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