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I’m in the process of reviewing the HIPPA Privacy Rule & Security Rule and I am wondering how other Universities that are designated as covered entities ensure compliance with the following two Administrative Requirements:
1. Training - Does your school offer security & privacy training to all workforce including management?
a. Yes, mandatory for all employees
b. Yes, mandatory but ONLY for employees who handle HIPPA data
c. Yes, mandatory but only for employees who handle sensitive information (one training covers all regulations PII, PCI, HIPAA, PERPA, etc.)
c. Yes, optional generic computer & data security training for all employees, but it does not specifically emphasize a regulation
b. No, don’t have a HIPPA training program
2. Privacy and Security Official – has your institution formally appointed or identified who will be operationally responsible for assuring that the covered entity complies with both the Security and Privacy rules?
a. Yes, a Security Official and Privacy Official has been appointed and it is the same person
b. Yes, a Security Official and Privacy Official has been appointed and it is NOT the same person
c. No, no person has been identified.
Your input will be highly appreciated and I will summarize the results and share with the group.
Carlos S. Lobato, CISA, CIA
IT Compliance Officer
New Mexico State University
Information and Communication Technologies
MSC 3AT PO Box 30001
Las Cruces, NM 88003-8001