Information Security Policy

Executive Summary

FHIR IQ is committed to maintaining the highest standards of information security to protect our clients, partners, and stakeholders. This Information Security Policy establishes the framework for securing all information assets, systems, and data under FHIR IQ's control.

This policy applies to all employees, contractors, consultants, temporary staff, and other workers at FHIR IQ, including all personnel affiliated with third parties who have access to FHIR IQ systems and data.

1. Purpose and Scope

1.1 Purpose

The purpose of this Information Security Policy is to:

• Protect the confidentiality, integrity, and availability of information assets
• Ensure compliance with applicable laws, regulations, and contractual obligations
• Minimize security risks and prevent unauthorized access to information
• Establish clear roles and responsibilities for information security
• Provide a framework for responding to security incidents
• Support business continuity and disaster recovery efforts

1.2 Scope

This policy applies to:

• All information assets owned or managed by FHIR IQ
• All information systems, networks, and infrastructure
• All physical and electronic data, including client data and healthcare information
• All locations where FHIR IQ conducts business
• All personnel with access to FHIR IQ systems and data
• Third-party service providers and business partners

2. Information Security Governance

2.1 Security Roles and Responsibilities

2.2 Policy Review and Updates

This policy is reviewed annually and updated as needed to address emerging threats, regulatory changes, and business requirements. All policy changes are approved by executive management.

3. Information Classification and Handling

3.1 Data Classification

3.2 Data Handling Requirements

• Critical/Confidential data must be encrypted in transit and at rest
• Access to sensitive data requires authentication and authorization
• Data must be transmitted using secure protocols (HTTPS, SFTP, etc.)
• Sensitive data disposal must use approved secure deletion methods
• Physical documents containing sensitive data must be securely stored and shredded when disposed

4. Access Control and Authentication

4.1 User Access Management

• Access is granted based on the principle of least privilege
• All user accounts require unique credentials
• Multi-factor authentication (MFA) is required for all system access
• Access rights are reviewed quarterly and upon role changes
• Terminated employee access is revoked within 24 hours
• Shared accounts and generic credentials are prohibited

4.2 Password Requirements

• Minimum 12 characters in length
• Combination of uppercase, lowercase, numbers, and special characters
• Password changes required every 90 days
• No reuse of previous 12 passwords
• Account lockout after 5 failed login attempts
• Use of password managers is encouraged

4.3 Privileged Access Management

Administrative and privileged accounts require enhanced security controls, including separate credentials, additional monitoring, and justification for access requests.

5. Network and System Security

5.1 Network Security Controls

• Network segmentation to isolate sensitive systems
• Firewall protection at network perimeters
• Intrusion detection and prevention systems (IDS/IPS)
• Regular network vulnerability scanning
• Secure configuration of network devices
• VPN required for remote access

5.2 Endpoint Security

• Anti-malware software on all endpoints
• Operating system and application patches applied within 30 days
• Full-disk encryption on laptops and mobile devices
• Automatic screen lock after 10 minutes of inactivity
• Approved software whitelist enforcement

5.3 Cloud and Third-Party Services

• Security assessment required before cloud service adoption
• Data encryption for data stored in cloud services
• Regular review of cloud security configurations
• Vendor security certifications verified (SOC 2, ISO 27001)

6. Data Protection and Privacy

6.1 Healthcare Data Protection

FHIR IQ handles Protected Health Information (PHI) and healthcare-related data with the highest level of security:

• HIPAA compliance for all PHI handling activities
• Encryption of PHI in transit (TLS 1.2 or higher) and at rest (AES-256)
• Audit logging of all PHI access and modifications
• Business Associate Agreements (BAA) with all relevant vendors
• Regular HIPAA Security Rule compliance assessments
• De-identification procedures following HIPAA Safe Harbor method

6.2 Data Backup and Recovery

• Daily automated backups of critical systems and data
• Encrypted backup storage in geographically diverse locations
• Quarterly backup restoration testing
• 30-day retention for daily backups
• 12-month retention for monthly backups
• Recovery Time Objective (RTO): 4 hours for critical systems
• Recovery Point Objective (RPO): 24 hours

6.3 Data Retention and Disposal

• Client data retained per contractual agreements (minimum 7 years)
• Healthcare data retained in compliance with federal and state requirements
• Secure data disposal using NIST-approved methods
• Certificate of destruction maintained for all disposed media

7. Application and Development Security

7.1 Secure Development Practices

• Security requirements integrated into development lifecycle
• Code reviews with security focus before production deployment
• Static Application Security Testing (SAST) for all code
• Dynamic Application Security Testing (DAST) for web applications
• Dependency scanning for third-party libraries
• Security training for all developers

7.2 FHIR-Specific Security

• OAuth 2.0 implementation for FHIR API authorization
• SMART on FHIR authentication framework compliance
• FHIR resource-level access controls
• Validation against FHIR profiles and implementation guides
• Audit logging of all FHIR resource access
• TLS 1.2+ required for all FHIR API communications

