1. Inventory of PHI.
Compile a comprehensive list of all PHI stored, processed, or transmitted, including electronic and physical formats.
2. Identification of Potential Threats and Vulnerabilities.
Identify and document potential risks and vulnerabilities to PHI, considering both internal and external sources.
3. Security Measures Evaluation.
Assess current security measures in place to protect PHI against identified risks and vulnerabilities.
4. Risk Level Determination.
Determine the level of risk for each identified threat and vulnerability, taking into account the likelihood and impact.
5. Documentation and Analysis of Security Incidents.
Establish a process for documenting and analyzing security incidents to improve future risk management.
6. Review of Employee Access to PHI.
Regularly review and modify employee access rights to PHI, ensuring minimum necessary access for job functions.
7. Assessment of Physical Security Controls.
Evaluate the physical security measures in place to protect PHI, including facility access controls.
8. Evaluation of Technical Security Measures.
Assess technical safeguards such as encryption, firewalls, and intrusion detection systems to protect electronic PHI.
9. Compliance with Privacy and Security Policies.
Review and ensure adherence to organizational privacy and security policies and procedures.
10. Continuity Plan for Emergency Situations.
Develop and test a continuity plan to ensure PHI protection and access during emergencies.