Presented by: Jason C. Gavejian Morristown Office
|
|
- Esmond Victor Benson
- 5 years ago
- Views:
Transcription
1 Presented by: Jason C. Gavejian Morristown Office } Unauthorized use of, or access to, records or data containing personal information Personal Information (PI) typically includes First name or first initial and last name in combination with: Social Security Number Drivers License or State identification number Account number or credit or debit card number in combination with access or security code Biometric Information (e.g. NC, NE, IA, WI) Medical Information (e.g. CA, VA) PI typically maintained by employers? Human Resources-Applications, FMLA, Disability, etc. Accounting-Payroll documents Benefits-Health, Vision, Dental 2 1
2 } Fines, Penalties, Settlements: State Attorney Generals Vary By State Multipliers: Michigan permits civil fines of not more than $250 per failure (each person), with a maximum of $750,000. Length of notification delay: Florida imposes fines when notification is not provided within the statute s mandated time frame (45 days). Calculate the fine as $1,000 per day for the first 30 days, and $50,000 for each 30 day period thereafter with a maximum fine of $500,000. Health and Human Services Penalties and settlements in the millions of dollars } Private Cause of Action 14 states have some form of private action 3 } Employment Context Loss, Theft, Improper Access, Inadvertent Disclosure Laptop iphone, Droid, ipad, Tablet, Blackberry Thumb Drive, Hard Drive Shared Documents } Other Instances Click/Turn On News 4 2
3 Need to take a number of steps to address the incident: Identify The Internal Team Who Will Be Handling The Incident Executives/management level employees Too much involvement must be managed carefully Adhere to existing internal procedures/data Incident Response Plan, document steps taken Data Incident response/hipaa Notify/Coordinate with insurance carrier 5 } Finalize the investigation and review results To respond to the incident and complete the required notifications, you will need to determine some key information: Nature of incident Date incident occurred Date incident was discovered Number of persons affected: Total number of affected persons - how many residents of each state were affected. Names of persons affected (LA only) Contact person: Who will be the contact person in the notification letter. Does not have to be the same person for all notifications-could be multiple persons Signatory of notification letters: Same as bullet above 6 3
4 Where is this information available? A review of activity logs on the company systems or backup tapes related to this employee Conducting a formal interview with the employee/others to help learn more about what information might have been saved on the device Consider also: The projects the employee worked on, the life of the device, how long the employee has been with the company. More information here may shape the steps that need to be taken below Careful of unreasonable delays to the notification 7 } File police report } Litigation hold } Data Security Agreements Review and confirm there is a data security agreement in place with the vendors that will be assisting Work with your insurance carrier as they may have preferred vendors 8 4
5 } Determine whether this is a reportable breach State breach notification statutes and regulations 46 states have a data breach notification requirement Definitions vary state by state Residency of the affected individual is key Risk of harm trigger What is it? How can you make this decision? Document your decision Employee Relations Concerns? 9 } Verify persons affected and contact information before and after sending notifications Last known mailing addresses Check all data bases for current information, not just the personnel or payroll files. For former employees, consider looking at COBRA or retirement plan records. If you are are unable to obtain accurate contact information additional measures may be advisable/required. Even after letters are sent, you will need to have a system for collecting and addressing letters that were undeliverable. 10 5
6 Determine whether credit monitoring services will be offered State laws do not require entities to provide credit monitoring services in the case of a data breach Protection? (e.g. only names and medical information, but not social security numbers or financial account numbers) Peace of mind for those affected, especially employees? Company image to state agency investigator Review the services agreements with the vendor(s) and coordinate with the vendor(s) to obtain language to include in the notification letters 11 } Set up call center Why/Why Not Size of the breach Review services agreements with the vendors and include the appropriate contact information in the letters Lead time Develop a script for call center employees to use when responding to questions about the incident Public Relations Develop an escalation process to address situations where the call center is not able to resolve a caller s concerns 12 6
