Facility Access and Physical Security

2020.1

It is the goal of FlowTrack to provide a safe and secure environment for all employees. Access to the FlowTrack facilities is limited to authorized individuals only.

FlowTrack works with Subcontractors (e.g. property management companies and facilities management) to assure restriction of physical access to systems used as part of the FlowTrack Platform.

Physical Access to all of FlowTrack facilities is limited to only those authorized in this policy. All workforce members are responsible for reporting an incident of unauthorized visitor and/or unauthorized access to FlowTrack's facility.

FlowTrack and its Subcontractors control access to the physical buildings/facilities that house these systems/applications, or in which FlowTrack workforce members operate, in accordance to the HIPAA Security Rule 164.310 and its implementation specifications. In an effort to safeguard ePHI from unauthorized access, tampering, and theft, access is allowed to areas only to those persons authorized to be in them and with escorts for unauthorized persons.

Policy Statements

FlowTrack policy requires that

(a) Physical access to any FlowTrack facilities are restricted.

(b) All employees are required to wear employee badges at secure facilities (such as server rooms, data centers, labs).

(c) All employees must follow physical security requirements and procedures documented by facility management.

(d) On-site visitors and vendors must be escorted by a FlowTrack employee at all times while on premise.

(e) All workforce members are responsible for reporting an incident of unauthorized visitor and/or unauthorized access to FlowTrack's facility.

(f) Retain a record for each physical access, including visits, maintenance and repairs to FlowTrack production environments and secure facilities.

  • Details must be captured for all maintenance and repairs performed to physical security equipment such as locks, walls, doors, surveillance cameras; and
  • All records must be retained for a minimum of seven years.

(g) Building security, such as fire extinguishers and detectors, escape routes, floor warden responsibilities, shall be maintained according to applicable laws and regulations.

Controls and Procedures

Physical Security

Access Requirements Overview

Applies only during and as long as FlowTrack maintains physical Facilities and Offices

  • Physical access is restricted using badge readers and/or smart locks that track all access.

    • Restricted areas and facilities are locked when unattended (where feasible).
    • Only authorized workforce members receive access to restricted areas (as determined by the Security Officer).
    • Access and keys are revoked upon termination of workforce members.
    • Workforce members must report a lost and/or stolen key(s) or badge(s) to his/her manager, local Site Lead, or the Facility Manager.
    • The Facility Manager or designee is responsible to revoke access to the lost/stolen badge(s) or access key(s), and re-provision access as needed.
    • The Facility Manager or designee facilitates the changing of the lock(s) within 7 days of a physical key being reported lost/stolen.
  • Enforcement of Facility Access Policies

    • Report violations of this policy to the restricted area's department team leader, supervisor, manager, or director, or the Privacy Officer.
    • Workforce members in violation of this policy are subject to disciplinary action, up to and including termination.
    • Visitors in violation of this policy are subject to loss of vendor privileges and/or termination of services from FlowTrack.
  • Workstation Security

    • Workstations may only be accessed and utilized by authorized workforce members to complete assigned job/contract responsibilities.
    • All workforce members are required to monitor workstations and report unauthorized users and/or unauthorized attempts to access systems/applications as per the System Access Policy.
    • All workstations purchased by FlowTrack are the property of FlowTrack and are distributed to users by the company.

Building Standards per Location

Applies only during and as long as FlowTrack maintains physical Facilities and Offices

All entry points for physical comercial offices are secured by card readers and have cameras for additional monitoring as needed. Each facility shall contain;

  • Facility Access Data Storage Policies
  • Facility Access Control Process
  • Maintenance & Repairs Policies for Access Control Systems
  • Reporting and Auditing of Access Control Systems
  • Special Access Requests Policy
  • New Hire Access Control Activation Policy
  • Seperation Access Control Activation Policy

Data Center Security

Physical security of data centers is ensured by the cloud infrastructure service provided, AWS.

Clean Desk Policy and Procedures

Employees must secure all sensitive/confidential information in their workspace at the conclusion of the work day and when away from their workspace. This includes both electronic and physical information such as:

  • computer workstations, laptops, and tablets
  • removable storage devices including CDs, DVDs, USB drives, and external hard drives
  • printed materials

Computer workstations/laptops must be locked (password protected) when physically unattended. Portable devices such as laptops and tablets should be taken home at the conclusion of the work day.

Removable storage devices and printed documents must be treated as sensitive material and locked in a drawer or similar when not in use. Printed materials must be immediately removed from printers or fax machines. Passwords must not be written down or stored physically.

Keys and access cards used for access to sensitive or restricted information/areas must not be left unattended anywhere in the office.