix, along with its employees, is committed to protecting the integrity, privacy and security of confidential health information as required by law, professional ethics, and accreditation requirements.
RLDatix acknowledges our duty and responsibility to protect the privacy and security of Individually Identifiable Health Information (“IIHI”) generally, and Protected Health Information (“PHI”) specifically, as defined in the HIPAA Privacy and Security Regulations, the HITECH Act and other applicable laws protecting the confidentiality of personal information, and under principles of general and professional ethics. We also acknowledge our duty and responsibility to support and facilitate the timely and unimpeded flow of health information for lawful and appropriate purposes.
RLDatix is a business associate as defined by HIPAA. As an organization, we are committed to maintaining compliance with the HIPAA Privacy and Security Rules. All RLDatix workforce members comply with the requirements of the HIPAA regulations with respect to privacy principles of minimum necessary use, security safeguards and controls, and accountability and oversight; and make reasonable efforts to limit use of and access to PHI within its systems.
RLDatix has implemented appropriate privacy and security policies and procedures to meet, and in many instances, exceed, the HIPAA privacy and security standards for five (5) key areas outlined below:
I. ADMINISTRATIVE SAFEGUARDS
RLDatix has implemented policies, practices and procedures to safeguard protected health information as defined in the HIPAA Regulations CFR 45 Section 164.308 including, but not limited to the following policies:
Security Management Process
- RLDatix has implemented policies and procedures including an annual Risk Analysis to identify potential risk and vulnerabilities to the confidentiality, integrity and availability of ePHI and remediate those risks as needed.
- RLDatix has a comprehensive Risk Management Policy including routine internal and external security audits, use of third-party security experts and annual review of all security policies and procedures.
Disciplinary & Grievance Policy
- RLDatix maintains a Disciplinary & Grievance Policy as part of our Integrated Management System Manual regarding workforce member conduct relative to a number of areas that impact PHI. The Disciplinary & Grievance Policy highlights the potential range of penalties when a workforce member violates any of the policies. Workforce members are trained annually including the Disciplinary & Grievance Policy.
Information System Activity Review
- RLDatix has implemented automated and continuous system monitoring that provides alerts and notification to services staff. This includes procedures to follow when a system alert occurs.
Assigned Security Responsibility
- RLDatix has identified a Chief Security Officer and Chief Privacy Officer. Additionally, RLDatix has a Privacy, Compliance and Security Committee responsible for the overall privacy and security at RLDatix.
Information and Access Management
- Access to all resources is controlled by Access Control Lists (ACL). The level of access is based on the workforce member’s job description within the organization.
Security Awareness and Training
- All RLDatix workforce members are required to have training covering information security including HIPAA and privacy upon hire and at least annually thereafter.
- RLDatix utilizes the current version of Endpoint Security and Anti-Virus software on production, development and test servers and on all user workstations. This includes real time scanning and nightly and weekly scans for all files and folders contained on each computer. Anti-malware databases are configured to be updated every hour for new signatures that are being made available from the software vendor.
- RLDatix password policy requires the use of complex passwords.
- RLDatix monitors all log-on attempts. Logs are reviewed monthly for unauthorized access.
Security Incident Protection and Response
- RLDatix maintains an Incident Reporting Mechanism in order to facilitate the reporting of potential security incidents and/or breaches. RLDatix takes all suspected incidents seriously and will investigate all suspected incidents as quickly as possible.
- RLDatix maintains and extensive Data Back-up Plan which creates and maintains retrievable copies of PHI within application level clustering and replication, disk and tape backups, snapshots on storage devices and storage device replication.
- RLDatix maintains a disaster recovery plan for recovery in the event of failure or disaster including all critical elements of the applications, snapshot technology in the event of major data corruption, backup databases for production data and an alternate site in the event the primary site goes down.
- RLDatix maintains a Disaster recovery (DR) site.
- RLDatix periodically tests contingency plans to verify procedural steps are valid and to provide updates to the procedures.