7 } Coordinate with public relations (PR) department You will want to have public relations involved to review all communications - ensure consistent overall messaging Notice to statewide media Depending on state and number of persons affected What if no PR department? Who will handle this? Human Resources? Legal? Both? 13 } Connect with letter fulfillment company Using a vendor to finalize and send the notices to the affected individuals - similar concerns regarding vendor agreements Consider the number of persons affected and the cost of notification Substitute notice provisions. This usually involves providing notice by all of the following , posting on website, and notification in state wide media. 14 7
8 } Prepare and send breach notifications Federal law HIPAA or SEC regulations/guidance (public companies) State law Notice to individuals - Risk of harm/employee relations Specific content and timing requirements Notice to state agencies If breach notice is required to be provided to residents of the state, some states require notice be provided to certain state agencies in the state Notice to credit reporting agencies May need to notify the consumer reporting agencies of the breach (Transunion, Equifax and Experian) Notice to owner of data. If you are not the owner of the data but maintain it on behalf of another, your obligation generally is to notify the owner 15 } Be prepared for complaints and agency inquiry Complaints with the FTC or the state Attorney General s office concerning the handling of the breach notification or the obligations to safeguard the information in the first place Consider the following: Ensure a complaint process is in place and effective for responding timely Review existing data privacy and security policies and procedures to ensure compliance and have them at the ready to be responsive to agency inquiry. Be sure appropriate parties are involved in the response 16 8
9 17 9
Data Compromise Notice Procedure Summary and Guide
Data Compromise Notice Procedure Summary and Guide Various federal and state laws require notification of the breach of security or compromise of personally identifiable data. No single federal law or
More informationKeeping It Under Wraps: Personally Identifiable Information (PII)
Keeping It Under Wraps: Personally Identifiable Information (PII) Will Robinson Assistant Vice President Information Security Officer & Data Privacy Officer Federal Reserve Bank of Richmond March 14, 2018
More informationInside the OCR Investigation/Audit Process 2018 PBI HEALTH LAW INSTITUTE TUESDAY, MARCH 13, 2017 GREGORY M. FLISZAR, J.D., PH.D.
Inside the OCR Investigation/Audit Process 2018 PBI HEALTH LAW INSTITUTE TUESDAY, MARCH 13, 2017 GREGORY M. FLISZAR, J.D., PH.D. HIPAA GENERAL RULE PHI may not be disclosed without patient authorization
More informationDeveloping Issues in Breach Notification and Privacy Regulations: Risk Managers Are you having the right conversation with the C Suite?
Developing Issues in Breach Notification and Privacy Regulations: Risk Managers Are you having the right conversation with the C Suite? Minnesota RIMS 39 th Annual Seminar Risk 2011-2012: Can You Hack
More informationCOMMENTARY. Information JONES DAY
February 2010 JONES DAY COMMENTARY Massachusetts Law Raises the Bar for Data Security On March 1, 2010, what is widely considered the most comprehensive data protection and privacy law in the United States
More informationElements of a Swift (and Effective) Response to a HIPAA Security Breach
Elements of a Swift (and Effective) Response to a HIPAA Security Breach Susan E. Ziel, RN BSN MPH JD Krieg DeVault LLP Past President, The American Association of Nurse Attorneys Disclaimer The information
More informationEmployee Security Awareness Training Program
Employee Security Awareness Training Program Date: September 15, 2015 Version: 2015 1. Scope This Employee Security Awareness Training Program is designed to educate any InComm employee, independent contractor,
More informationSummary Comparison of Current Data Security and Breach Notification Bills
Topic S. 117 (Nelson) S. (Carper/Blunt) H.R. (Blackburn/Welch) Comments Data Security Standards The FTC shall promulgate regulations requiring information security practices that are appropriate to the
More informationUpdate on HIPAA Administration and Enforcement. Marissa Gordon-Nguyen, JD, MPH October 7, 2016
Update on HIPAA Administration and Enforcement Marissa Gordon-Nguyen, JD, MPH October 7, 2016 Updates Policy Development Breaches Enforcement Audit 2 POLICY DEVELOPMENT RECENTLY PUBLISHED: RIGHT OF ACCESS,
More informationHIPAA For Assisted Living WALA iii
Table of Contents The Wisconsin Assisted Living Association... ix Mission... ix Vision... ix Values... ix Acknowledgments... ix Who Should Use This Manual... x How to Use This Manual... x Updates and Forms...
