Skip to content

Latest commit

 

History

History
33 lines (22 loc) · 2.2 KB

data_management_policy.md

File metadata and controls

33 lines (22 loc) · 2.2 KB
Raw

Data Management Policy

All Pact data backups are made a platform maintained by Catalyze, a service provider that stores all of Pact's ePHI. Catalyze has signed a BAA with Pact committing to the policy below.

Catalyze Data Management Policy

Catalyze has procedures to create and maintain retrievable exact copies of electronic protected health information (ePHI) stored in conjunction with Catalyze Add-ons and for PaaS Customers utilizing our Backup Service. This policy, and associated procedures for testing and restoring from backup data, do not apply to PaaS Customers that do not choose Catalyze Backup Service. The policy and procedures will assure that complete, accurate, retrievable, and tested backups are available for all systems used by Catalyze.

Data backup is an important part of the day-to-day operations of Catalyze. To protect the confidentiality, integrity, and availability of ePHI, both for Catalyze and Catalyze Customers, completes backups are done daily to assure that data remains available when it needed and in case of disaster.

Violation of this policy and its procedures by workforce members may result in corrective disciplinary action, up to and including termination of employment.

Applicable Standards from the HITRUST Common Security Framework

  • 01.v - Information Access Restriction

Applicable Standards from the HIPAA Security Rule

  • 164.308(a)(7)(ii)(A) - Data Backup Plan
  • 164.310(d)(2)(iii) - Accountability
  • 164.310(d)(2)(iv) - Data Backup and Storage

Backup Policy and Procedures

  1. Perform daily snapshot backups of all systems that process, store, or transmit ePHI for Catalyze Customers, including PaaS Customers that utilize the Catalyze Backup Service
  2. Catalyze Ops Team, lead by VP of Engineering, is designated to be in charge of backups.
  3. Dev Ops Team members are trained and assigned assigned to complete backups and manage the backup media.
  4. Document backups
    • Name of the system
    • Date & time of backup
    • Where backup stored (or to whom it was provided)
  5. Securely encrypt stored backups in a manner that protects them from loss or environmental damage.
  6. Test backups and document that files have been completely and accurately restored from the backup media.