FlowTrack shall audit, monitor, and assess the access and activity of systems and applications that process or store production and/or sensitive data such as personally identifiable information (PII) and electronic protected health information (ePHI) in order to ensure compliance.
It is required by the HIPAA Security Rule, that healthcare organizations to implement reasonable hardware, software, and/or procedural mechanisms that record and examine activity in information systems that contain or use ePHI.
Audit activities may be limited by application, system, and/or network auditing capabilities and resources. FlowTrack shall make reasonable and good-faith efforts to safeguard information privacy and security through a well-thought-out approach to auditing that is consistent with available resources.
It is the policy of FlowTrack to safeguard the confidentiality, integrity, and availability of applications, systems, and networks. To ensure that appropriate safeguards are in place and effective, FlowTrack shall audit access and activity to detect, report, and guard against:
This policy applies to all FlowTrack systems that store, transmit, or process sensitive information.
FlowTrack policy requires that:
(a) All critical computing systems and software, both virtual and physical, must enable audit logging.
(b) Audit logs must include sufficient information to identify who did what, when, where.
(c) An annual audit of FlowTrack security controls must be conducted, either by a designated internal audit team or a qualified external audit firm.
FlowTrack's auditing processes include the following.
Configuration and Activity Monitoring: This refers to the logging, monitoring, scanning and alerting of a system, account, or environment, which may be achieved using real-time automated scripts/software or a manual review/testing. This type of auditing is performed continuously as part of FlowTrack operations.
tip "Examples include:"
Data associated with above events will include origin, destination, action performed, timestamp, and other relevant details available.
Access Review: This refers to the review of all user and service accounts and permissions across FlowTrack operational environments, including on-premise systems, cloud environments such as AWS accounts, and other applications such as collaboration software, ticketing system and code repos.
Compliance and Controls Audit: This refers to the audit performed against the Technical, Administrative, and/or Physical controls as defined in FlowTrack policies and procedures, to measure their adoption and effectiveness. This type of auditing is typically performed by either a designated internal audit person/team or an external audit firm, at defined intervals or prompted by a trigger event.
tip "Potential trigger events include:"
Security logs, events, and audit trails are reviewed by the security team with the assistance of automated systems and processes.
Additional manual reviews, such as user accounts and access auditing, may be necessary from time to time. These activities may be triggered by the events listed above.
Responsibility for audit activity is assigned to FlowTrack's Security Officer. The Security Officer shall:
The manual review process shall define and include:
Manual audits and reviews activities are tracked in Jira.
Auditing, reviews and testing may be carried out internally or provided through an external third-party vendor. Whenever possible, a third party auditing vendor should not be providing the organization IT oversight services (e.g., vendors providing IT services should not be auditing their own services to ensure separation of duties).
A request may be made for an audit for a specific cause. The request may come from a variety of sources including, but not limited to, Privacy Officer, Security Officer, Customer, Partner, or an Application owner or application user.
A request for an audit for specific cause must include time frame, frequency, and nature of the request.
A request for an audit must be reviewed and approved by FlowTrack's Privacy Officer and/or Security Officer before proceeding. Under no circumstances shall detailed audit information be shared with parties without proper permissions and access to see such data.
Audit information that is routinely gathered must be reviewed in a timely manner, at least monthly, by the responsible workforce member(s). Additional reviews are performed as needed to assure the proper data is being captured and retained.
The reporting process shall allow for meaningful communication of the audit findings to relevant workforce members, Customers, or Partners.
Reports of audit results shall be limited to internal use on a minimum necessary/need-to-know basis. Audit results shall not be disclosed externally without administrative and/or legal counsel approval.
Security audits constitute an internal, confidential monitoring practice that may be included in FlowTrack's performance improvement activities and reporting. Care shall be taken to ensure that the results of the audits are disclosed to administrative-level oversight structures only and that information which may further expose organizational risk is shared with extreme caution. Generic security audit information may be included in organizational reports (individually-identifiable information shall not be included in the reports).