More informationFrequently Asked Question Regarding 201 CMR 17.00
Frequently Asked Question Regarding 201 CMR 17.00 What are the differences between this version of 201 CMR 17.00 and the version issued in February of 2009? There are some important differences in the
More informationOverview Bank IT examination perspective Background information Elements of a sound plan Customer notifications
Gramm-Leach Bliley Act Section 501(b) and Customer Notification Roger Pittman Director of Operations Risk Federal Reserve Bank of Atlanta Overview Bank IT examination perspective Background information
More informationHIPAA-HITECH: Privacy & Security Updates for 2015
South Atlantic Regional Annual Conference Orlando, FL February 6, 2015 1 HIPAA-HITECH: Privacy & Security Updates for 2015 Darrell W. Contreras, Esq., LHRM Gregory V. Kerr, CHPC, CHC Agenda 2 OCR On-Site
More informationThe HIPAA Omnibus Rule
The HIPAA Omnibus Rule What You Should Know and Do as Enforcement Begins Rebecca Fayed, Associate General Counsel and Privacy Officer Eric Banks, Information Security Officer 3 Biographies Rebecca C. Fayed
More informationPRIVACY-SECURITY INCIDENT REPORT
SECTION I GENERAL INFORMATION Name of Staff Member Reporting Incident PRIVACY-SECURITY INCIDENT REPORT Telephone Number Email Address Division/Office/Facility Unit/Section Supervisor SECTION II PRIVACY
More informationPutting It All Together:
Putting It All Together: The Interplay of Privacy & Security Regina Verde, MS, MBA, CHC Chief Corporate Compliance & Privacy Officer University of Virginia Health System 2017 ISPRO Conference October 24,
More informationInformation Security Incident Response Plan
Information Security Incident Response Plan Purpose It is the objective of the university to maintain secure systems and data. In order to comply with federal, state, and local law and contractual obligations,
More informationSecurity and Privacy Breach Notification
Security and Privacy Breach Notification Version Approval Date Owner 1.1 May 17, 2017 Privacy Officer 1. Purpose To ensure that the HealthShare Exchange of Southeastern Pennsylvania, Inc. (HSX) maintains
More informationINFORMATION TECHNOLOGY DATA MANAGEMENT PROCEDURES AND GOVERNANCE STRUCTURE BALL STATE UNIVERSITY OFFICE OF INFORMATION SECURITY SERVICES
INFORMATION TECHNOLOGY DATA MANAGEMENT PROCEDURES AND GOVERNANCE STRUCTURE BALL STATE UNIVERSITY OFFICE OF INFORMATION SECURITY SERVICES 1. INTRODUCTION If you are responsible for maintaining or using
More informationSTATE OF NEW JERSEY. ASSEMBLY, No th LEGISLATURE. Sponsored by: Assemblywoman ANNETTE QUIJANO District 20 (Union)
ASSEMBLY, No. 0 STATE OF NEW JERSEY th LEGISLATURE INTRODUCED NOVEMBER 0, 0 Sponsored by: Assemblywoman ANNETTE QUIJANO District 0 (Union) SYNOPSIS Requires certain persons and business entities to maintain
More informationPTLGateway Data Breach Policy
1 PTLGateway Data Breach Policy Last Updated Date: 02 March 2018 Data Breach Policy This page informs you of our policy which is to establish the goals and the vision for the breach response process. This
More informationHow Secure Do You Feel About Your HIPAA Compliance Plan? Daniel F. Shay, Esq.
