Does your organization perform background checks to examine and assess an employee's or contractor's work and criminal history?
Yes
No
We are a small organization of 1-5 persons and are not planning to hire anyone in the future, so this action is not applicable to our business.
Are your employees required to sign a non-disclosure agreement upon hire, and then again annually?
Yes
No
We are a small organization of 1-5 persons and are not planning to hire anyone in the future, so this action is not applicable to our business.
Do you have a formal process to manage the termination and/or transfer of employees?
Yes
No
We are a small organization of 1-5 persons and are not planning to hire anyone in the future, so this action is not applicable to our business.
Do you have physical security controls (e.g., door locks) to prevent unauthorized access to facilities and a facility security plan?
Yes
No
We are a small organization of 1-5 persons, we all work from our homes, and are not planning to hire anyone in the future, so this action is not applicable to our business.
Do you have controls on systems and networks that host, process and/or transfer sensitive information, including the use of firewalls and controls for protecting network devices from unauthorized access and data-theft?
Yes
We have some of these controls in place, but not all of them.
No, we have one or none of these types of controls in place.
We use a managed systems provider (MSP) that is responsible for and manages all the systems and networks we use for our business. So this action is not applicable to our business; it is the responsibility of the MSP.
Are connections to your networks and systems logged and monitored?
Yes
We do some logging, but we don't log everything involving all types of access to PHI on systems and networks.
No
We use a managed services provider (MSP) so we are not sure, but we think they are
Do you have a formal access authorization process based on 'least privilege' (employees are granted the least amount of access possible in order to perform their assigned duties) and need to know (access permissions are granted based upon the legitimate business need of the user to access the information)?
Yes
We have a loose rule about this, but we do not have a formal access authorization procedure in place.
No
We are a small organization of 1-5 persons, we all need access to all data to run our business and fulfill business obligations, and are not planning to hire anyone in the future, so this action is not applicable to our business.
Do you require each user ID to be unique and not shared with others, and have a process to remove them when the user leaves the organization?
Yes
For the most part. But we have one or a very few IDs we share.
No
Have you implemented anti-malware (e.g., anti-virus, spam filters, etc.) on your computers and supporting systems?
Yes
We have some anti-malware tools in place on our systems and personal computers, but we should implement more to cover everything.
No
We use a managed services provider (MSP) to do all our computing activities, so they need to have anti-malware in place, not us.
Media handling: Do procedures exist to protect documents (e.g., paper files, prescription labels, print materials, etc.) and computer media (e.g., tapes, disks, CD-ROMs, etc.), from unauthorized disclosure, modification, removal, and destruction? Is sensitive data encrypted when stored on laptop, desktop and server hard drives, flash drives, backup tapes, etc.?If the answer is "No" to either of these questions, answer "No".
Yes
No
We use a managed services provider (MSP) to do all our computing activities, so they need to have media handling procedures in place, not us.
Segregation of Computing Environments: Are development, test and production environments separated from operational IT environments to protect production (actively used) applications from inadvertent changes or disruption? Are the data files of your business clients segregated from one another? If the answer to either question is "No" indicate "No" as your answer. Or, is this not applicable at your organization?
Yes
No
We use a managed systems provider (MSP) and are not sure, but we think they are.
We are a small organization of 1-5 persons, do not use an MSP, and we do not create software, so this action is not applicable to our business.
Segregation of Duties: Are duties separated, where appropriate, to reduce the opportunity for unauthorized modification, unintentional modification or misuse of the organization's IT assets? Or, is this not applicable at your organization?
Yes
No
We are a small (e.g., 1 - 5 person) business and we all know each other well and perform many different duties, so this action is not feasible to our business.
Change Management: Do formal change management procedures exist for networks, systems, desktops, software releases, deployments, and software vulnerability (e.g., virus or spyware) patching activities? Or, is this not applicable at your organization?
Yes
No
We use a managed systems provider (MSP) and are not sure, but we think they are
How would you evaluate your current implementation of all of the above controls?
Just getting started, but have some of the controls fully implemented.
Have around half to most of the controls implemented, but still have some work to do
Have fully implemented all the controls and is now managing ongoing compliance.
Could you provide documentation (e.g., information security policies, supporting business documentation, etc.) for all the controls above within 24 hours or request?
Yes
For most of the controls above, but some would take longer
No, we still need to do a lot of documentation, but we're working on it.