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Standards › Standard 2A › Policies

Policy · DIG-POL-001 · Version 1.1 · Approved by the ASF Expert Committee

Supports: 2A.4

At a glance

  • Give each person access only to the health information they need for their job.
  • Use a unique login and a strong password. Never share your login.
  • Lock your screen when you leave the workstation.
  • Report any suspected breach at once through the breach procedure.
  • Review who has access every quarter and remove access when a person leaves.
  • Stop and get help straight away if: you suspect patient information has been seen, copied or sent to the wrong person. Stop, and report it at once.

1. Purpose

To protect patient health information from unauthorised access, loss, change or disclosure, using practical security measures [E-006, EC].

2. Scope

Applies to All staff, students, contractors and anyone with access to the facility’s systems or paper records
Locations All sites, systems, devices and paper records
When At all times
Does not apply to Clinical decisions on the use of information, which are covered by the confidentiality and records policies

3. Definitions

Term Meaning
Health information Any information that identifies a patient and relates to their care
Access control Rules and tools that decide who can see, change or share information
Breach Any unauthorised access, loss, disclosure or change of health information

4. Background

Patients share their health information on the basis that it will be kept private. A breach can cause harm, distress and loss of trust. Criterion 2A.4 asks for access controls and a breach response plan that the facility can actually carry out with its resources.

5. Responsibilities

Role Responsibility Competence
IT lead Sets access controls; runs the access review; manages security tools IT security competence
Data protection lead Advises on the law; leads breach assessment; keeps the breach log Data protection competence
Line managers Request and approve access; tell IT when a person changes role or leaves Management training
Every user Protect login and device; report breaches; follow the rules Induction and annual training

6. Materials and equipment

Item Requirement Condition
Access rules (role-based list) Written per role Reviewed quarterly
Strong password standard Length and rules set by the IT lead (EC) Enforced by system
Screen lock Set to lock after a short period of inactivity (EC) On all workstations
Breach response plan (DIG-SOP-001) Current Available to the breach team

7. Safety

8. Before you start

9. Procedure

Step 1. Set access by role.

  • Write an access list for each role: what information, what systems, what actions (view, change, export).
  • Give access on the basis of the role, not the person.
  • Use a unique login for each user.

Key point: Role-based access limits what a person can see to what their job needs.

Step 2. Protect logins and devices.

  • Use a strong password and multi-factor login where the system allows.
  • Lock the screen when you leave. Log out of shared devices.
  • Keep devices encrypted where the hospital can do so (EC).

Key point: Most breaches start with a stolen or shared login.

Step 3. Review access every quarter.

  • The IT lead and line managers review the list of users and their access.
  • Remove access that is no longer needed. Remove access the same day a person leaves.
  • Record the review date and the changes.

Key point: Access that is never reviewed grows until no one knows who can see the records.

Step 4. Monitor and log access.

  • Keep logs of access to electronic records where the system allows.
  • Check unusual access (for example, records of patients not under the person’s care) each month.

Key point: Logs show who looked at a record, which is essential when a breach is suspected.

Step 5. Keep paper records secure.

  • Store paper records in locked cabinets with controlled keys.
  • Track removal of records from the store.
  • Destroy paper records only through the approved disposal process.

Key point: Paper breaches happen through records left on desks and in cars.

Step 6. Report any breach at once.

  • Report to your line manager and the data protection lead immediately, using DIG-SOP-001.
  • Do not try to investigate alone or delete anything.

Key point: Early reporting limits harm and is required by the breach procedure.

10. Decision points

11. Special situations

Situation Action
Remote working Use only approved devices and connections. No health information on personal devices unless the IT lead approves it (EC).
Third-party systems Contracts must set security duties and breach notice periods (EC).

12. Escalation

13. Monitoring

Measure Target Frequency Owner If not met
Access reviews completed each quarter 100% Quarterly IT lead Escalate to chief executive
Access removed the same day a person leaves 100% Monthly sample HR lead Review and correct
Breaches reported within 24 hours of discovery 100% Monthly Data protection lead Review of reporting delay

14. Records

Record Kept in Retention
Access review record IT file the period set by the facility’s records policy years
Breach log Data protection file the period set by the facility’s records policy years

15. Training

16. Related documents

ID Title Use
DIG-SOP-001 Patient Data Breach Response Procedure Used when a breach occurs
DIG-FRM-001 Breach Response Test Record Test record
REC-POL-001 Records Management and Retention Retention and disposal
SOP-087 Confidentiality Policy (generic) Confidentiality duties
SOP-108 Privacy Standard (generic) Privacy duties

17. Evidence

Reference Note
E-006 ASF Policy Framework v1.2. Adapted.
E-009 ASF Expert Committee consensus. Password, encryption and logging rules to be set by the IT lead and checked against national data protection law.

18. Change history

Version Date What changed Approval
1.0 the date of approval First version adapted from ASF Policy 37 and 71 Approved by the ASF Expert Committee
1.1 the date of approval Internal quality review: corrected cross-references, status wording and document control Approved by the ASF Expert Committee

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References

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