How Secure Do You Feel About Your HIPAA Compliance Plan? Daniel F. Shay, Esq. Word Count: 2,268 Physician practices have lived with the reality of HIPAA for over twenty years. In that time, it has likely
More informationWhen the Other Brother Steps Up: State Privacy Enforcement Actions
When the Other Brother Steps Up: State Privacy Enforcement Actions Healthcare Enforcement Compliance Conference November 6, 2018 Washington, DC Blaine Kerr, CISA, CHPC Chief Privacy Officer Jackson Health
More informationBreaches and Remediation
Breaches and Remediation Ramona Oliver US Department of Labor Personally Identifiable Information Personally Identifiable Information (PII): Any information about an individual maintained by an agency,
More informationCyber Attacks and Data Breaches: A Legal and Business Survival Guide
Cyber Attacks and Data Breaches: A Legal and Business Survival Guide August 21, 2012 Max Bodoin, Vince Farhat, Shannon Salimone Copyright 2012 Holland & Knight LLP. All Rights Reserved What this Program
More informationRegulation P & GLBA Training
Regulation P & GLBA Training Overview Regulation P governs the treatment of nonpublic personal information about consumers by the financial institution. (Gramm-Leach-Bliley Act of 1999) The GLBA is composed
More informationHIPAA/HITECH Act Update HCCA South Central Regional Annual Conference December 2, Looking Back at 2011
HIPAA/HITECH Act Update HCCA South Central Regional Annual Conference December 2, 2012 Phyllis F. Granade The Granade Law Firm Atlanta, GA (678) 705 2507 pgranade@granadelaw.com www.granadelaw.com Looking
More informationData Breach Preparation and Response. April 21, 2017
Data Breach Preparation and Response April 21, 2017 King & Spalding Data, Privacy & Security King & Spalding s 60 plus lawyer Data, Privacy & Security ( DPS ) Practice is best known for: Experienced crisis
More informationCredit Card Data Compromise: Incident Response Plan
Credit Card Data Compromise: Incident Response Plan Purpose It is the objective of the university to maintain secure financial transactions. In order to comply with state law and contractual obligations,
More informationBeam Technologies Inc. Privacy Policy
Beam Technologies Inc. Privacy Policy Introduction Beam Technologies Inc., Beam Dental Insurance Services LLC, Beam Insurance Administrators LLC, Beam Perks LLC, and Beam Insurance Services LLC, (collectively,
More informationInformation Security Incident Response Plan
Information Security Incident Response Plan Purpose It is the objective of the university to maintain secure systems and data. In order to comply with federal, state, and local law and contractual obligations,
More informationDATA BREACH NUTS AND BOLTS
DATA BREACH NUTS AND BOLTS Your Company Has Been Hacked Now What? January 20, 2016 Universal City, California Sponsored by Hogan Lovells Moderator: Stephanie Yonekura, Hogan Lovells #IHCC16 Panelists:
More informationHIPAA How to Comply with Limited Time & Resources. Jonathan Pantenburg, MHA, Senior Consultant August 17, 2017
HIPAA How to Comply with Limited Time & Resources Jonathan Pantenburg, MHA, Senior Consultant JPantenburg@Stroudwater.com August 17, 2017 Stroudwater Associates is a leading national healthcare consulting
More informationInto the Breach: Breach Notification Requirements in the Wake of the HIPAA Omnibus Rule
Into the Breach: Breach Notification Requirements in the Wake of the HIPAA Omnibus Rule The Twenty-Second National HIPAA Summit Healthcare Privacy and Security After HITECH and Health Reform Rebecca Williams,
More informationBreach Notification Remember State Law
Breach Notification HITECH: First federal law mandating breach notification for health care industry Applies to covered entities, business associates, PHR vendors, and PHR service providers FTC regulates
More informationPrivacy Breach Policy
1. PURPOSE 1.1 The purpose of this policy is to guide NB-IRDT employees and approved users on how to proceed in the event of a privacy breach, and to demonstrate to stakeholders that a systematic procedure
More informationDATA PRIVACY & SECURITY THE CHANGING HIPAA CLIMATE
DATA PRIVACY & SECURITY THE CHANGING HIPAA CLIMATE Melodi (Mel) M. Gates mgates@pattonboggs.com (303) 894-6111 October 25, 2013 THE CHANGING PRIVACY CLIMATE z HEALTH INSURANCE PORTABILITY & ACCOUNTABILITY
More informationBreach Notification Assessment Tool
Breach Notification Assessment Tool December 2006 Information and Privacy Commissioner of Ontario David Loukidelis Commissioner Ann Cavoukian, Ph.D. Commissioner This document is for general information
More informationData Processing Agreement
In accordance with the European Parliament- and Council s Directive (EU) 2016/679 of 27th April 2016 (hereinafter GDPR) on the protection of physical persons in connection with the processing of personal
More informationOverview of Presentation
A HIPAA Security Incident and Investigation. It Can Happen to You. Sandra a L. Sessoms, RN, CPHQ, CHC Interim Vice President, System Compliance West Penn Allegheny Health System Robert R. Michalski, CHC
More informationGramm Leach Bliley Act 15 U.S.C GLBA/HIPAA Information Security Program Committee GLBA, Safeguards Rule Training, Rev.
