KNAVCPA is committed to conducting business in compliance with all applicable laws, regulations, and policies. KNAVCPA has adopted this policy to outline the security measures required to protect electronic information systems and related equipment from unauthorized use.
The goal of these policies is to protect Information System and other protected information such as individually identifying information by enhancing the security of our electronic information systems. KNAVCPA requires securing Information System contained on all mobile media, laptops, workstations, servers, and external hosted sites that are not located in Approved Secure Data Centers. Approved Secure Data Centers are defined as data centers that have had a formal risk assessment on the physical and logical controls completed by the Information Security Office and the Internal Audit Office with no findings that would render the data center unsecured.
These policies and guidelines apply to all workforce members who use, collect and/or access information. These policies and guidelines apply to all KNAVCPA owned and personal electronic devices that are connected to KNAVCPA networks and receive, store or transmit personal information. This policy does not cover text pagers or basic voice / SMS text cell phones.
- Encryption: the process of converting data to an unrecognizable or “encrypted” form.
- Personal Identifiable Information (PII): Individually identifiable information transmitted or maintained in any form.
- Workforce Member: Employees, volunteers (board members, community representatives), trainees (students), contractors and other persons whose conduct, in the performance of work for a covered entity, is under the direct control of such entity, whether or not they are paid by the covered entity.
- The Security Officer will provide appropriate workforce members with training and awareness regarding encryption methods implemented to protect PII from unauthorized alteration or destruction during transmission over electronic communications networks.
- All PII will be encrypted, whether at rest or in transmission, where a risk analysis indicates that such encryption is necessary to protect the security of PII.
- Such risk analysis shall consider the probability and criticality of risks to security.
- All electronic devices that receive, store and/or transmit PII and are not located in an Approved Secure Data Center must use approved encryption methods to secure the information stored on or transmitted outside the secure clinical network.
- Servers that are not located in an Approved Secure Data Center are required to have all information stores of PII encrypted.
- PII contained on laptops or workstations are required to be either File, Folder or Full Disk Encrypted.
- Any and all mobile devices (smart phones and tablets) that connect to the secure clinical network that may contain or transmit PII (through e-mail) are required to accept Information Security Standards to encrypt and protect the devices.
- External storage media (backup tapes, removable drives, etc) will need to have the PII encrypted.
- Files that contain PII transmitted across the Internet (e-mail attachments sent outside network, or file transfers to other entities) will need to have the attachments encrypted or use an approved secure encryption method to deliver the information.
Existing systems and applications containing Protected Information which cannot use encryption because of a technological limitation, but have compensating controls, may be granted a special exception by the Security Officer. However, these systems and applications will be required to have a formal risk assessment performed by the Security Officer to ensure that major risks are addressed via compensating controls to protect the data in lieu of encryption. Exceptions will be reviewed periodically and removed when a suitable solution is available.
Any known violations of this policy should be reported to the Security Officer. Violations of this policy can result in immediate withdrawal or suspension of system and network privileges and/or disciplinary action in accordance with KNAVCPA procedures.
KNAVCPA may advise law enforcement agencies when a criminal offense may have been committed.