Steps to achieve HIPAA compliance for your SaaS Company
In edition #9 of All Things AppSec we looked at everything you need to prepare for HIPAA compliance as a SaaS vendor. This included where you would fall under HIPAA as a SaaS vendor and the different requirements for compliance.
This week we will take a look at the steps required to achieve HIPAA compliance as a SaaS company. Without any further delay, let’s dive in.
Steps to achieve your SaaS HIPAA compliance
Here’s a 6-step checklist that SaaS companies need to take to achieve HIPAA compliance:
Protect the right types of patient data
The first step in putting appropriate security and privacy precautions in place is to be aware of the types of patient data that must be protected.
To know if you are protecting the right kind of data, you must understand what constitutes PHI. The HIPAA Privacy Rule defines PHI as “individually identifiable health information” stored or transmitted by a covered entity or its business associates. The patient data to be protected generally includes but is not limited to:
Names
Dates related to birth and death
Medical record numbers
Photographs and other images
Fingerprints
Other forms of unique identification
Implement safeguards
PHI or ePHI needs secure storage and cannot be kept just about anywhere. Safeguards are required to protect patient data like using encryption, multi-factor authentication, access control, etc. This includes:
Technical safeguards - All hardware, software, and other technology units should be safeguarded.
Physical safeguards - Access to physical facilities that store PHI should be controlled.
Administrative safeguards - Security management processes must be documented and risks to PHI must be analyzed.
Policies and procedures must be established for security incidents.
Conduct periodic risk assessments
This involves identifying potential risks and vulnerabilities to patient data in your SaaS application and evaluating the impact.
Risk analysis should be a continuous process even after you achieve HIPAA compliance. All administrative and technological policies should be covered by your audits and any identified gaps or weaknesses should be addressed promptly.
Periodic inspections and corrections based on these are the only way to maintain compliance.
Have business associate agreements in place
A majority of SaaS companies are classified as a business associate under HIPAA regulations. You’ll need to ensure that you sign Business Associate Agreements (BAAs) with your clients and subcontractors who have access to ePHI.
A BAA outlines the responsibilities of both parties in safeguarding ePHI and the following considerations are particularly relevant:
Identify all parties handling ePHI
Specify the services provided
Define security obligations
Define breach notification procedures
Termination terms and return & destruction of ePHI
Prevent potential HIPAA violations
HIPAA violations can happen in a variety of ways. Internal violations are the most frequent sort of infraction, not data breaches or hacks by outside parties.
Most privacy rule infractions are the result of carelessness or partial adherence. Staff members should be trained on HIPAA rules and security policies and procedures.
This helps avoid unintentional disclosures of PHI and thus prevents violations. Take basic steps such as recognizing common violations, and understand, anticipate, and prepare for breaches.
Maintain proper documentation & stay updated on HIPAA changes
Compiling all HIPAA-related material and being open about your policies is an essential practice. In general, you should keep records of everything involving PHI. The records containing PHI or the guidelines for exposing PHI must be kept for a minimum of six years.
The records should generally include:
Policies and procedures
Copies of all communication within the organization
Any tasks, decisions, or titles that call for keeping records in writing or electronically
Policies and procedures must be reviewed and updated as needed to maintain compliance with changes in HIPAA regulations. Even though you may have reached HIPAA compliance at present, it’s imperative to monitor for new updates and ensure you comply when it arrives.
Ensuring compliance with HIPAA need not be a huge headache or expense for your organization. Beagle Security helps healthcare SaaS companies in their HIPAA journey with HIPAA compliant penetration test reports.
You can keep a check on your SaaS application’s security posture and easily integrate a continuous security testing approach in your SDLC to find vulnerabilities and ensure compliance with HIPAA. More on that here if you’d like to have a look.
That’s a wrap for today’s newsletter. Hope you’ve understood the main steps that needs to be taken to achieve HIPAA compliance as a SaaS company. See you again next week!