Description:


Organizations adhere to a rigorous record-keeping practice, meticulously documenting the movements of hardware and electronic media, alongside details of the individuals responsible for these assets. This critical process is indispensable for monitoring the physical whereabouts and secure handling of sensitive equipment, storage media, and electronic devices, including those containing Protected Health Information (PHI). By maintaining detailed records, organizations strengthen security measures, ensure accountability, and demonstrate compliance with regulatory requirements.


The record-keeping protocol encompasses the entire lifecycle of hardware and electronic media, covering movement, transfer, and disposal. Each entry in the record includes vital information such as the asset's description, unique identifier, location, date, time, and the responsible individual. This meticulous documentation is instrumental in monitoring asset usage, detecting potential security breaches, and guaranteeing the proper handling of devices containing sensitive information.


As an additional security measure, organizations ensure the creation of a retrievable, exact copy of electronic protected health information (ePHI) before the movement of equipment, whenever needed. This proactive step involves capturing a complete and accurate duplicate of ePHI to mitigate the risk of data loss or compromise during equipment transitions.


Moreover, organizations implement procedures for the removal of electronic protected health information (ePHI) from electronic media before the media are made available for re-use. These procedures are designed to securely and irreversibly delete or sanitize any ePHI stored on electronic media, ensuring that the media can be safely repurposed without the risk of unintentional disclosure or data compromise.


These records serve not only as a security measure but also as a powerful accountability tool, mitigating the risks of unauthorized access, loss, or theft of hardware and media that could compromise the confidentiality and integrity of electronic data.


Priority: High


Category: Data Disposal and Media Sanitization


Services Associated with AWS:


AWS Identity and Access Management (IAM)

AWS Key Management Service (KMS)

AWS Security Hub


Services Associated with Azure:


Azure Identity and Access Management

Azure Active Directory

Azure Security Center


Objective Evidence:


- Administrative: Documented policies and procedures for recording hardware and media movements

- Administrative: Supporting documentation demonstrating the proper handling and tracking of electronic media

- Technical: Records and logs of hardware and media movements

- Technical: Documentation of procedures for creating retrievable, exact copies of ePHI before equipment movement

- Technical: Procedures for the removal of ePHI from electronic media before re-use


Possible Technology Considerations:


- Data Erasure Tools

- Secure Data Deletion Processes

- Media Sanitization Procedures

- Encryption Key Management

- Data Disposal Verification Mechanisms


What needs to be answered:


  • Are there documented policies and procedures for recording the movements of hardware and electronic media?
  • Can the organization provide evidence of how these records are maintained and used for accountability?
  • Are there mechanisms in place to capture and document the movements of hardware and electronic media, including the responsible individuals?
  • Is there a documented procedure for creating retrievable, exact copies of ePHI before the movement of equipment?
  • Have procedures been established and implemented for the removal of ePHI from electronic media before the media are made available for re-use?


More details: The maintenance of records and the implementation of media sanitization procedures are fundamental practices for safeguarding electronic data, especially PHI. These measures help prevent data breaches, unauthorized access, and ensure proper asset and data disposal management throughout the lifecycle of sensitive information.