Sunshine Health Care Provider
Remote Access Policy for Remote Workers & Medical Clinics
To establish guidelines and define standards for remote access to Sunshine Health Care Provider’s information resources (networks, systems, applications, and data including but not limited to, electronic protected health information (ePHI) received, created, maintained or transmitted by the organization). Remote access is a privilege and is granted only to remote users who have a defined need for such access, and who demonstrate compliance with Sunshine Health Care Provider’s established safeguards which protect the confidentiality, integrity, and availability of information resources.
The purpose of this policy is to establish uniform security requirements for all authorized users who require remote electronic access to Sunshine Health Care Provider’s network and information assets. The guidelines set forth in this policy are designed to minimize exposure to damages that may result from unauthorized use of Sunshine Health Care Provider’s resources and confidential information, and to at all times be in compliance with HIPAA.
This policy applies to all authorized system users, including members of the workforce, business associates, and vendors, desiring remote connectivity to Sunshine Health Care Provider’s networks, systems, applications, and data. This includes nurses, hospice staff, and administrators of Sunshine Health Care Provider’s remote healthcare branches and locations.
The policy has in its scope all policies pertaining to the LAN to WAN domain, WAN domain, and Remote Access Domain. Additionally, policies from the Workstation domain to ensure the health of remote clients, as well as the policies of End Users domain to ensure safe information security practices are employees while accessing the VPN as included.
The policy adheres to the recommendations in the NIST SP 800-77: Guide to IPSec VPN.
- Password authentication should be through Extensible Authentication Protocol-Transport Level Security (EAP-TLS)
- Passwords should be in compliant with the organization’s Password Policy which refers to the NIST 800-63B document
- All communication and data flow should ensure strong encryption and should be through Layer Two Tunneling Protocol (L2TP) over Internet Protocol security (IPsec)
Gaining Remote Access
- Workforce members shall apply for remote access connections by completing a “VPN Access Authorization” form.
- The applied form should be approved and authorized by the supervisor of the employee and the CISO.
- The CISO will authorize the form only after ensuring that the employee has undergone compliance training and VPN usage training
- All employees who are granted remote access privileges must sign and comply with the “Information Access & Confidentiality Agreement.”
Equipment, Software, and Hardware
- The VPN server will be updated and patched and always current
- The Network Access Control server will be updated and patched and always current
- Corporate firewalls, IPS, and the client host-based firewall will be updated and patched and always current
- The employee laptops will have full disk encryption and will be remotely administrated for updating and health checks
- The employee may not tamper or turn off with any installed software (anti-malware, data loss prevention software, VPN clients, local firewall) or use any systems to circumvent their functioning
- VPN connections will be permitted to authorized users only through organization-provided and registered laptops
- VPN connections will be granted only in accordance with the authorization form – for the particular user, for the specified duration
- All data in motion encryption and authentication protocols will follow policy and required standards
- All connections are permitted only on multi-form authentication: passwords and SMS code, or passwords and voice code.
- Data transfers after successful authentication are permitted only after the NAC system provides a green light of the laptop’s security health, else the connection will be closed
- VPN connected employees will log off and disconnect when their task is completed, even if the session has not ended
- The connection will be automatically closed if there is no activity for 15 minutes.
Logging and Monitoring
- All login attempts, authentication, and log off times and usernames are logged
- All VPN activity is logged
- All logs are centrally maintained in the SIEM server
- All logs are monitored by security personnel and anomalies reported
- Logs are retained as defined in the Log Collection and Retainment policy
- Remote access users who violate this policy are subject to sanctions and/or disciplinary actions, up to and including termination of employment or contract. Termination of access by remote users is processed in accordance with the Termination policy.
- Employees should always lock computer screens when not in use
- Supervisors should grant authorization only on a need to know basis to an employee
- Security personnel should stay current with all encryption and authentication standards and ensure that the VPN system is always current.