Information System Activity Review 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: Administrative Safeguards
TYPE: Required implementation Specification for Security Management Process Standard
CITATION: 45 CFR 164.308(a)(1)(ii)(D)

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 (OCR). HIPAA Regulation Text 45 CFR Part 164.308(a)(1)(i) requires a covered entity to implement policies and procedures to prevent, detect, contain, and correct security violations.

UBIT regularly reviews records of information system activity including, but not limited to: audit logs, access reports, and security incident tracking reports. UBIT selects ePHI information systems that have appropriate hardware, software, or procedural auditing mechanisms to enable such review on an ongoing basis. 

UBIT implements procedures to regularly review records of information system activity.

This policy applies to all UBIT workforce members.

Workforce members: Adhere to all policies and procedures as written.

HIPAA Security and Privacy Officer: Regularly reviews records of information system activity including, but not limited to: audit logs, access reports, and security incident tracking reports.

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

Date Approved: 12/6/2017