Gramm Leach Bliley Act 15 U.S.C. 6801-6809 GLBA/HIPAA Information Security Program Committee GLBA, Safeguards Rule Training, Rev. 11/30/2016 1 Objectives for GLBA Training GLBA Overview Safeguards Rule
More informationPrivacy Statement. Your privacy and trust are important to us and this Privacy Statement ( Statement ) provides important information
Privacy Statement Introduction Your privacy and trust are important to us and this Privacy Statement ( Statement ) provides important information about how IT Support (UK) Ltd handle personal information.
More informationLCU Privacy Breach Response Plan
LCU Privacy Breach Response Plan Sept 2018 Prevention Communication & Notification Evaluation of Risks Breach Containment & Preliminary Assessment Introduction The Credit Union makes every effort to safeguard
More informationBreach Notifications: How to Handle Breaches Across Jurisdictions. Moderated by: Zach Warren, Editor-in-Chief, Legaltech News
Breach Notifications: How to Handle Breaches Across Jurisdictions Moderated by: Zach Warren, Editor-in-Chief, Legaltech News 1 States with/without breach notification laws 47 states, plus the District
More informationHIPAA UPDATE. Michael L. Brody, DPM
HIPAA UPDATE Michael L. Brody, DPM Objectives: How to respond to a patient s request for a copy of their records. Understand your responsibilities after you send information out to another doctor, hospital
More informationFirst aid toolkit for the management of data breaches. Mary Deligianni Senior Associate 15 February 2018
First aid toolkit for the management of data breaches Mary Deligianni Senior Associate 15 February 2018 What is a personal data breach? Breach of security which leads to the accidental or unlawful destruction,
More informationUpdate on Administration and Enforcement of the HIPAA Privacy, Security, and Breach Notification Rules
Update on Administration and Enforcement of the HIPAA Privacy, Security, and Breach Notification Rules Marissa Gordon-Nguyen Office for Civil Rights (OCR) U.S. Department of Health and Human Services June
More informationHow to Respond to a HIPAA Breach. Tuesday, Oct. 25, 2016
How to Respond to a HIPAA Breach Tuesday, Oct. 25, 2016 This Webinar is Brought to You By. About HealthInsight and Mountain-Pacific Quality Health HealthInsight and Mountain-Pacific Quality Health are
More informationPrivacy & Information Security Protocol: Breach Notification & Mitigation
The VUMC Privacy Office coordinates compliance with the required notification steps and prepares the necessary notification and reporting documents. The business unit from which the breach occurred covers
More informationUTAH VALLEY UNIVERSITY Policies and Procedures
Page 1 of 5 POLICY TITLE Section Subsection Responsible Office Private Sensitive Information Facilities, Operations, and Information Technology Information Technology Office of the Vice President of Information
More informationUniversity of Wisconsin-Madison Policy and Procedure
Page 1 of 10 I. Policy The Health Information Technology for Economic and Clinical Health Act regulations ( HITECH ) amended the Health Information Portability and Accountability Act ( HIPAA ) to establish
More informationThe Relationship Between HIPAA Compliance and Business Associates
The Relationship Between HIPAA Compliance and Business Associates 1 HHS Wall of Shame 20% Involved Business Associates Based on HHS Breach Portal: Breaches Affecting 500 or More Individuals, Type of Breach
More informationencrypted, and that all portable devices (laptops, phones, thumb drives, etc.) be encrypted while in use and while at rest?
Data Privacy According to statistics provided by the Data Breach Level Index, hackers and thieves are stealing more than 227,000 personal records per hour as of 2017, generally targeting customer information
More informationCyber Risks in the Boardroom Conference
Cyber Risks in the Boardroom Conference Managing Business, Legal and Reputational Risks Perspectives for Directors and Executive Officers Preparing Your Company to Identify, Mitigate and Respond to Risks
More informationRed Flags/Identity Theft Prevention Policy: Purpose
Red Flags/Identity Theft Prevention Policy: 200.3 Purpose Employees and students depend on Morehouse College ( Morehouse ) to properly protect their personal non-public information, which is gathered and
More informationHIPAA and HIPAA Compliance with PHI/PII in Research
HIPAA and HIPAA Compliance with PHI/PII in Research HIPAA Compliance Federal Regulations-Enforced by Office of Civil Rights State Regulations-Texas Administrative Codes Institutional Policies-UTHSA HOPs/IRB
More informationAudits Accounting of disclosures
Once more unto the breach Mastering HIPAA s data breach notification requirements September 20, 2011 Presented by: Kathy Kenady Senior Loss Prevention Representative Medical Insurance Exchange of California
More informationFinFit will request and collect information in order to determine whether you qualify for FinFit Loans*.
