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10. Facility Access Policy#

WayToHealth works with Subcontractors to assure restriction of physical access to systems used as part of the WayToHealth Platform. WayToHealth and its Subcontractors control access to the physical buildings/facilities that house these systems/applications, or in which WayToHealth workforce members operate, in accordance to the HIPAA Security Rule 164.310 and its implementation specifications. Physical Access to all of WayToHealth 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 WayToHealth's facility.

Of note, WayToHealth does not physically house any systems used by its Platform in WayToHealth facilities. Physical security of our Platform servers is outlined in ยง1.1.

10.1 Applicable Standards#

10.1.1 Applicable Standards from the HITRUST Common Security Framework#

  • 08.b - Physical Entry Controls
  • 08.d - Protecting Against External and Environmental Threats
  • 08.j - Equipment Maintenance
  • 08.l - Secure Disposal or Re-Use of Equipment
  • 09.p - Disposal of Media

10.1.2 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 WayToHealth-controlled Facility Access Policies#

  1. WayToHealth maintains offices within The University Of Pennsylvania campus. Access to the building is restricted by badge access. WayToHealth inherits security, repair and maintenance, insurance and other requirements from the parent UPHS and University of Pennsylvania organizations.
  2. Electronic and physical media containing covered information is securely destroyed (or the information securely removed) prior to disposal.
  3. The organization securely disposes media with sensitive information.
  4. Physical access is restricted using badges and keys where necessary.
  5. Restricted areas and facilities are locked when unattended (where feasible).
  6. Only authorized workforce members receive access to restricted areas.
  7. Access and keys are revoked upon termination of workforce members.
  8. Workforce members must report a lost and/or stolen key(s) immediately to the floor manager (Dana Opeila).
  9. The floor manager will facilitate the changing of the lock(s) per UPHS/PSOM policies.
  10. Enforcement of Facility Access Policies
  11. Report violations of this policy to the restricted area's department team leader, supervisor, manager, or director, or the Privacy Officer.
  12. Workforce members in violation of this policy are subject to disciplinary action, up to and including termination.
  13. Visitors in violation of this policy are subject to loss of vendor privileges and/or termination of services from WayToHealth.
  14. Workstation Security
  15. Workstations may only be accessed and utilized by authorized workforce members to complete assigned job/contract responsibilities.
  16. 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.
  17. All workstations purchased by WayToHealth are the property of UPHS or the University of Pennsylvania and are distributed to users by the those organizations.
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