Map protected information
Document where electronic protected health information is created, received, maintained and transmitted. Include support tools, logs, backups and analytics.
Connect safeguards to operations
Define access approval, workforce changes, encryption, audit logging, incident response, availability and contingency procedures. Assign owners and test the procedures.
Review vendors and cloud services
Understand subprocessors, regions, support access, deletion, restoration and breach notification. Contract language and technical architecture should describe the same reality.
Preserve useful evidence
Keep risk-analysis decisions, policy approvals, access reviews, training records, incident exercises and remediation evidence in a controlled repository.
Clarify the role firstDetermine whether the organisation acts as a covered entity, business associate, subcontractor or another party, then obtain appropriate legal and compliance advice.