FinFit Web Privacy Policy General: This Privacy Policy ( Policy ) describes the ways FinFit, LLC ( FinFit, we, us) collects, stores, uses and protects information we receive from you or that you may provide
More informationHIPAA & Privacy Compliance Update
HIPAA & Privacy Compliance Update Vermont Medical Society FREE Wednesday Webinar Series March 15, 2017 Anne Cramer and Shireen Hart Primmer Piper Eggleston & Cramer PC acramer@primmer.com shart@primmer.com
More informationWithin the meanings of applicable data protection law (in particular EU Regulation 2016/679, the GDPR ):
Privacy Policy Introduction Ikano S.A. ( Ikano ) respects your privacy and is committed to protect your Personal Data by being compliant with this privacy policy ( Policy ). In addition to Ikano, this
More informationIntegrating HIPAA into Your Managed Care Compliance Program
Integrating HIPAA into Your Managed Care Compliance Program The First National HIPAA Summit October 16, 2000 Mark E. Lutes, Esq. Epstein Becker & Green, P.C. 1227 25th Street, N.W., Suite 700 Washington,
More informationCore Elements of HIPAA The Privacy Rule establishes individuals privacy rights and addresses the use and disclosure of protected health information ( PHI ) by covered entities and business associates The
More informationWhy you MUST protect your customer data
Why you MUST protect your customer data If you think you re exempt from compliance with customer data security and privacy laws because you re a small business, think again. Businesses of all sizes are
More informationSecurity Breach Notification Reflections on the U.S. Experience
Compliance & Regulatory Matters Data Privacy Security Breach Notification Reflections on the U.S. Experience Bojana Bellamy Director of Data Privacy Accenture Brief History of Breach Notification Laws
More informationSECURITY STATE OF THE INDUSTRY
SECURITY STATE OF THE INDUSTRY An Interview with Stephen Treglia JD, HCISPP, HIPAA Compliance Officer, Investigations Section, Absolute OVERVIEW The health sector is rapidly adopting new technologies,
More informationDavid C. Marshall, Esq. PACAH 2017 Spring Conference April 27, 2017
David C. Marshall, Esq. PACAH 2017 Spring Conference April 27, 2017 Privacy and security of patient information held by health care providers remains a concern of the federal government. More resources
More informationINFORMATION SECURITY AND SECURITY BREACH NOTIFICATION GUIDANCE Preventing, Preparing for, and Responding to Breaches of Information Security
INFORMATION SECURITY AND SECURITY BREACH NOTIFICATION GUIDANCE Preventing, Preparing for, and Responding to Breaches of Information Security The Office of Illinois Attorney General Lisa Madigan has created
More information[Utility Name] Identity Theft Prevention Program
[Utility Name] Identity Theft Prevention Program Effective beginning, 2008 Minnesota Municipal Utilities Association Sample Red Flag policy I. PROGRAM ADOPTION The [Utility Name] ("Utility") developed
More informationSecurity Breaches: How to Prepare and Respond
Security Breaches: How to Prepare and Respond BIOS SARAH A. SARGENT Sarah is a CIPP/US- and CIPP/E-certified attorney at Godfrey & Kahn S.C. in Milwaukee, Wisconsin. She specializes in cybersecurity and
More informationFerrous Metal Transfer Privacy Policy
Updated: March 13, 2018 Ferrous Metal Transfer Privacy Policy Ferrous Metal Transfer s Commitment to Privacy Ferrous Metal Transfer Co. ( FMT, we, our, and us ) respects your concerns about privacy, and
More informationHIPAA Compliance: What it is, what it means, and what to do about it. Adam Carlson, Security Solutions Consultant Intapp
HIPAA Compliance: What it is, what it means, and what to do about it. Adam Carlson, Security Solutions Consultant Intapp Agenda Introductions HIPAA Background and History Overview of HIPAA Requirements
More informationEU GDPR and . The complete text of the EU GDPR can be found at What is GDPR?
