Data Security and Privacy Policy
ModelPath Health (d/b/a of Valid Signal LLC) Last Updated: November 4, 2024
1. Introduction
ModelPath Health, operating as a d/b/a of Valid Signal LLC of New York, is dedicated to maintaining the highest standards of security and compliance in handling healthcare data and protected health information (PHI). This policy outlines our comprehensive approach to data protection, security measures, and compliance procedures.
2. Scope
This policy applies to:
All Valid Signal LLC employees
Contractors and consultants
Third-party service providers
Any individual or entity with access to our systems or data
3. Regulatory Compliance
ModelPath Health maintains strict compliance with:
Health Insurance Portability and Accountability Act (HIPAA)
New York State information security regulations
Other applicable federal and state healthcare privacy laws
Industry security standards and best practices
4. Data Classification and Handling
4.1 Data Categories
Protected Health Information (PHI)
Personally Identifiable Information (PII)
Business Confidential Information
Public Information
4.2 Handling Requirements
Each data category has specific handling, storage, and transmission requirements detailed in our operational procedures.
5. Security Controls
5.1 Access Management
Role-based access control (RBAC)
Regular access reviews
Strong authentication requirements
Detailed access logging and monitoring
5.2 Technical Security
Industry-standard encryption for data in transit and at rest
Secure data storage and transmission protocols
Regular security patches and updates
Continuous system monitoring
6. Incident Response
6.1 Breach Response Procedures
Immediate incident containment
Investigation and documentation
Required notifications to affected parties
Regulatory reporting as required by law
6.2 Business Continuity
Regular data backup procedures
Disaster recovery planning
Business continuity testing
7. Employee Requirements
7.1 Training
Initial security awareness training
Annual HIPAA compliance training
Regular security updates and refreshers
7.2 Responsibilities
Adherence to security policies
Prompt incident reporting
Maintaining confidentiality
8. Vendor Management
Security assessment of vendors
Business Associate Agreements (BAA) requirements
Regular vendor compliance reviews
Security requirements in contracts
9. Compliance Monitoring
9.1 Auditing
Regular internal security audits
External compliance assessments
System activity monitoring
Access log reviews
9.2 Documentation
Maintenance of security records
Compliance documentation
Training records
Incident reports
10. Policy Updates
This policy is reviewed and updated annually or when significant changes occur in:
Regulatory requirements
Business operations
Technology infrastructure
Risk landscape
Contact Information
For questions or concerns regarding this policy:
Email: nick@modelpath.ai
Valid Signal LLC d/b/a ModelPath Health