- All RLDatix applications, including its elements such as the network, servers, storage and databases are equipped and operated at high-availability.
II. PHYSICAL SAFEGUARDS
RLDatix hosts its Safety Solutions SaaS applications, including PHI data in dedicated spaces (or cages) in data centers in the US. These are co-location facilities or dedicated spaces in these Tier III/IV data centers.
All security policies are set by the hosting facility. RLDatix has reviewed these policies and verified acceptability. The data centers are SSAE-16 and SAS 70 certified. They maintain 24/7 manned security. All doors have alarm contacts, the building has ballistic entrances/bulletproof glass and no signage. Only authorized employees have badges that will get them in any door. The physical security requires both a proximity badge and a palm print biometric authentication be performed before anyone can gain access to the facility via man traps. The data centers have recording cameras spread throughout and outside the facility and several motion sensor lights.
Aside from the aforementioned facility security implementations, RLDatix also has procedures and practices related to the following:
Facility Access Controls
- RLDatix has policies that allow for appropriate access to its data centers in support of restoration of lost data or under the disaster recovery plan. Additionally, RLDatix has implemented a comprehensive Facility Security Plan for all of its locations, including data centers. This includes the physical security of the facilities and appropriate access to those facilities.
- RLDatix has implemented policies and procedures that govern the use and security of workforce member workstations, including laptops and portable devices. This includes the encryption of all workstations and laptops.
Device and Media Controls
- RLDatix has implemented policies and procedures that govern the movement of all devices and media. This includes disposal, re-use, data back-up, and data storage.
III. TECHNICAL SAFEGUARDS
RLDatix has implement policies and procedures in order to meet the all the required and addressable specifications as defined in the HIPAA Regulations CFR 45 Section 164.312 Security Standard Technical Safeguards. These policies and procedures include:
- Unique user IDs and secure passwords for access to systems
- Automatic Logoff procedures
- Emergency Access procedures
- Data that is moving is encrypted using Secure Socket Layer and Transport Layer Security (SSL/TLS). Data at rest is either encrypted or de-identified.
- All interactively and remote access to servers, network and storage equipment is logged on a Security Information and Event Management (SEIM) System. Database access and activities are also logged locally and centrally. All web accesses to the applications from users are logged in a platform and/or application specific database down to the activity level.
- Digital Signatures and Message Digest are employed to protect data from improper alteration or destruction during transit.
Person or Entity Authentication
- User authentication is handled within the application. It is equipped with configurable options to comply with commonly enforced password policies in the market.
- RLDatix Safety Solutions are equipped with transmission security and data integrity mechanisms to protect the exchanges of Protected Health Information according to the Encryption Policy including SSL/TLS or SSH encryption.
Monitoring and Alerting
- RLDatix uses several systems and tools that complement each other to provide the best protection and coverage for its hosted application environments. These include monitoring and alerting for the following:
- System and Services Health and Availability
- Resource Capacity and Utilization Monitors
- Application Performance Monitors
- Synthetic and Real User Monitors
IV. ORGANIZATIONAL REQUIREMENTS
RLDatix maintains Business Associate Agreements with all applicable customers and vendors. Business Associate Agreements are reviewed to ensure compliance with the latest requirements.
V. DOCUMENTATION REQUIREMENTS
RLDatix has a comprehensive Compliance Audit Plan which includes a review of the following policies:
- Annual HIPAA Risk Assessment
- Annual review of all Privacy and Security Policies
- Annual review of Vendor Management Program
- Annual review of Disaster Recovery Plan
- Annual HIPAA employee training
Vendor Management Program
RLDatix has an extensive Vendor Management Program in place to evaluate, select and monitor vendors in order to minimize the risks associated with vendors working with Sensitive Information. This program includes vendor screening, Business Associate Agreements, Service Level Agreements, and monitoring.
The Client System Boundary illustrates data flow to and from RLDatix Safety Solutions and where data resided within RLDatix’ enterprise.