Is Your Organization Ready for an Archival Project?

Before you select the right vendor for your organization’s health data archival projects, it’s important to get your house in order! You need to define the policies and workflows clearly for effective implementation by the vendor.

As the project manager for health data archival, it is important that you set your organization ready before you allow your chosen vendor to get their hands on your organization’s vulnerable health data.

Are you wondering where to start?

You need not worry - we have you covered.

Here are the key points you should think about:

1. Data Security

Research indicates that 68% of security breaches in healthcare are due to insufficient archival rules and procedures.

These are some of the things that you should define:

• Data categorization: While working out your data types, formats, and storage requirements, consider if specific data elements are to be considered sensitive and require special protection

• Access control: Establish protocols for granting and revoking access to data, including who has access to the data and under what circumstances. Define authentication and authorization mechanisms, such as usernames, passwords, multi-factor authentication, and Role-based Access Control.

• Data encryption (both in transit and at rest): You need to define the protocols during transmission and encryption algorithms during storage. There might be minimum requirements that need to be incorporated as part of HIPAA, HITECH, and CCPA.

• Incident response: Define procedures for detecting and responding to security incidents, including breach notification and escalation procedures. Establish protocols for incident investigation, remediation, and reporting.

2. Compliance with Regulatory Requirements

Regulatory requirements from HIPAA, HITECH, CCPA, etc., would inform policies in all areas. You need to review all your policies from the lens of these compliances.

A good vendor would have resources that summarize these requirements, and they should also help guide you in your policy definition, keeping these in mind.

In addition, you should establish procedures for regularly reviewing and updating the policy to reflect changes in regulations or industry best practices.

3. Data Retention Policy

You should define the minimum retention periods for different types of data based on federal and state requirements. Certain types of data, such as patient health information, may require longer retention periods than others. Defining the purpose of retention (legal, regulatory, operational, etc.) helps in the determination of the appropriate retention periods.

Automatic and secure data destruction based on these lifecycle policies is crucial. Similarly, audit and monitoring of access, destruction, and exceptions are quite important as well.

4. Disaster Recovery (DR) and Business Continuity (BC)

Bad, unforeseen events happen. They’ll happen to you. It’s estimated that nearly 30% of businesses fail to recover from any type of disaster due to a lack of proper practices for DR and BC planning. You should do a risk assessment first to identify critical systems and data. This would lead to defining the Recovery Time Objective (RTO) and Recovery Point Objective (RPO). RTO is about the time frame when the service can come back up in different DR scenarios. RPO is about the level of data loss that is acceptable in a disaster.

Comprehensive DR and BC procedures that are regularly tested are a must. This needs to cover backing up data, restoring systems, and maintaining operations during and after a disaster.

5. Service Level Agreement (SLA)

The health organization should have an SLA in place that outlines the expected level of service from the vendor. This should primarily include metrics such as average system uptime and response and resolution times for support requests.

In addition, you should consider data availability level, retrieval response time, RTO and RPO for DR and BC, etc. There should also be specifically defined messaging about data integrity over time, data security and confidentiality assurances, and maintenance service window timings.

Ultimately, you need to define the proportionate penalty for a breach in any of the policies that are part of the SLA.

6. Interoperability

You should ensure that the vendor can integrate with your existing systems and workflows. This can include requirements for data formats, APIs, and other technical considerations.

According to recent statistics, interoperability protocols are now being used in over 70% of all healthcare settings and represent a significant increase from past years when these standards had little to no adoption.

Examples of such policies include making sure the technical environment supports interoperability, maintaining compliance with security protocols, leveraging existing standards and guidelines, and engaging all relevant stakeholders to ensure common objectives are met.

When such policies are in place, organizations can feel more confident about selecting a vendor whose services will perfectly fit their needs, allowing them to benefit from improved data exchange and better patient care.

In conclusion, it is important to consider various aspects of an archival project before committing your organization to the task and to the vendor. By having these policies and workflows in place, your health organization can ensure that it is ready to accommodate the chosen vendor and efficiently implement a successful archival project.