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10. Facility Access Policy

NutriAdmin works with Subcontractors to assure restriction of physical access to systems used as part of the NutriAdmin Platform. NutriAdmin and its Subcontractors control access to the physical buildings/facilities that house these systems/applications, or in which NutriAdmin workforce members operate, in accordance to the HIPAA Security Rule 164.310 and its implementation specifications. Physical Access to all of NutriAdmin facilities is limited to only those authorized in this policy. In an effort to safeguard ePHi from unauthorized access, tampering, and theft, access is allowed to areas only to those persons authorized to be in them and with escorts for unauthorized persons. All workforce members are responsible for reporting an incident of unauthorized visitor and/or unauthorized access to NutriAdmin's facility.

Of note, NutriAdmin does not have ready access to ePHI, it provides cloud-based, compliant software as a service to covered entities and business associates. NutriAdmin does not physically house any systems used by its Platform in NutriAdmin facilities. Physical security of our Platform servers is outlined in §1.4.

10.1 Applicable Standards from the HIPAA Security Rule

  • 164.310(a)(2)(ii) Facility Security Plan
  • 164.310(a)(2)(iii) Access Control & Validation Procedures
  • 164.310(b-c) Workstation Use & Security

10.2 NutriAdmin-controlled Facility Access Policies

  1. Visitor and third party support access is recorded on the NutriAdmin Facilities Visitor Log spreadsheet and supervised. All visitors are escorted.
  2. Repairs are documented on the Repairs on NutriAdmin Systems Log spreadsheet and the documentation is retained.
  3. Fire extinguishers and detectors are installed according to applicable laws and regulations.
  4. Maintenance is controlled and conducted by authorized personnel in accordance with supplier-recommended intervals, insurance policies and the organizations maintenance program.
  5. Electronic and physical media containing covered information is securely destroyed (or the information securely removed) prior to disposal.
  6. The organization securely disposes media with sensitive information.
  7. Physical access is restricted using physical locks in doors.
    • Restricted areas and facilities are locked when unattended (where feasible).
    • Only authorized workforce members receive access to restricted areas (as determined by the Security Officer).
    • Access and keys are revoked upon termination of workforce members.
    • Workforce members must report a lost and/or stolen key(s) to the Security Officer.
    • The Security Officer facilitates the changing of the lock(s) within 7 days of a key being reported lost/stolen
  8. Enforcement of Facility Access Policies
    • Report violations of this policy to the Privacy Officer.
    • Workforce members in violation of this policy are subject to disciplinary action, up to and including termination.
    • Visitors in violation of this policy are subject to loss of vendor privileges and/or termination of services from NutriAdmin.
  9. Workstation Security
    • Workstations may only be accessed and utilized by authorized workforce members to complete assigned job/contract responsibilities.
    • All workforce members are required to monitor workstations and report unauthorized users and/or unauthorized attempts to access systems/applications as per the System Access Policy.
    • All workstations purchased by NutriAdmin are the property of NutriAdmin and are distributed to users by the company.