21. 3rd Party Policy#
WayToHealth makes every effort to assure all 3rd party organizations are compliant and do not compromise the integrity, security, and privacy of WayToHealth or WayToHealth Customer data. 3rd Parties include Customers, Partners, Subcontractors, and Contracted Developers.
21.1 Applicable Standards#
21.1.1 Applicable Standards from the HITRUST Common Security Framework#
- 05.i - Identification of Risks Related to External Parties
- 05.k - Addressing Security in Third Party Agreements
- 09.e - Service Delivery
- 09.f - Monitoring and Review of Third Party Services
- 09.g - Managing Changes to Third Party Services
- 10.1 - Outsourced Software Development
21.1.2 Applicable Standards from the HIPAA Security Rule#
- 164.314(a)(1)(i) - Business Associate Contracts or Other Arrangements
21.2 Policies to Assure 3rd Parties Support WayToHealth Compliance#
- WayToHealth does not allow 3rd party access to production systems containing ePHI.
- All connections and data in transit between the WayToHealth Platform and 3rd parties are encrypted end to end.
- A standard business associate agreement with Customers and Partners is defined and includes the required security controls in accordance with the organization's security policies. Additionally, responsibility is assigned in these agreements.
- WayToHealth has Service Level Agreements (SLAs) with Subcontractors with an agreed service arrangement addressing liability, service definitions, security controls, and aspects of services management.
- Subcontractors must coordinate, manage, and communicate any changes to services provided to WayToHealth.
- Changes to 3rd party services are classified as configuration management changes and thus are subject to the policies and procedures described in §9; substantial changes to services provided by 3rd parties will invoke a Risk Assessment as described in §4.2.
- WayToHealth utilizes monitoring tools to regularly evaluate Subcontractors against relevant SLAs.
- No WayToHealth Customers or Partners have access outside of their own environment, meaning they cannot access, modify, or delete anything related to other 3rd parties.
- WayToHealth does not outsource software development.
- WayToHealth maintains and annually reviews a list all current Partners and Subcontractors.
- The list of current Partners and Subcontractors is maintained by the WayToHealth Privacy Officer, includes details on all provided services (along with contact information), and is recorded in §1.1.
- The annual review of Partners and Subcontractors is conducted as a part of the security, compliance, and SLA review referenced below.
- WayToHealth assesses security, compliance, and SLA requirements and considerations with all Partners and Subcontractors. This includes annual assessment of SOC2 reports for all WayToHealth infrastructure partners.
- WayToHealth leverages recurring calendar invites to assure reviews of all 3rd party services are performed annually. These reviews are performed by the WayToHealth Security Officer and Privacy Officer or designated personnel. The process for reviewing 3rd party services is outlined below:
- The Security Officer or designated personnel initiates the SLA review by creating an Ticket in the WayToHealth TQMS.
- The Security Officer, Privacy Officer, or designated personnel, is assigned to review the SLA and performance of 3rd parties. The list of current 3rd parties, including contact information, is also reviewed to assure it is up to date and complete.
- SLA, security, and compliance performance is documented in the Ticket.
- Once the review is completed and documented, the Security Officer or designated personnel approves or rejects the Ticket. If the Ticket is rejected, it goes back for further review and documentation.
- Regular review is conducted as required by SLAs to assure security and compliance. These reviews include reports, audit trails, security events, operational issues, failures and disruptions, and identified issues are investigated and resolved in a reasonable and timely manner.
- Any changes to Partner and Subcontractor services and systems are reviewed before implementation.
- For all partners, WayToHealth reviews activity annually to assure partners are in line with SLAs in contracts with WayToHealth.
- SLA review is monitored on a annual basis using the TQMS reporting to assess compliance with above policy.
- The 3rd Party Assurance process is reviewed annually and updated to include any necessary changes.
- Changes to the 3rd Party Assurance process will also be made on an ad-hoc basis in cases where operational changes require it or if the process is found lacking.