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Authentication |
§164.312 Technical Safeguards.
(d) Standard: Person or entity authentication. Verify person / entity seeking access to electronic protected health information is the one claimed. |
- Unique user IDs
- Access is restricted by e-mail address
- Email address validation is required through the use of a confirmation link
- All passwords are encrypted during client-server communications and when accessing the website using a web browser or mobile device
- Ability to enforce strong password / master password creation
- Users are able to change their password
- Passwords can be reset but not recovered
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Access Control |
§164.312 Technical Safeguards
(a)(1)Standard: Access control. Allow access only to those persons or software programs that have been granted access rights.
(a)(2)(i)Unique user identification (Required). Assign a unique name and/or number for identifying and tracking user identity.
(a)(2)(iii)Automatic logoff (Addressable). Terminate an electronic session after a predetermined time of inactivity.
(a)(2)(iv) Encryption and decryption (Addressable). Encrypt/decrypt electronic protected health information. |
- Administrative SoD (Separation of Duties) with multiple levels of access control and administrator privileges
- Administrators cannot access accounts of other administrators
- Administrators can set disk space, maximum file storage, and maximum bandwidth or users, user groups, or sites
- Option to require strong / master password for all file transfers
- All files are automatically deleted after a configurable time period
- Option to restrict the number of times a file can be downloaded
- Restrict ability to send files by user, group, email address domain, or site
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Privacy |
§164.312 Technical Safeguards
(e)(1) Standard: Transmission Security
(e)(2)(ii) Encryption (Addressable). Encrypt electronic protected health information (that is being transmitted) |
- User IDs and passwords are always encrypted
- All uploads and downloads are transmitted on an encrypted SSL connection; no exceptions
- All data is encrypted before it is committed to disk
- Passwords are never transmitted unless over a secure, encrypted connection
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Integrity |
(c)(1)Standard: Integrity. Protect electronic health information from improper alteration or destruction.
(c)(2) Implementation specification: Mechanism to authenticate electronic protected health information (Addressable). Implement electronic mechanisms to corroborate that electronic protected health information has not been altered or destroyed in an unauthorized manner.
(e)(2)(i) Integrity controls (in transmission) (Addressable). Ensure that electronically transmitted electronic protected health information is not improperly modified without detection until disposed of. |
- All data is stored in an encrypted format. Tampering with the data effectively destroys the data. Files protected by a strong / master password use a custom encryption key known only to the file sender. Files sent with a strong / master password can not be opened or modified by any SendToPerson.com staff
- All access to the system is captured in detailed logs and is monitored
- Pysical access to hardware is restricted and physical access is guarded 24 hours per day, 7 days per week including holidays
- Administrators do not have access to user data
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Availability |
§164.308(a)(7)(ii) Administrative Safeguards
(a) Data backup plan (Required). Establish and implement procedures to create and maintain retrievable exact copies of electronic protected health information.
(b) Disaster recovery plan (Required). Establish (and implement as needed) procedures to restore any loss of data.
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- Database backups are performed on all servers at least once daily
- Database backups are stored on a separate hardware appliance, on site, with physical access security safeguards in place and fire retardant protection
- Uploaded files are not included in backups. In the event of a hardware failure, uploaded files may not be recoverable. Files sent using the service are intended to be copies in transit, that are always scheduled for automatic deltion; SendToPerson.com is not a file storage service and your files may be deleted at any time for security and privacy purposes
- Hardware is monitored 24 hours per day, 7 days per-week to ensure service availability
- Redundant hardware and telecommunications systems are in place to ensure that under all circumstances service can be restored within four hours or less
- Disaster recovery plans are in place to notify system administrators, replace failed or damaged equipment, and restore backups at any time of day or night
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Audit |
§164.312 Technical Safeguards
(b) Standard: Audit controls. Implement hardware, software, and/or procedural mechanisms that record and examine activity in information systems that contain or use electronic protected health information.
§164.308 Administrative Safeguards
(a)(5)(ii)(c) Log-in monitoring (Addressable). Procedures for monitoring log-in attempts and reporting discrepancies. |
- Client-Server Logging: Capture Client-Server connectionsa nd activities related to the storage and transfer of files
- Web browser access logging: Collect detailed records of all user's activities and access to the system, including the upload and download of files
- Logs are included in and protected by backup and redundancy systems
- Detailed reporting is available of all system activity, and can be filtered by user, site, or email domain name
- All attempts to access the system (success or failure) are recorded along with details such as IP address and web browser details
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