Website Security Policy

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Website Security Policy – Center for Wellness International

Effective Date: June 3, 2025

1. Purpose and Scope

This Website Security Policy outlines the measures and protocols implemented by the Center for Wellness International (“we,” “us,” or “our”) to protect the confidentiality, integrity, and availability of electronic Protected Health Information (ePHI) and other sensitive data collected, transmitted, processed, or stored via our website (www.centerforwellnessint.com) and related online services.

This policy applies to all workforce members (employees, contractors, volunteers, trainees) and business associates who have access to or manage our website and its associated systems that handle ePHI. This policy is established in accordance with the Health Insurance Portability and Accountability Act (HIPAA) Security Rule and relevant North Carolina state laws.

2. Data Security Governance

  • Security Official: We have designated a Security Official who is responsible for the development, implementation, and oversight of this policy and all security-related procedures. The Security Official can be contacted at [Insert Email or Title of Security Official Contact, e.g., privacyofficer@centerforwellnessint.com].
  • Risk Management: We conduct regular risk assessments of our website and associated systems to identify potential threats and vulnerabilities to ePHI. These assessments inform the implementation and updating of security measures.
  • Workforce Training and Management:
    • All workforce members with access to ePHI through the website or related systems receive security awareness training upon hiring and at least annually thereafter.
    • Training covers this policy, HIPAA security requirements, identifying and reporting malicious software, password management, and secure handling of ePHI.
    • Access to ePHI is granted based on roles and responsibilities (least privilege principle).
    • Sanctions for violations of this security policy will be applied consistently and appropriately.

3. Technical Safeguards

We implement technical safeguards to protect ePHI handled by our website:

  • Access Controls:
    • Unique User Identification: All users accessing systems that manage ePHI via the website are assigned a unique username and password.
    • Authentication: Strong password policies are enforced (e.g., minimum length, complexity, regular changes). Multi-factor authentication (MFA) is implemented for administrative access and access to sensitive systems where feasible.
    • Role-Based Access Control (RBAC): Access to ePHI is restricted based on the user’s role and job responsibilities.
    • Automatic Logoff: Systems are configured to automatically log off users after a predetermined period of inactivity.
  • Transmission Security:
    • Encryption in Transit: Our website uses HTTPS (Hypertext Transfer Protocol Secure) with valid SSL/TLS (Secure Sockets Layer/Transport Layer Security) certificates to encrypt all data transmitted between the user’s browser and our web server. This applies to all pages, especially those collecting any personal information or PHI (e.g., contact forms, appointment request forms, patient portals if applicable).
    • Secure Communication: Any transmission of ePHI outside our secure internal network (e.g., to clients via a patient portal or secure messaging system, if used) must utilize encrypted and secure channels. Standard email is not considered secure for transmitting PHI without specific encryption measures and client consent.
  • Data Integrity:
    • Measures are in place to ensure that ePHI is not improperly altered or destroyed. This includes input validation on web forms and audit trails.
    • Regular data backups are performed for website data and any associated databases containing ePHI.
  • Audit Controls:
    • Hardware, software, and/or procedural mechanisms are implemented to record and examine activity in information systems that contain or use ePHI. Audit logs are reviewed regularly for suspicious activity.
  • Protection from Malicious Software:
    • Anti-virus software, firewalls, and intrusion detection/prevention systems are deployed and regularly updated on servers hosting the website and related systems.
  • Website Platform Security:
    • The website’s content management system (CMS), plugins, themes, and underlying server software are kept up-to-date with the latest security patches.
    • Unnecessary plugins or services are removed to reduce the attack surface.
  • Secure Development (If Applicable):
    • If custom web applications are developed, secure coding practices (e.g., OWASP guidelines) are followed to prevent common vulnerabilities.

4. Physical Safeguards

While this policy primarily addresses website security, physical safeguards are in place for systems supporting the website:

  • Server Security: If servers are hosted on-premises, they are located in secure areas with restricted access. If using a third-party hosting provider, they must demonstrate HIPAA-compliant physical security measures (see Section 7).
  • Workstation Security: Workforce members accessing website administrative functions or ePHI via the website must ensure their workstations (computers, mobile devices) are physically secured and employ screen locks and strong passwords.

