Risk Management Policy

Risk Management Policy

Last Modified: April 03, 2017

This policy establishes the scope, objectives, and procedures of Visible Health’s information security risk management process. The risk management process is intended to support and protect the organization and its ability to fulfill its mission.

Applicable Standards from the HIPAA Security Rule

Risk Management Policies

  1. It is the policy of Visible Health to conduct thorough and timely risk assessments of the potential threats and vulnerabilities to the confidentiality, integrity, and availability of electronic protected health information (ePHI) (and other confidential and proprietary electronic information) it stores, transmits, and/or processes for its Customers and to develop strategies to efficiently and effectively mitigate the risks identified in the assessment process as an integral part of the Visible Health’s information security program.
  2. Risk analysis and risk management are recognized as important components of Visible Health’s corporate compliance program and information security program in accordance with the Risk Analysis and Risk Management implementation specifications within the Security Management standard and the evaluation standards set forth in the HIPAA Security Rule, 45 CFR 164.308(a)(1)(ii)(A), 164.308(a)(1)(ii)(B), 164.308(a)(1)(i), and 164.308(a)(8).
    1. Risk assessments are done throughout product life cycles:
    2. Before the integration of new external system technologies outside of our AWS infrastructure and before changes are made to Visible Health physical safeguards; and
      • These changes do not include routine updates to existing systems, deployments of new systems created based on previously configured systems, deployments of new Customers, or new code developed for operations and management of the Visible Health Platform.
    3. While making changes to Visible Health physical equipment and facilities that introduce new, untested configurations.
    4. Visible Health performs periodic technical and non-technical assessments of the security rule requirements as well as in response to environmental or operational changes affecting the security of ePHI.
  3. Visible Health implements security measures sufficient to reduce risks and vulnerabilities to a reasonable and appropriate level to:
    1. Ensure the confidentiality, integrity, and availability of all ePHI Visible Health receives, maintains, processes, and/or transmits for its Customers;
    2. Protect against any reasonably anticipated threats or hazards to the security or integrity of Customer ePHI;
    3. Protect against any reasonably anticipated uses or disclosures of Customer ePHI that are not permitted or required; and
    4. Ensure compliance by all workforce members.
  4. Any risk remaining (residual) after other risk controls have been applied, requires sign off by the senior management and Visible Health’s Security Officer.
  5. All Visible Health workforce members are expected to fully cooperate with all persons charged with doing risk management work, including contractors and audit personnel. Any workforce member that violates this policy will be subject to disciplinary action based on the severity of the violation according to Visible Health’s policies, which is outlined in the Visible Health Policy Management Policy.
  6. The implementation, execution, and maintenance of the information security risk analysis and risk management process is the responsibility of Visible Health’s Security Officer (or other designated employee), and the identified Risk Management Team.
  7. All risk management efforts, including decisions made on what controls to put in place as well as those to not put into place, are documented and the documentation is maintained for six years.

Risk Management Procedures

Risk Assessment: The intent of completing a risk assessment is to determine potential threats and vulnerabilities and the likelihood and impact should they occur. The output of this process helps to identify appropriate controls for reducing or eliminating risk.

Risk Mitigation: Risk mitigation involves prioritizing, evaluating, and implementing the appropriate risk-reducing controls recommended from the Risk Assessment process to ensure the confidentiality, integrity and availability of Visible Health Platform ePHI. Determination of appropriate controls to reduce risk is dependent upon the risk tolerance of the organization consistent with its goals and mission.

Risk Management Schedule: The two principle components of the risk management process - risk assessment and risk mitigation - will be carried out according to the following schedule to ensure the continued adequacy and continuous improvement of Visible Health’s information security program:

Process Documentation

Maintain documentation of all risk assessment, risk management, and risk mitigation efforts for a minimum of six years.