Develop comprehensive device and media control policies including:
• Device and media disposal procedures
• Data sanitization and destruction procedures
• Hardware disposal and recycling procedures
• Media destruction and disposal procedures
• Documentation and certification of disposal
• Regular review and update of disposal procedures
Key components:
- Device disposal procedures
- Media destruction procedures
- Data sanitization methods
- Disposal documentation
- Disposal certification
- Regular procedure review
Device and Media Controls
High Risk
Moderate Implementation
Medium Cost
Implement policies and procedures to address the final disposition of ePHI, and/or the hardware or electronic media on which it is stored.
Implementation Guidance
Required Documentation
• Device and media disposal policies
• Data sanitization and destruction procedures
• Hardware disposal and recycling procedures
• Media destruction and disposal procedures
• Disposal documentation and certification
• Disposal vendor agreements
• Regular review and update procedures
• Data sanitization and destruction procedures
• Hardware disposal and recycling procedures
• Media destruction and disposal procedures
• Disposal documentation and certification
• Disposal vendor agreements
• Regular review and update procedures
Best Practices
• Develop comprehensive disposal policies
• Use proper data sanitization methods
• Implement secure hardware disposal
• Use certified media destruction
• Document all disposal activities
• Obtain disposal certifications
• Regular review and update of procedures
• Use proper data sanitization methods
• Implement secure hardware disposal
• Use certified media destruction
• Document all disposal activities
• Obtain disposal certifications
• Regular review and update of procedures
Common Violations
• Lack of device and media disposal policies
• Inadequate data sanitization procedures
• Insufficient hardware disposal procedures
• Poor media destruction procedures
• Inadequate disposal documentation
• Insufficient disposal certification
• Inadequate data sanitization procedures
• Insufficient hardware disposal procedures
• Poor media destruction procedures
• Inadequate disposal documentation
• Insufficient disposal certification
Testing Procedures
• Review disposal policies and procedures
• Test data sanitization methods
• Verify hardware disposal procedures
• Test media destruction procedures
• Review disposal documentation
• Verify disposal certifications
• Review policy compliance
• Test data sanitization methods
• Verify hardware disposal procedures
• Test media destruction procedures
• Review disposal documentation
• Verify disposal certifications
• Review policy compliance
Audit Considerations
• Device and media disposal policies
• Data sanitization implementation
• Hardware disposal procedures
• Media destruction procedures
• Disposal documentation
• Disposal certifications
• Policy review and updates
• Data sanitization implementation
• Hardware disposal procedures
• Media destruction procedures
• Disposal documentation
• Disposal certifications
• Policy review and updates
NIST Cybersecurity Framework Alignment
This HIPAA control aligns with the following NIST Cybersecurity Framework functions and controls:
Identify (ID)
- ID.AM-1: Physical devices and systems within the organization are inventoried
- ID.AM-2: Software platforms and applications within the organization are inventoried
- ID.AM-3: Organizational communication and data flows are mapped
Protect (PR)
- PR.AC-1: Identities and credentials are issued, managed, verified, revoked, and audited
- PR.AC-3: Remote access is managed
- PR.DS-1: Data-at-rest is protected
- PR.DS-2: Data-in-transit is protected
Detect (DE)
- DE.AE-1: A baseline of network operations and expected data flows is established
- DE.CM-1: The network is monitored to detect potential cybersecurity events
- DE.CM-3: Personnel activity is monitored to detect potential cybersecurity events
Respond (RS)
- RS.CO-1: Personnel know their roles and order of operations when a response is needed
- RS.CO-2: Incidents are reported consistent with established criteria
- RS.AN-1: Notifications from detection systems are investigated
Recover (RC)
- RC.RP-1: Recovery plan is executed during or after a cybersecurity incident
- RC.IM-1: Recovery plans incorporate lessons learned
- RC.CO-1: Public relations are managed
Note: This mapping provides a general alignment between HIPAA controls and NIST Framework functions. Specific implementation may vary based on your organization's risk profile and compliance requirements.
Implementation Templates & Checklists
Download our expert-developed templates and checklists to implement this control effectively:
Implementation Checklist
Step-by-step checklist to ensure complete implementation of this control
Download ChecklistExpert Implementation Recommendations
Based on our experience with 500+ healthcare organizations, here are our expert recommendations for implementing this control:
High Priority
Start with Risk Assessment
Conduct a comprehensive risk assessment to identify specific vulnerabilities and threats related to this control. This will help prioritize implementation efforts and allocate resources effectively.
- Identify all systems and data covered by this control
- Assess current security measures and gaps
- Evaluate potential impact of security incidents
- Document findings and remediation priorities
Medium Priority
Develop Comprehensive Policies
Create detailed policies and procedures that address all aspects of this control. Ensure policies are specific, actionable, and aligned with your organization's risk profile.
- Define roles and responsibilities clearly
- Establish approval workflows and escalation procedures
- Include specific technical requirements and standards
- Regular review and update schedules
Low Priority
Implement Monitoring and Testing
Establish ongoing monitoring and testing procedures to ensure the control remains effective over time. Regular testing helps identify new vulnerabilities and compliance gaps.
- Automated monitoring where possible
- Regular manual testing and validation
- Incident response procedures
- Continuous improvement processes
Recommended Implementation Timeline
1
Week 1-2: Assessment & Planning
Conduct risk assessment and develop implementation plan
2
Week 3-4: Policy Development
Create and review policies and procedures
3
Week 5-8: Implementation
Deploy technical controls and train staff
4
Week 9-10: Testing & Validation
Test controls and validate compliance
Related Controls
164.310(a)(1) - Facility Access Controls
164.310(a)(2) - Workstation Use
164.310(b) - Media Controls
164.312(a)(1) - Access Control
164.310(a)(2) - Workstation Use
164.310(b) - Media Controls
164.312(a)(1) - Access Control