EU GDPR and Email The EU General Data Protection Regulation (GDPR) is the new legal framework governing the use of the personal data of European Union (EU) citizens across all EU markets. It replaces existing
More information2016 SC REGIONAL HOUSING AUTHORITY NO. 3 S EIV SECURITY POLICY
2016 SC REGIONAL HOUSING AUTHORITY NO. 3 S EIV SECURITY POLICY Purpose: The purpose of this policy is to provide instruction and information to staff, auditors, consultants, contractors and tenants on
More informationUniversity of North Texas System Administration Identity Theft Prevention Program
University of North Texas System Administration Identity Theft Prevention Program I. Purpose of the Identity Theft Prevention Program The Federal Trade Commission ( FTC ) requires certain entities, including
More informationUniversity of Pittsburgh Security Assessment Questionnaire (v1.7)
Technology Help Desk 412 624-HELP [4357] technology.pitt.edu University of Pittsburgh Security Assessment Questionnaire (v1.7) Directions and Instructions for completing this assessment The answers provided
More informationUCOP Guidelines for Protection of Electronic Personal Information Data and for Security Breach Notification
University of California UCOP Guidelines for Protection of Electronic Personal Information Data and for Security Breach Notification UCOP Implementation Plan for Compliance with Business and Finance Bulletin
More informationGOCO.IO, INC TERMS OF SERVICE
GOCO.IO, INC TERMS OF SERVICE GoCo.io, Inc. ("GoCo", the "Site", "https://www.goco.io") welcomes you! GoCo provides services to you subject of the following terms of service (the "Agreement"). The Agreement
More informationTop Five Privacy and Data Security Issues for Nonprofit Organizations
Top Five Privacy and Data Security Issues for Nonprofit Organizations Julia K. Tama, Esq. Jeffrey S. Tenenbaum, Esq. Association of Corporate Counsel Nonprofit Organizations Committee Legal Quick Hit MAY
More information01.0 Policy Responsibilities and Oversight
Number 1.0 Policy Owner Information Security and Technology Policy Policy Responsibility & Oversight Effective 01/01/2014 Last Revision 12/30/2013 Department of Innovation and Technology 1. Policy Responsibilities
More informationBreaches and Remediation
Breaches and Remediation Ramona Oliver US Department of Labor Personally Identifiable Information Personally Identifiable Information (PII): Any information about an individual maintained by an agency,
More informationBYOD (Bring Your Own Device): Employee-owned Technology in the Workplace
BYOD (Bring Your Own Device): Employee-owned Technology in the Workplace MCHRMA Spring Conference April 4, 2014 PRESENTED BY: Sonya Guggemos MCIT Staff Counsel for Risk Control sguggemos@mcit.org The information
More informationDATA PROTECTION LAWS OF THE WORLD. United States
DATA PROTECTION LAWS OF THE WORLD United States Downloaded: 10 December 2017 UNITED STATES Last modified 25 January 2017 LAW The United States has about 20 sector specific or medium-specific national privacy
More informationDeMystifying Data Breaches and Information Security Compliance
May 22-25, 2016 Los Angeles Convention Center Los Angeles, California DeMystifying Data Breaches and Information Security Compliance Presented by James Harrison OM32 5/25/2016 3:00 PM - 4:15 PM The handouts
More informationSample BYOD Policy. Copyright 2015, PWW Media, Inc. All Rights Reserved. Duplication, Reproduction or Distribution by Any Means Prohibited.
