HIPAA / daily practice
For covered entities and business associates handling electronic protected health information.
01The account no one turned off+
Shared credentials and yesterday’s permissions make it hard to say who reached a record. Give each person a unique identity, tie access to the work they perform, review it, and change or remove it when their role changes.
02The data outside the main app+
Electronic protected health information can surface in forms, attachments, notification previews, exports, support tickets, diagnostic logs and mobile downloads. Map the whole route, minimize what each channel carries, and define retention and disposal.
03The cloud tool that “only stores it”+
A cloud provider can be a business associate even when it stores encrypted ePHI and cannot decrypt it. Identify the vendor and subcontractor chain, put required agreements in place before data flows, and document who handles access, backup, return or destruction, and incident notice.
04The backup nobody restored+
A backup file does not prove that the business can recover. Document backup, disaster recovery and emergency operations, then run and record restore tests against the systems the team actually needs.
05The device leaving service+
Phones, laptops, drives, copier storage and portable media need a documented return, removal, reuse or destruction path before they leave the organization’s control.
06The incident with no owner+
Decide who receives the alert, contains the event, preserves facts, assesses notification duties and contacts the right people. A federal 60-day breach-notification limit, when applicable, is an outside limit rather than a waiting period.
07The policy nobody practiced+
Train against the real day: a lost phone, a misdirected attachment, an unusual export and a suspicious login. Record the training and evaluate controls again when systems, people or risks change.