Worker Background Checks: Does your organization perform background checks to examine and assess an employee's or contractor's work and criminal history? Or, do you believe that is this not applicable at your organization? If not applicable, provide information for why in the text box below. Also provide any additional information in the text box you believe is important to consider. And, if you have documentation to support your answers that you would like to provide, please attach them using the "Add Files" option.
Yes. We perform background checks following our documented policies and procedures.
No. We do not perform background checks on potential or current employees or contractors.
We are a small organization of 1-5 persons, know each other well, and are not planning to hire anyone in the future, so this action is not applicable to our business.
Employee NDAs: Are your employees required to sign a non-disclosure agreement (NDA) upon hire, and then again annually? Or, do you believe that is this not applicable at your organization? If not applicable, provide information for why in the text box below. Also provide any additional information in the text box you believe is important to consider. And, if you have documentation to support your answers that you would like to provide, please attach them using the "Add Files" option.
Yes, we have documented employee confidentiality policies & procedures, and all our workers sign NDAs.
No, we do not require our employees to sign NDAs.
We are a small organization of 1-5 persons, know each other well, and are not plannng to hire anyone in the future, so this action is not applicable to our business.
Off-boarding Security: Do you have a formal process to manage the termination and/or transfer of employees? Or, do you believe that is this not applicable at your organization? If not applicable, provide information for why in the text box below. Also provide any additional information in the text box you believe is important to consider. And, if you have documentation to support your answers that you would like to provide, please attach them using the "Add Files" option.
Yes. We have formal processes for off-boarding workers.
No. We do not have processes for off-boarding workers.
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.
Physical Security: Do you have physical security controls (e.g., door locks) to prevent unauthorized access to facilities and a facility security plan? Or, do you believe that is this not applicable at your organization? If not applicable, provide information for why in the text box below. Also provide any additional information in the text box you believe is important to consider. And, if you have documentation to support your answers that you would like to provide, please attach them using the "Add Files" option.
Yes. We have implemented physical controls to protect access to PHI.
No. We do not have formal physical security controls in place to prevent access to PHI.
We are a completely mobile business and use no office space; all our employees work from their home. So this action is not applicable to our business.
Data Protection: 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? Or, do you believe that is this not applicable at your organization? If not applicable, provide information for why in the text box below. Also provide any additional information in the text box you believe is important to consider. And, if you have documentation to support your answers that you would like to provide, please attach them using the "Add Files" option.
Yes. We have data protection controls implemented, and associated policies & procedures.
No, do not have such controls in place, or we only have one or two that we've implemented.
We have some of these controls in place, but not all of them.
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.
Access Controls: 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)? Or, do you believe that is this not applicable at your organization? If not applicable, provide information for why in the text box below. Also provide any additional information in the text box you believe is important to consider. And, if you have documentation to support your answers that you would like to provide, please attach them using the "Add Files" option.
Yes. We follow formally documented access authorization procedures.
No. We do not have a formal access authorization process in place.
We have a loose rule about this, but we do not have a formal access authorization procedure in place.
We are a small organization of 1-5 persons, do not use an MSP, and we all perform generally the same types of activities with the same data, so this action is not applicable to our business.
ID Management: 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? Or, do you believe that is this not applicable at your organization? If not applicable, provide information for why in the text box below. Also provide any additional information in the text box you believe is important to consider. And, if you have documentation to support your answers that you would like to provide, please attach them using the "Add Files" option.
Yes. We have policies and procedures prohibiting IDs from being shared.
No. We have no restrictions on ID sharing.
For the most part we do not share IDs. But we have one or a very few IDs we share.
Malicious Code Controls: Have you implemented anti-malware (e.g., anti-virus, spam filters, etc.) on your computers and supporting systems? Or, do you believe that is this not applicable at your organization? If not applicable, provide information for why in the text box below. Also provide any additional information in the text box you believe is important to consider. And, if you have documentation to support your answers that you would like to provide, please attach them using the "Add Files" option.
Yes. We have Have you implemented anti-malware (e.g., anti-virus, spam filters, etc.) software and technologies on our computing and storage devices, and have documented policies and procedure in place for their use, and to keep them updated.
No. But this is something we should do, or we do not believe this is necessary for our environment.
We have some anti-malware tools in place on our systems and personal computers, but we should implement more to cover all computing and digital storage devices.
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". Or, is this not applicable at your organization? If not applicable, provide information for why in the text box below. Also provide any additional information in the text box you believe is important to consider. And, if you have documentation to support your answers that you would like to provide, please attach them using the "Add Files" option.
Yes, we have documented media handling policies and procedures implemented, and can provide upon request.
No. We do not have documented media handling policies and procedures. See our reasons why below.
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. See more information about this in the text field below.
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. They are separated.
No. They are not separated. Provide an explanation for why in the field below.
We use a managed systems provider (MSP) and are not sure, but we think they are using segregation of computing environments management procedures.
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, do you believe that is this not applicable at your organization? If not applicable, provide information for why in the text box below. Also provide any additional information in the text box you believe is important to consider.
Yes. They are separated.
No. They are not separated. Provide an explanation for why in the text field below.
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 formally documented 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? If not applicable, provide information for why in the text box below. Also provide any additional information in the text box you believe is important to consider. And, if you have documentation to support your answers that you would like to provide, please attach them using the "Add Files" option.
Yes. We follow formally established change management procedures.
No. We do not have, or need to have, change management procedures. See our reasons why below.
We use a managed systems provider (MSP) and are not sure, but we think they are using change management procedures.
Controls: How would you evaluate your current implementation of all the information security and privacy controls needed within your organization to effectively mitigate risks and meet all legal requirements?
We have fully implemented all the controls and we are now managing ongoing compliance.
We have around half to most of the controls implemented, but still have some work to do.
We are just getting started, and no to some of the controls fully implemented.
Documentation: Could you provide documentation (e.g., information security policies, supporting business documentation, etc.) for all your organization's information security and privacy controls within 24 hours or request?
Yes, we have everything well documented and can provide upon request.
Yes, we could for most of our information security and privacy controls. However, some would take longer.
No, we still need to do a lot of documentation, but we're working on it.
Digital Connectivity: Are connections to your networks and systems logged and monitored? Or, do you believe that is this not applicable at your organization? If not applicable, provide information for why in the text box below. Also provide any additional information in the text box you believe is important to consider. And, if you have documentation to support your answers that you would like to provide, please attach them using the "Add Files" option.
Yes. We consistently monitor all networks and systems connections
No. We do not monitor networks and systems connections.
We do some logging, but we do not log everything involving all types of access to PHI on systems and networks.
We use a managed services provider (MSP) so we are not sure, but we think they are logging connections to the systems and networks.