Encryption and Decryption Policy (UBIT HIPAA)

Category: HIPAA Security
Responsible Office: UBIT HIPAA Compliance
Responsible Executive: Vice President and Chief Information Officer (VPCIO)
Approved By (Name/Title): J. Brice Bible, VPCIO

CATEGORY: Technical Safeguards
TYPE: Addressable Implementation Specification for Access Control Standard
CITATION:  45 CFR 164.312(a)(2)(iv)

The University at Buffalo Information Technology (UBIT) operates as a covered entity as defined by the U.S. Department of Health and Human Services Office of Civil Rights. HIPAA Regulation Text 45 CFR Part 164.312(a)(2) requires a covered entity to implement technical policies and procedures for electronic information systems that maintain electronic protected health information to allow access to those persons or software programs that have been granted access rights as specified in 164.308 (a)(4) Information Access Management.

Where UBIT has determined through its risk analysis, in accordance with its Risk Analysis Policy that it is reasonable and appropriate, UBIT protects the confidentiality of ePHI by encrypting ePHI on ePHI Systems. Based on its risk analysis, UBIT determines the type and quality of the encryption algorithm and cryptographic key length.

This policy applies to all UBIT workforce members.

Workforce members: Adhere to policies and procedures as written.

HIPAA Security and Privacy Officer: Ensures implementation of mechanisms to encrypt and decrypt ePHI.

Compliance Officer: Participates in ensuring the security of ePHI is effective and enforced, in conjunction with the HIPAA Security and Privacy Officer.

Director, Enterprise Infrastructure Services: Oversees implementation of mechanisms to encrypt and decrypt ePHI.

Date Approved: 12/4/2017