Whenever indicated through evaluation and reporting, appropriate corrective actions must be undertaken. These actions shall be documented and shared with the responsible workforce members, Customers, and/or Partners.
Many controls are continuously monitored and reported via automation on the AWS platform.
Control deficiencies identified as a result of an internal or external system audit are documented and reviewed with management.
Security team works with the corresponding control owner to prioritize and mitigate the control deficiency, including applying corrective actions, implementating additional controls or adjusting existing controls as needed.
FlowTrack logging standards requires application and system logs to contain sufficient information to determine who did what, when, where to ensure recording of security and audit events and to generate evidence for unauthorized activities.
All systems and software developed at FlowTrack must have the following security events logging enabled as part of or in addition to standard application logging.
All security log events must have the following attributes at minimum:
The following types of security events must be logged at minimum:
All application and system logs must not include (removed or masked):
Any sensitive information, including protected health information (PHI), personally identifiable information (PII)
Authentication and session tokens, user credentials
Security events and audit logs must be:
All FlowTrack IT infrastructure must have system clock synchronized
Examples of recommended application events for logging and their auditing purpose:
|Client requests and server responses||forensics and debugging - details level is defined by application|
|Successful and unsuccessful login attempts||authentication|
|Successful and failed access to application resources||authorization, escalation of privileges|
|Excessive amount of requests from the client||brute-forcing, malicious bots, denial of service attacks|
|E-mails sent by an application||spamming, social engineering|
Details of the logging configuration is documented at
Audit logs shall be protected from unauthorized access or modification, so the information they contain will be made available only if needed to evaluate a security incident or for routine audit activities as outlined in this policy.
All audit logs are protected in transit and encrypted at rest to control access to the content of the logs.
Whenever possible, audit logs shall be stored on a separate system to minimize the impact auditing may have on the privacy system and to prevent access to audit trails by those with system administrator privileges.
Reports summarizing audit activities shall be retained for a period of seven years.
Audit log data is retained locally on the audit log server or in the source environment for a period of one month. Beyond that, log data is encrypted and moved to warm storage (currently S3) using automated scripts, and is retained for a minimum of one year.
Raw event data may be purged after one month / 30 days as long as the required details are sufficiently covered in aggregated audit logs/reports.
Periodic monitoring of Customer and Partner activity shall be carried out to ensure that access and activity is appropriate for privileges granted and necessary to the arrangement between FlowTrack and the 3rd party. FlowTrack will make every effort to assure Customers and Partners do not gain access to data outside of their own environments.
If it is determined that the Customer or Partner has exceeded the scope of access privileges, FlowTrack's management and security must remedy the problem immediately.
If it is determined that a Customer or Partner has violated the terms of the HIPAA business associate agreement or any terms within the HIPAA regulations, FlowTrack must take immediate action to remediate the situation. Continued violations may result in discontinuation of the business relationship.
FlowTrack's Security Officer is authorized to select and use assessment tools that are designed to detect vulnerabilities and intrusions. Use of such tools against FlowTrack systems and environments are prohibited by others, including Customers and Partners, without the explicit authorization of the Security Officer. These tools may include, but are not limited to:
Vulnerability testing software may be used to probe the network to identify what is running (e.g., operating system or product versions in place), whether publicly-known vulnerabilities have been corrected, and evaluate whether the system can withstand attacks aimed at circumventing security controls.
FlowTrack workforce members are provided training, education, and awareness on safeguarding the privacy and security of business and data. FlowTrack's commitment to auditing access and activity of the information applications, systems, and networks is communicated through new employee orientation, ongoing training opportunities and events, and applicable policies. FlowTrack workforce members are made aware of responsibilities with regard to privacy and security of information as well as applicable sanctions/corrective disciplinary actions should the auditing process detect a workforce member's failure to comply with organizational policies.
FlowTrack Customers are provided with necessary information to understand FlowTrack auditing capabilities. Platform Customers are responsible for the logging, auditing and retention of any application hosted outside of FlowTrack environments, even though the applications may integrate with FlowTrack Platform API. Customer applications hosted within the FlowTrack environments will follow the auditing standards and procedures defined in this document.
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