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
- Do not write passwords on paper near a workstation.
- Do not email health information to personal accounts or unapproved services.
- Do not leave paper records unattended. Use locked storage.
8. Before you start
- Check your access is correct for your role.
- Check your device is locked when unattended.
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
- If a breach is confirmed to affect many patients, the chief executive decides on notification to the regulator and to patients, as the law requires (EC).
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
- Breaches go to the data protection lead at once, and to the chief executive the same day.
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
- All staff are trained in information security at induction and yearly (EC).
- IT and data protection staff receive specialist training (EC).
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 |
E-learning for this document
References
- Accréditation Sans Frontières (2026). ASF Policy Framework v1.2. (E-006)
- Accréditation Sans Frontières (2026). ASF Expert Committee consensus on Standard 1. (E-009)