Sample BYOD Policy Copyright 2015, PWW Media, Inc. All Rights Reserved. Duplication, Reproduction or Distribution by Any Means Prohibited. SAMPLE BRING YOUR OWN DEVICE POLICY TERMS OF USE This Sample Bring
More informationSANMINA CORPORATION PRIVACY POLICY. Effective date: May 25, 2018
SANMINA CORPORATION PRIVACY POLICY Effective date: May 25, 2018 This Privacy Policy (the Policy ) sets forth the privacy principles that Sanmina Corporation and its subsidiaries (collectively, Sanmina
More informationManaging Cybersecurity Risk
Managing Cybersecurity Risk Maureen Brundage Andy Roth August 9, 2016 Managing Cybersecurity Risk Cybersecurity: The Current Legal and Regulatory Environment Cybersecurity Governance: Considerations for
More informationUpdate on Administration and Enforcement of the HIPAA Privacy, Security, and Breach Notification Rules
Update on Administration and Enforcement of the HIPAA Privacy, Security, and Breach Notification Rules Wandah Hardy, RN BSN, MPA Equal Opportunity Specialist/Investigator Office for Civil Rights (OCR)
More informationSocial Media and Texting: A Growing Concern
Social Media, Care Providers Texting: How Do You Protect PHI? HCCA Compliance Institute Monday, April 18, 2016 Presented By: Donna Thiel, VP & CCO, Fortis Management Group, LLC Craig Day, Esq., Lane Powell
More informationHIPAA Privacy and Security. Rochelle Steimel, HIPAA Privacy Official Judy Smith, Staff Development January 2012
HIPAA Privacy and Security Rochelle Steimel, HIPAA Privacy Official Judy Smith, Staff Development January 2012 Goals and Objectives Course Goal: Can serve as annual HIPAA training for physician practice
More informationIDENTITY THEFT PREVENTION Policy Statement
Responsible University Officials: Vice President for Financial Operations and Treasurer Responsible Office: Office of Financial Operations Origination Date: October 13, 2009 IDENTITY THEFT PREVENTION Policy
More informationHIPAA Privacy and Security Training Program
Note The following HIPAA training is intended for Vendors, Business Associates, Students, Pre Approved Shadowers, and Visitors. The following training module does not provide credit for annual training
More informationPrivacy Policy on the Responsibilities of Third Party Service Providers
Privacy Policy on the Responsibilities of Third Party Service Providers Privacy Office Document ID: 2489 Version: 3.2 Owner: Chief Privacy Officer Sensitivity Level: Low Copyright Notice Copyright 2016,
More informationHIPAA Federal Security Rule H I P A A
H I P A A HIPAA Federal Security Rule nsurance ortability ccountability ct of 1996 HIPAA Introduction - What is HIPAA? HIPAA = The Health Insurance Portability and Accountability Act A Federal Law Created
More informationShaw Privacy Policy. 1- Our commitment to you
Privacy Policy last revised on: Sept 16, 2016 Shaw Privacy Policy If you have any questions regarding Shaw s Privacy Policy please contact: privacy@shaw.ca or use the contact information shown on any of
More informationBaseline Information Security and Privacy Requirements for Suppliers
Baseline Information Security and Privacy Requirements for Suppliers INSTRUCTION 1/00021-2849 Uen Rev H Ericsson AB 2017 All rights reserved. The information in this document is the property of Ericsson.
More informationWhat to do if your business is the victim of a data or security breach?
What to do if your business is the victim of a data or security breach? Introduction The following information is intended to help you decide how to start preparing for and some of the steps you will want
More informationAgenda. Hungry, Hungry HIPAA: Security, Enforcement, Audits, & More. Health Law Institute
Health Law Institute Hungry, Hungry HIPAA: Security, Enforcement, Audits, & More Brooke Bennett Aziere October 18, 2017 Agenda Enforcement Trends Phase 2 HIPAA Audits Upcoming Initiatives 1 Enforcement
More informationHIPAA Security and Privacy Policies & Procedures
Component of HIPAA Security Policy and Procedures Templates (Updated for HITECH) Total Cost: $495 Our HIPAA Security policy and procedures template suite have 71 policies and will save you at least 400
More informationChecklist: Credit Union Information Security and Privacy Policies
Checklist: Credit Union Information Security and Privacy Policies Acceptable Use Access Control and Password Management Background Check Backup and Recovery Bank Secrecy Act/Anti-Money Laundering/OFAC
More informationInformation Technology Standards
Information Technology Standards IT Standard Issued: 9/16/2009 Supersedes: New Standard Mobile Device Security Responsible Executive: HSC CIO Responsible Office: HSC IT Contact: For questions about this
More information