Mobile Device Security and Storage Media Management

2021.1

Tuna recognizes that media containing sensitive data may be reused when appropriate steps are taken to ensure that all stored sensitive data has been effectively rendered inaccessible. Destruction/disposal of sensitive data shall be carried out in accordance with federal and state law. The schedule for destruction/disposal shall be suspended for sensitive data involved in any open investigation, audit, or litigation.

Tuna utilizes virtual storage repositories such as AWS EBS volumes and S3 buckets to store production data. Volumes and repositories utilized by Tuna and Tuna Customers are encrypted. Tuna does not use, own, or manage any mobile devices, removable storage media, or backup tapes that have access to sensitive data.

Policy Statements

Tuna policy requires that:

(a) All media, including mobile and removable media, storing Tuna company data must be encrypted.

(b) Critical data as defined in Tuna data classification model §data-management may not be stored on mobile devices or removable media such as USB flash drives.

(c) All destruction/disposal of sensitive data storage media will be done in accordance with federal and state laws and regulations and pursuant to the Tuna's written retention policy/schedule.

  • Records that have satisfied the period of retention will be destroyed/disposed of in an appropriate manner.
  • Records involved in any open investigation, audit or litigation should not be destroyed/disposed of.

(d) All sensitive data must rendered inaccessible in a forensically sound manner prior to media reuse or disposal.

(e) Mobile devices, including laptops, smart phones and tables, used in support of critical business operations shall be fully managed and/or audited by Tuna IT and Security.

Controls and Procedures

Media Disposal Process

IT and Security is responsible to ensure media containing critical / sensitive data is disposed securely in the following manner:

  • The methods of destruction, disposal, and reuse are reassessed periodically, based on current technology, accepted practices, and availability of timely and cost-effective destruction, disposal, and reuse technologies and services. This may include

    • Secure wipe;
    • Physical destruction;
    • Destruction of encryption keys (if the data on the media is encrypted using a strong algorithm such as AES-256).

  • If the records have been requested in the course of a judicial or administrative hearing, a qualified protective order will be obtained to ensure that the records are returned to the organization or properly destroyed/disposed of by the requesting party.

  • All Tuna Subcontractors provide that, upon termination of the contract, they will return or destroy/dispose of all patient health information. In cases where the return or destruction/disposal is not feasible, the contract limits the use and disclosure of the information to the purposes that prevent its return or destruction/disposal.

  • In the cases of a Tuna Customer terminating a contract with Tuna and no longer utilize Tuna Services, data will be returned or disposed per contract agreement or Tuna Platform use terms and conditions. In all cases it is solely the responsibility of the Tuna Customer to maintain the safeguards required of laws and regulations once the data is transmitted out of Tuna environments.