Security and privacy
Today we accept no patient information
This page says what will be in place before we accept any. Nothing below is live yet. Each item is being set up, and we confirm each one in writing first.
i.Agreement
A signed agreement comes before any patient information
- No patient information comes to us before a business associate agreement (BAA) is signed by both sides.
- For a practice, we are its business associate. For a billing firm, we are its subcontractor.
- We sign our BAA or yours after reading it.
ii.Where files live
Files stay on one server in the United States
- Office files go to a separate server used only for office cases.
- It runs on Amazon Web Services (AWS), in a United States region, under AWS's business associate addendum.
- No storage, access or support from outside the United States.
iii.Encryption
Files are encrypted in transit and at rest
- Every upload and download uses HTTPS.
- The server's disk and every backup are encrypted. Backups expire after 7 days.
- Patient files never go by e-mail. If you e-mail us patient information by mistake, we delete it and tell you.
- The office pages run no advertising, analytics or third-party scripts.
iv.Access
Only named people can sign in
- Each person at your office gets an invite-only account with two-step sign-in. No shared accounts and no public sign-up.
- Each office sees only its own cases.
- On our side, one person has access: our owner, who is also our security official. The owner signs in with a passkey or security key.
- Nobody else gets access without a signed confidentiality agreement, HIPAA and Texas privacy training, and written notice to you.
v.Logging
Every action is logged
Every sign-in, upload, view, download, edit, sign-off and erase is logged with the account and the time. The log holds case codes, not patient names. We review it every day, and you can ask for your office's entries at any time.
vi.Erasing
Files are erased on a fixed schedule
- Each case is erased 30 days after its packet is ready, or within 3 business days if you ask sooner.
- At the end of the pilot, we return what you ask for and erase everything within 30 days. Backups expire 7 days later. You get a signed certificate.
- We keep only counts with no patient details. We never sell, rent or market your data.
vii.Problems
We tell you fast if something goes wrong
- We tell your privacy contact by phone and e-mail immediately, and no later than 48 hours after we find a problem.
- A written report follows within 10 calendar days.
- You decide on notices to patients and regulators. We give you the facts in time for your deadlines.
viii.Program
Our written program is signed before go-live
- A risk analysis made with HHS's Security Risk Assessment workbook, repeated every year.
- Written security and privacy policies, kept for 6 years.
- A yearly HIPAA and Texas privacy training record (Texas Health and Safety Code ch. 181).
- Errors-and-omissions and cyber insurance that covers our duties as a business associate. We share the certificate.
ix.Not yet
Some things are not in place yet
- No SOC 2 report, HITRUST rating or ISO 27001 certificate. No outside firm has examined our controls.
- No outside penetration test yet.
- No insurance bound yet. It is bound before any patient information is accepted.
Have your own security form? We fill it in item by item. E-mail hello@provlyappeals.com.