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Covered Entity Presentation Regarding Business Associates[1]
- 1. Covered Entity Requirement to Ensure Business Associates & Their Vendors Comply with HITECH Accurate Data Partners, LLC
- 3. People make decisions about you, your clients and your employees that are based on more than the information in a Credit Report. It is imperative that Personally Identifiable Information and Non-Public Information be as protected and as accurate as possible. Drivers License Medical Financial Social Security Character/ Criminal Five Common Identity Risks
- 5. ™ Medical Identity & The DBY Copyright Accurate Data Partners, LLC. All rights reserved. This document may not be shared, transferred, copied or sold in any form except for the business that has purchased the document for its own use. Your Name 1000’s of aggregators Acxiom, Choice Point, LexisNexis, etc. Insurance Companies, Agencies and Agent’s C.L.U.E. DBS, etc... Physician's Data Bases Medical Information Bureau Data Base (MIB) Blood Bank & Various Lab Data Bases Drug Store & Pharmacy Data Bases Employer’s Data Bases Your Address 1000’s of DBS Hospital’s Various Data Bases Center for Disease and Control (CDC) USB Keys, CD/DVDs Thumb & Jump Drives DHEC/State Health Dept Local, State Federal Health DBS Billing and Collection DBS and Credit Repository Computers
- 6. ™ The Web of The DataBased You Copyright Accurate Data Partners, LLC. All rights reserved. This document may not be shared, transferred, copied or sold in any form except for the business that has purchased the document for its own use. Your Name 1000’s of aggregators Your Fingerprints and DNA FBI, State, and Local DBS Your Insurance Claims C.L.U.E. DBS, etc... Your Military Record DOD DBS Your Criminal History NCIC DBS Your Real Estate Deeds Clerks of Court DBS Your Legal History State and Federal Court DBS Your Credit History Credit Repositories’ DBS Your Birth Certificate Choice Point DBS, State, etc … Your Phone Number and Tracking Info 1000’s of aggregators Your Social Security Number SSA DBS and any you gave to Your Address 1000’s of DBS Your Driver’s License # and Record – DMV DBS Your Medical Records MIB DBS, etc … Your Car Registration & Info DMV, Local Treasurer, On Star, etc … DBS
- 7. ™ Where the Laws Becomes Logical Copyright Accurate Data Partners, LLC. All rights reserved. This document may not be shared, transferred, copied or sold in any form except for the business that has purchased the document for its own use. Once the credit systems accept bad data it can be next to impossible to clear . USA Today June 5, 2007 Medical identity theft can impair your health and finances… and detecting this isn’t easy… and remedying the damages can be difficult. WSJ Oct 11, 2007 Because it’s so overwhelming to CORRECT the victims’ records, it’s imperative for anyone who touches Medical Info to PROTECT the data. Your Insurance Claims C.L.U.E. DBS, etc... Your Social Security Number SSA DBS and any you gave to Your Name 1000’s of aggregators Your Address 1000’s of DBS Your Fingerprints and DNA FBI, State, and Local DBS Your Driver’s License # and Record – DMV DBS Your Military Record DOD DBS Your Criminal History NCIC DBS Your Real Estate Deeds Clerks of Court DBS Your Medical Records MIB DBS, etc … Your Phone Number and Tracking Info 1000’s of aggregators Your Car Registration & Info Your Legal History State and Federal Court DBS Your Credit History Credit Repositories’ DBS Your Birth Certificate Choice Point DBS, State, etc …
- 8. 1 The Secure Data Based You – The Complete Approach Patient/Employee Copyright Accurate Data Partners, LLC. All rights reserved. This document may not be shared, transferred, copied or sold in any form except for the business that has purchased the document for its own use. Protecting potential victims, your patients, and yourself
- 9. Client Data Security Laws, HIPAA, GLB & SC ID Theft Law Privacy Laws, HIPAA, HITECH; GLB & State Laws HITECH, RFR, HIPAA, other State & Federal Laws Red Flags Rule (RFR) State Immigration Acts FACTA – Document Destruction Rule – State Laws 1 Requires Businesses to Protect Personally Identifiable information Reduces threat of thief gaining access to information which can be used to corrupt an individuals records Securing The Data Based You Requires Businesses to Authenticate the Identity of Their Patients/Employees – Helps reduce the risk of perpetuation of a crime against an innocent victim Requires Businesses to Limit Access to and Keep Private Personally Identifiable Information - Reduces access to information & protects individual’s privacy; Only allows permissible access with permissible uses Businesses must Destroy/Shred All Documents or Digital Media Containing PII or NPI upon Disposal - Reduces threat from loss & resulting misuse of PII or NPI which can be used to steal someone’s identity Businesses must Insure that they Share ,Sell, Give, Information with /to ONLY Those Vendors and Business Associates with these same measures in place. Reduces risk of individual becoming a victim through a 3 rd Party Vendor with which the victim has no direct relationship A Legal Safety Net for Identities Copyright Accurate Data Partners, LLC. All rights reserved. This document may not be shared, transferred, copied, sold or used in any form except for the business that has purchased the document for its own use. These issues, although separated by the legislative process, are not so cleanly separated in our day to day practices.
- 10. Imagine someone stealing your patients or employees information from one of your Business Associates, their Subcontractors, Vendors or Agents and you must notify Victims and Government Agencies. What can you show to prove you acted reasonably in overseeing and requiring compliance by those you entrusted with Patient information The Potential Cost to Covered Entity Copyright Accurate Data Partners, LLC. All rights reserved. This document may not be shared, transferred, copied or sold in any form except for the business that has purchased the document for its own use. Have your Business Associates employees even executed Confidentiality Docs and acknowledged training? Do Business Associates even have required written policies? Do you think a change in your Business Associate Contract accomplished what is required?
- 13. THANK YOU For additional information please contact: www.accuratedatapartners.com
Editor's Notes
- THE RED FLAGS RULE. Red Flags are patterns, practices, or specific activities that indicate the possible existence of identity theft. Your Red Flags Program must be approved by your Board of Directors or senior management, a senior officer must be put in charge of the program and the FTC Rule requires 4 steps: 1. Identify your dealership’s red flags from a risk-based analysis; No “one size fits all” set of red flags. Have procedures to detect and evaluate red flags in individual covered transactions. 3 key ways are to examine customer ID, examine credit report and examine the report of an electronic identity verification service. Ask out-of-wallet or challenge questions available from electronic identity verification service. 3. Have procedures to respond to red flags. Seek additional information from the customer and escalate unresolved red flags to a senior Program Officer 4. Update program at least annually and make reports to Board or senior management. Training employees is also very important in the Red Flags Rule. Create a “culture of security” in your dealership.
- THE RED FLAGS RULE. Red Flags are patterns, practices, or specific activities that indicate the possible existence of identity theft. Your Red Flags Program must be approved by your Board of Directors or senior management, a senior officer must be put in charge of the program and the FTC Rule requires 4 steps: 1. Identify your dealership’s red flags from a risk-based analysis; No “one size fits all” set of red flags. Have procedures to detect and evaluate red flags in individual covered transactions. 3 key ways are to examine customer ID, examine credit report and examine the report of an electronic identity verification service. Ask out-of-wallet or challenge questions available from electronic identity verification service. 3. Have procedures to respond to red flags. Seek additional information from the customer and escalate unresolved red flags to a senior Program Officer 4. Update program at least annually and make reports to Board or senior management. Training employees is also very important in the Red Flags Rule. Create a “culture of security” in your dealership.
- Basic Steps You Can Take In Your Office To Protect Your Clients