Skip to content

Latest commit

 

History

History
35 lines (27 loc) · 3.76 KB

03-policy_management_policy.md

File metadata and controls

35 lines (27 loc) · 3.76 KB

3. Policy Management Policy

Wally implements policies and procedures to maintain compliance and integrity of data. The Security Officer and Privacy Officer are responsible for maintaining policies and procedures and assuring all Wally workforce members, business associates, customers, and partners are adherent to all applicable policies. Previous versions of policies are retained to assure ease of finding policies at specific historic dates in time.

3.1 Applicable Standards

3.1.1 Applicable Standards from the HITRUST Common Security Framework

  • 12.c - Developing and Implementing Continuity Plans Including Information Security

3.1.2 Applicable Standards from the HIPAA Security Rule

  • 164.316(a) - Policies and Procedures
  • 164.316(b)(1)(i) - Documentation

3.2 Maintenance of Policies

  1. All policies are stored and updated to maintain Wally compliance with HIPAA, HITRUST, NIST, and other relevant standards. Updates and version control are done similarly to source code control.
  2. Policy update requests can be made by any workforce member at any time. Furthermore, all policies are reviewed annually by both the Security and Privacy Officer to assure they are accurate and up-to-date.
  3. Wally employees may request changes to policies using the following process:
  4. The Wally employee initiates a policy change request by creating a ticket in the QMS. The change request may optionally include a GitHub pull request from a separate branch or repository containing the desired changes.
  5. The Security Officer or the Privacy Officer is assigned to review the policy change request.
  6. Once the review is completed, the Security Officer or Privacy Officer approves or rejects the ticket. If the ticket is rejected, it goes back for further review and documentation.
  7. If the review is approved, the Security Officer or Privacy Officer then marks the ticket as Done, adding any pertinent notes required.
  8. If the policy change requires technical modifications to production systems, those changes are carried out by authorized personnel using Wally's change management process (§9.4).
  9. All policies are made accessible to all Wally workforce members. The Security Officer communicates policy changes to all employees via email. These emails include a high-level description of the policy change using terminology appropriate for the target audience.
  10. All policies, and associated documentation, are retained for 6 years from the date of its creation or the date when it last was in effect, whichever is later. Version history of all Wally policies is done via GitHub.
  11. The policies and information security policies are reviewed and audited annually, or after significant changes occur to Wally's organizational environment. Tickets that come up as part of this process are reviewed by Wally management to assure all risks and potential gaps are mitigated and/or fully addressed. The process for reviewing polices is outlined below:
  12. The Security Officer initiates the policy review by creating a ticket in the QMS.
  13. The Security Officer or the Privacy Officer is assigned to review the current Wally policies.
  14. If changes are made, the above process is used. All changes are documented in the ticket.
  15. Once the review is completed, the Security Officer or Privacy Officer approves or rejects the ticket. If the ticket is rejected, it goes back for further review and documentation.
  16. If the review is approved, the Security Officer or Privacy Officer then marks the ticket as Done, adding any pertinent notes required.
  17. Policy review is monitored on a quarterly basis using the QMS reporting to assess compliance with above policy. Additional documentation related to maintenance of policies is outlined in §5.3.1.