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 physical safeguards for all workstations that access electronic protected health information (ePHI) to restrict access to authorized users. These safeguards include measures such as physical access controls, secure workstation placement, and user authentication mechanisms. The goal is to prevent unauthorized individuals from gaining physical access to workstations, ensuring that only authorized users can interact with systems containing ePHI.

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: Physical Security

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: Documentation of physical safeguards implemented for workstations accessing ePHI

Possible Technology Considerations:

- Biometric Access Controls

- Card Readers and Access Badges

- Video Surveillance Systems

- Secure Workstation Placement Policies

- User Authentication and Authorization 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 physical safeguards been implemented for all workstations that access ePHI to restrict access to authorized users?

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