PII Policies and Procedures

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1 PII Policies and Procedures HEALTHCARE BENEFIT SERVICES INC. Kirk Peters HEALTHCARE BENEFIT SERVICES INC BOCA RATON BLVD. SUITE 202 BOCA RATON, FL

2 Table of Contents What is PII... 2 PII Overview... 2 Common PII Examples... 2 Policy on PII... 2 Call Center... 2 Information Technology... 3 CRM Customer Relation Management System... 3 Retention and Security... 4 Workstations and Computers... 4 Passwords... 4 Domain Password Policy Required Settings... 5 Data Classification... 5 Human Resources... 5 Background Checks... 5 Breach and Incidents... 5

3 What is PII PII Overview HBS deals with sensitive Personal Identifiable Information which we refer to as PII. PII can be anything that could identify a customer such as a social security number, telephone number, credit card, customer name, and health related questions. Common PII Examples Social Security Number Name Date of Birth Alien Registration Number Address Phone Number Tax Information such as W2 and 1099 Medicaid Stats Smoker or Non Smoker Citizen or Immigration Status Applicant ID Household Income QHP Eligibility States Policy on PII Call Center Mobile Phone and other electronic devices capable of recording or capturing either video, audio, or a picture or combination of any of the three are not permitted on the call center floor. This includes but is not limited to Cell Phone, Tablet, Laptops, Cameras, and any other electronic devices. These devices must be left in the car or locker prior to entering the call center floor. When communication with the customer DO NOT repeat PII information back to the customer as others in the call center may be able to hear PII related information or medial information. Instead ask the customer to repeat if you are confirming information. No thumb drive, CDROM, Flash Drives, or any other media, peripherals or accessories are to be connected to the computers on the call center floor. Media ports are disabled to prevent unauthorized use. All calls are recorded and archived for a period of 6 years per CMS retention guidance on PII related calls. Our quality control department, team leader, or floor manager at any point my take over a call if PII is not be handled correctly. If anyone in the call center or any employee, agent, or contractor that

4 deals with or has access to PII is mishandling PII this is grounds for immediate termination. Should the misuse of PIII be intention and used for personal or financial gain, fraud, identify theft or any other misuse we will notify the police, FBI, and take every measure to investigate and peruse criminal charges. Absolutely no use of personal accounts is allowed such as Gmail, Yahoo or Social Media such as Facebook and Twitter. PII should not be sent via , while we do have enterprise grade using Microsoft Exchange with Encryption and Retention capabilities. Any PII gathered should be entered only in our CRM, Healthcare.gov or Jibehealth.com. Notes takes on the call can be entered on the notes screen of the dialer or CRM which will be saved and cleared on the next call. Absolutely no paper, post it notes, or pens are allowed on the call center floor. In some circumstances a customer may need to documents to complete their enrollment. In this case your team leader can make the assessment if is the appropriate channel and take measures to safe guard the document. Notes must be entered in the CRM with the time and date the was received, the team leader that authorized and received the containing the PII. Absolutely no Printing of PII including but not limited to screenshots, documents received, notes or any other PII. Inform the customer of our PII policy following our script word for word, including why we request the information, their authorization and consistent, and the steps we take to safe guard. Failure to do this on every call could be grounds for termination. Information Technology CRM Customer Relation Management System Our CRM is security trimmed with username and complex passwords. We require password changes every 90 days. Each agent in our call center is assigned and username and password. Sharing either username and/or password is grounds for immediate termination. Based on the skillset an agent is determines the level of access in the CRM. We can trim what is visible down to the field level so as to protect the customer s information.

5 1 CRM Security Skillsets Retention and Security Calls are retained on a secure file server running Centos Linux OS behind a firewall. We regularly monitor log files for any attempted breach. Any PII related Business Intelligence, Reporting, Marketing, and other actives are handled on a secure file server or our Enterprise Content Management System using SharePoint. This allows for Active Directory credentials and Kerberos Authentication and Encryption to be employed for accessing the content that may need to be used for the purposes of Reporting, BI, Marketing and other IT management related activities. All Production Servers are housed in a datacenter using SAS 70, SSAE 16, HIPPA, SOC2, SSAE16, and SOC3 standards. Development Servers used OnPrem are in a locked Server Room with access to authorized personnel. Workstations and Computers All workstation will lock after 5 minutes of inactivity. All personnel are required to lock their computer when leaving for lunch or a break and log out of their computer at the end of their shift. Scripts and monitoring tools will be employed for compliance with this policy. Passwords Passwords should never be shared with anyone for any reason. Should a password be shared it is grounds for immediate termination. All passwords must be a minimum of 8 characters, contain letters, numbers, special characters, and at least one capital character. Any admin or root passwords must be randomly generated and contain a minimum of 10 characters, contain alpha numeric characters, special characters and employ capital and lowercase characters.

6 Domain Password Policy Required Settings The following settings are mandatory and must be used if the Active Directory domain is part of network: Enforce password history 5 passwords remembered Maximum password age 90 days Minimum password age 0 days Minimum password length 8 characters Password must meet complexity requirements Enabled Store passwords using reversible encryption Disabled Account lockout duration 30 minutes Account lockout threshold 3 invalid logon attempts Reset account lockout counter after 30 minutes Enforcing password history Data Classification PII Restricted + Sensitive This classification of data restricts access to the minimum level of access need for the skillset to complete their job. Restricted data is security trimmed to show only the fields or data values need for that job skillset. Data marked as Sensitive requires special care in handling backups, tapes, and other IT tasks as it relates to Sensitive data. Sensitive data requires logging of access, ACL, and other security permission. Human Resources Background Checks Anyone Employee, Contractor, Vendor, Partner or Agent that has access to any sensitive or restricted data such as PII must be cleared by HR after a background check has been completed. Periodic background checks for anyone with access to PII may be conducted. Breach and Incidents. A breach of PII will be consider a comprise, unauthorized discloser, unauthorized access, loss of control of data, loss of equipment, and/or misuse of PII data for the personal or financial gain outside the course of normal business. Should a breach occur the management team should be immediately notified. The CTO will act as the Designated Privacy Official in the organization with oversight by Peter Colon. In the event of a breach an investigation will immediately take place, and a reasonable effort made to report the breach to CMS IT Service Desk at , and followed up with an to cms_it_service_desk@cms.hhs.gov within one hour of discovery of such a breach. The report must include: - Unauthorized personnel accessing, possessing PII and the extent of any misuse - Lost, stolen or misplaced records containing PII. - Lost, stolen, or misplaced electronic devices, hard drives that contain PII.

7 Should PII be misused intentional for fraud, identity theft, or personal or financial gain of an employee outside of the course of normal business the FBI and local authorities will be notified within 24 hours of the extent and persons involved in the breach or incident. Every measure will be exhausted to prosecute to the full extent of the law.

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