5. Administrative Safeguards (Website Context)

  • Information Access Management: Procedures are in place to authorize, establish, modify, and terminate access to systems handling ePHI via the website, consistent with role-based access controls.
  • Security Incident Procedures:
    • We have established procedures for identifying, responding to, mitigating, and documenting suspected or known security incidents, including data breaches.
    • In the event of a breach of unsecured ePHI, we will follow HIPAA breach notification requirements, including notifying affected individuals, the Secretary of Health and Human Services, and, if applicable, the media.
  • Contingency Plan:
    • Data Backup Plan: Regular backups of website data and associated ePHI are performed and stored securely.
    • Disaster Recovery Plan: Procedures are in place to restore website functionality and access to ePHI in the event of a disaster or system failure.
    • Emergency Mode Operation Plan: If critical website functions support patient care, plans exist for operating in emergency mode.

6. Website-Specific Security Practices

  • HTTPS Enforcement: All website traffic is forced to use HTTPS.
  • Web Application Firewall (WAF): A WAF may be used to filter and monitor HTTP traffic between the website and the Internet, protecting against common web attacks.
  • Forms and Data Submission:
    • Web forms collecting sensitive information are designed to minimize the data collected to only what is necessary.
    • Data submitted through forms is transmitted securely via HTTPS.
    • Storage of data submitted via forms is handled according to our Data Retention and Destruction Policy and PHI handling procedures. Data is not unnecessarily stored on the web server itself if it can be directly and securely transferred to a designated PHI system (e.g., EHR).
  • Third-Party Scripts and Content: Embedded third-party scripts or content (e.g., analytics, social media widgets, tracking pixels) are reviewed for security and privacy implications. We strive to limit their use, especially on pages handling sensitive information. Standard analytics tools that collect IP addresses (which can be considered PHI) are configured or used in a manner that supports HIPAA compliance, or alternative HIPAA-compliant analytics are used if necessary.

7. Third-Party Vendor Management (Website Related)

  • Hosting Provider: Our website hosting provider is selected based on their ability to provide a secure environment compliant with HIPAA standards. A Business Associate Agreement (BAA) is in place if the hosting provider has access to or stores ePHI.
  • Plugin/Service Vendors: Any third-party plugins or services integrated into the website that may access, process, or store ePHI will be reviewed for security practices, and a BAA will be obtained where required.
  • Due Diligence: We conduct due diligence on all third-party vendors handling ePHI on our behalf to ensure they have appropriate security measures in place.

8. Policy Enforcement and Updates

  • Compliance and Sanctions: All workforce members are expected to comply with this policy. Violations may result in disciplinary action, up to and including termination, and potential legal consequences.
  • Policy Review and Updates: This Website Security Policy will be reviewed at least annually and updated as necessary to reflect changes in legal requirements, technology, identified risks, or business operations.

9. Reporting Security Concerns or Incidents

All workforce members must immediately report any suspected or actual security incidents, vulnerabilities, or violations of this policy to the Security Official or their supervisor. Clients and other external parties can report security concerns related to our website to [Insert Contact Email or Method, e.g., security@centerforwellnessint.com or contact details for the Privacy/Security Officer].

10. Contact Information

For questions regarding this Website Security Policy, please contact:

Security Official Center for Wellness International [Insert Physical Address, if different for security matters, or same as other policies] [Insert Phone Number for Security Official] [Insert Email Address for Security Official, e.g., privacyofficer@centerforwellnessint.com or security@centerforwellnessint.com]

Note to the Center for Wellness International:

  • Fill in bracketed information: Designate a Security Official and provide their contact details.
  • Actual Implementation is Key: This policy document outlines intentions. The crucial part is the actual implementation, configuration, and ongoing maintenance of these security measures.
  • Technical Expertise: Implementing many of these safeguards requires technical expertise. Engage qualified IT security professionals.
  • Business Associate Agreements (BAAs): Ensure BAAs are in place with all vendors that create, receive, maintain, or transmit ePHI on your behalf (e.g., hosting provider, patient portal vendor, secure email provider, potentially some analytics or form plugin vendors if they handle PHI).
  • Risk Analysis: The HIPAA Security Rule requires a formal, documented risk analysis. This policy should be informed by and align with your risk analysis.
  • North Carolina Law: While HIPAA sets a federal baseline, ensure you are also compliant with any specific North Carolina data security or breach notification laws that may be more stringent or specific. (Your Data Retention policy touched on some NC record retention aspects).
  • Simplicity vs. Detail: This policy attempts to be comprehensive yet understandable. Your internal, more detailed procedures might supplement this overarching policy.
  • Legal and Professional Review: Strongly recommended.