7.3 Production Environment Security

• Separation of development, testing, and production environments
• Change management process for production deployments
• Production data not used in non-production environments
• Web application firewall (WAF) protection
• API rate limiting and throttling

8. Security Monitoring and Logging

8.1 Logging Requirements

• Centralized logging for all systems and applications
• Logs protected from unauthorized modification
• Minimum 12-month log retention
• Logging of authentication events (success and failure)
• Logging of privileged operations
• Logging of data access and modifications
• System errors and security events logged

8.2 Security Monitoring

• 24/7 security monitoring of critical systems
• Real-time alerting for security events
• Regular log review and analysis
• Security Information and Event Management (SIEM) system
• Threat intelligence integration

9. Incident Response and Management

9.1 Incident Response Process

FHIR IQ maintains a formal incident response plan with the following phases:

1. Detection and Reporting: Identification of security incidents through monitoring or reporting
2. Assessment: Evaluation of incident severity and impact
3. Containment: Isolation of affected systems to prevent further damage
4. Eradication: Removal of threat and closing of vulnerabilities
5. Recovery: Restoration of systems to normal operations
6. Post-Incident Review: Analysis and lessons learned documentation

9.2 Incident Severity Classification

9.3 Breach Notification

In the event of a data breach involving PHI or personally identifiable information:

• Affected clients notified within 72 hours of discovery
• Breach reported to Department of Health and Human Services (HHS) if required
• State attorney general notification per state requirements
• Documentation of breach circumstances and response actions
• Credit monitoring offered to affected individuals when appropriate

10. Third-Party and Vendor Management

10.1 Vendor Security Assessment

All third-party vendors with access to FHIR IQ systems or data undergo security assessment:

• Security questionnaire completion before engagement
• Review of security certifications (SOC 2, ISO 27001, HITRUST)
• Business Associate Agreement (BAA) for PHI access
• Data Processing Agreement (DPA) for personal data
• Annual vendor security reassessment
• Right to audit vendor security controls

10.2 Vendor Access Control

• Minimum necessary access principle
• Time-limited access credentials
• Enhanced monitoring of vendor activities
• Immediate revocation upon contract termination

11. Physical Security

• Secure facility access controls
• Visitor sign-in and escort requirements
• Secured server rooms with access logging
• Clear desk policy for sensitive documents
• Secure disposal bins for confidential materials
• Environmental controls (fire suppression, climate)

12. Business Continuity and Disaster Recovery

12.1 Business Continuity Planning

• Documented business continuity and disaster recovery plans
• Annual business impact analysis
• Identification of critical business functions
• Defined recovery time and recovery point objectives
• Alternative work arrangements for staff

12.2 Testing and Maintenance

• Annual disaster recovery testing
• Quarterly backup restoration verification
• Plan updates following testing or incidents
• Staff training on continuity procedures

13. Security Training and Awareness

13.1 Training Requirements

• Security awareness training for all employees upon hire
• Annual security refresher training
• Role-specific security training (developers, administrators)
• HIPAA privacy and security training for personnel with PHI access
• Phishing awareness and simulation exercises

13.2 Security Awareness Program

• Monthly security tips and communications
• Incident lessons learned sharing
• Security threat updates and alerts
• Positive reinforcement for security-conscious behavior

14. Compliance and Audit

14.1 Regulatory Compliance

FHIR IQ maintains compliance with applicable regulations and standards:

• HIPAA Security and Privacy Rules
• HITECH Act requirements
• Federal and state data protection laws
• Payment Card Industry Data Security Standard (PCI DSS) where applicable
• Industry best practices (NIST Cybersecurity Framework, ISO 27001)

14.2 Security Assessments

• Annual independent security assessment
• Quarterly vulnerability scans
• Annual penetration testing of external systems
• HIPAA Security Rule compliance assessment
• Internal security audits

14.3 Documentation and Records

• Security policy and procedure documentation
• Risk assessment and treatment records
• Incident response documentation
• Audit logs and security event records
• Training completion records
• Vendor security assessments

15. Policy Violations and Enforcement

15.1 Consequences

Violations of this Information Security Policy may result in:

• Verbal or written warning
• Mandatory additional security training
• Suspension or revocation of system access privileges
• Termination of employment or contract
• Legal action where appropriate

15.2 Reporting Violations

All employees are required to report suspected security policy violations or security incidents immediately to their supervisor or the Security Officer. Reports can be made confidentially without fear of retaliation.

16. Contact Information

For questions about this Information Security Policy or to report security concerns:

17. Policy Acknowledgment

All employees, contractors, and authorized users must acknowledge receipt and understanding of this Information Security Policy. This acknowledgment is documented and maintained by Human Resources.

By accessing FHIR IQ systems and data, you acknowledge that you have read, understood, and agree to comply with this Information Security Policy and all related security procedures.