By Art Gross, President and CEO, HIPAA Secure Now!
LinkedIn: Art Gross
X: @HIPAASecureNow
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Common Mistakes & Best Practice Recommendations
In the fast-paced world of healthcare, safeguarding patient privacy remains paramount. Yet, despite the diligence exercised in patient care, one area where vulnerabilities persist is record disposal. From the cluttered file rooms to the maze of electronic data, mistakes are made that can jeopardize sensitive patient information. In this blog post, we’ll shine a spotlight on the top mistakes healthcare workers make with record disposal and, more importantly, provide best-practice solutions to fortify the defenses of patient privacy. Join us as we uncover the crucial art of secure record disposal, ensuring compliance with HIPAA and reinforcing the trust at the heart of healthcare.
1. Failure to Properly Shred Documents
One of the most prevalent errors is failing to securely shred physical documents containing patient information. Simply tearing or discarding them in regular trash bins leaves them vulnerable to unauthorized access.
Best Practice: Physical documents should be shredded using a cross-cut shredder to make it virtually impossible to reconstruct the information. You can also use third-parties for this service, although be sure to check out #5 beforehand.
2. Insufficient Electronic Data Sanitization
Disposing of electronic devices or storage media without properly sanitizing them can result in data breaches. Failing to use data sanitization techniques to render electronic patient records unrecoverable is a grave mistake.
Best Practice: When disposing of electronic devices or storage media that may contain ePHI, it’s crucial to employ data sanitization techniques to render the data unrecoverable. There are different methods for different purposes, including degaussing for magnetic media and data wiping for hard drives.
3. Incomplete or Inadequate Documentation
Neglecting to maintain clear and comprehensive records of the disposal process is another mistake. Proper documentation, including what was disposed of, when, and by whom, is essential for demonstrating compliance with HIPAA requirements.
Best Practice: Maintain clear records of the disposal process, including what was disposed of, when, and by whom. If you use a third-party, consider asking for a certificate of destruction. This documentation helps demonstrate compliance with HIPAA requirements.
4. Inadequate Employee Training
If employees are not adequately trained in proper disposal procedures and the significance of safeguarding patient information during disposal, they may inadvertently mishandle records.
Best Practice: Conduct regular training sessions, both in-person and online, covering topics such as proper disposal procedures, HIPAA compliance, and the significance of patient privacy. Developing a training policy, as well as materials and resources that are easily accessible to all employees, will help promote retention and accountability.
5. Lack of Vendor Due Diligence
When healthcare organizations use third-party vendors for disposal services, not conducting due diligence to ensure their HIPAA compliance and secure handling of patient records is a significant error. Choosing an unqualified vendor can lead to data exposure.
Best Practice: If you use third-party vendors for disposal services, ensure they are HIPAA-compliant and provide secure handling and disposal. You should always have a Business Associate Agreement in place.
6. “Set it and forget it” Mentality
Per HIPAA requirements, many healthcare organizations establish disposal procedures; however, they fail to revisit and update them regularly. This complacency can lead to a false sense of security and neglect when it comes to adapting to new threats and technologies.
Best Practice: Periodically audit your disposal processes to identify and address any vulnerabilities or non-compliance issues. Establishing a regular schedule and involving staff members from various teams can enhance the impact of these audits. Be sure that all employees review the policies annually.
A Proactive Path Forward
As we conclude our exploration of the top mistakes in record disposal and their best-practice solutions, we underscore the pivotal role played by proper disposal processes. By recognizing these missteps and embracing the best practices outlined, healthcare organizations can raise their record disposal standards to the highest level.
Let us leave behind the “set it and forget it” mentality, replacing it with a proactive commitment to patient privacy. With each securely shredded record and every diligently documented step, we reaffirm our dedication to maintaining the trust and integrity at the core of healthcare.
This article was originally published on HIPAA Secure Now! and is republished here with permission.