Healthcare Code of Conduct

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Full Title or Meme

In Healthcare Identity Management a Code of Conduct applies to those software elements that handle the Patient Health Information.





  • There are two categories, large and small organizations. The small guys get series of passes.
  • There are a series of fact sheets as summarized below. These all include something that looks like assessment criteria except for the first.
    • the actors in a healthcare covered entity.
    • There shall be a security management system where PHI is present.
    • Procedures must be inlace before processing PHI.
    • Security Audits shall be conducted at least annually.
    • Risk assessments must be carried out prior to operations, including any change that may impact security.
    • External data processors must agree to follow and report on compliance with regulations.
    • Access control appears to be granted based on the purpose of access. It seems to be up to each organization to create the purposes or roles. (RBAC?)
    • Incident registration and followup shall be inlace before PHI is collected and patient shall have access. Notice does not appear to be required.
    • Message communications are subject to national standards - which might be HL7 formats. not clear. It is called ebXML (which goes back to ANSI X12 EDI) and utilized a national ID.
    • Agreeing to research
    • Remote Acces to suppliers must respect confidentiality and integrity, etc.
    • Security seems to be homegrown. No international standards.
    • Infosec in research.
    • If PHI is accidentally disclose, try to limit the damage and stop any continuing release of PHI.
    • Test data seems to imply that real data is used and then destroyed. No indication if test data will be created that is not from live patients.
    • Register of authorizations sound like an RBAC registry that also logs access and roles by user. Somehow this data is to be compared with other registries to create security incidents.
    • Testing is agains describe as though real data is used in testing rather than dummy data.
    • PKI is assumed in use for signing, authentication and encryption.
    • Patient access to incident register. There are held by the data controller. It is not clear where the patient needs to go to access these registers.