PE-19 Physical Protection

Information Leakage

Medium Risk Moderate Low Cost

PE-19 requires protecting the system from information leakage due to electromagnetic signals and other emanations, or limiting leakage to organization-defined levels. In practical healthcare programs this includes shoulder-surfing of EHR screens, printer output in public areas, and — where risk warrants — technical emanation controls for high-sensitivity environments.

Control Objective

Reduce unauthorized observation and emanation of ePHI from system components through physical placement, privacy aids, and, where justified, technical leakage limits.

Implementation Guidance

  1. Assess leakage risks: public-facing screens, registration desks, shared printers, glass conference rooms overlooking EHR ops.
  2. Deploy privacy screens, session lock (AC-11), and display positioning for clinical workstations.
  3. Route ePHI print jobs to secured printers; avoid lobby multi-functions for clinical output.
  4. Use clean desk and remove printed ePHI promptly (MP controls).
  5. For high-risk programs (e.g., certain research/government care), evaluate electromagnetic emanation requirements explicitly.
  6. Train workforce on shoulder-surfing awareness in open bays.
  7. Review telehealth and remote work camera angles that capture ePHI screens.
  8. Document risk-based scope so PE-19 is not ignored as only TEMPEST.

Real-World Use Cases

How this control shows up in healthcare and HIPAA-covered environments.

ED tracking board visible to waiting room

Board shows patient names/status. PE-19 review relocates or applies privacy filtering for public sight lines.

Registration desk shoulder surf

Visitor photographs an insurance card screen. Privacy screen plus recessed monitor positioning reduce leakage.

Shared floor printer

After-visit summaries sit in an open bin. Secured release printing under PE-19/MP handling stops casual pickup of ePHI.

Best Practices

  • Privacy screens in public clinical areas.
  • Secure print release for ePHI.
  • Position monitors away from public view.
  • Session lock and screen timeout.
  • Risk-based emanation analysis for high sensitivity.
  • Telehealth screen hygiene.

Common Gaps & Violations

  • Waiting-room visibility into EHR screens.
  • Unattended clinical printouts.
  • Glass war rooms with live ePHI dashboards.
  • Ignoring PE-19 as irrelevant outside defense.
  • Remote workers on planes with open charts.

Required Documentation

  • Information leakage / visual privacy standard (PE-19)
  • Workstation placement and privacy-screen requirements
  • Secure printing procedures
  • Risk assessment for emanation controls if applicable
  • Training materials on visual privacy

How to Test & Validate

  1. Observe registration/nursing stations for visual exposure.
  2. Check printer locations and release controls.
  3. Verify privacy screens where required.
  4. Sample telehealth workspace guidance.
  5. Review any high-sensitivity emanation requirements and evidence.

Audit Considerations

Visual leakage is one of the most common physical privacy failures in clinics. Assessors and mystery-walkers notice it immediately.

HIPAA Mapping

How this NIST control supports HIPAA Security Rule expectations.

  • 164.530(c) Safeguards — reasonable and appropriate safeguards to protect PHI from intentional or unintentional disclosure.
  • 164.312(a) Access Control — automatic logoff and access controls reduce on-screen exposure time.
  • 164.310(b) Workstation Use — policies for physical attributes of surroundings of workstations that access ePHI.
  • 164.310(c) Workstation Security — physical safeguards for workstations that access ePHI.

Compliance Tips

  • Add visual privacy to clinic security walkthrough checklists.
  • Prefer pull-print everywhere clinical documents print.
  • Include PE-19 in telehealth onboarding.

Frequently Asked Questions

Is PE-19 only TEMPEST?

The control addresses emanations broadly; healthcare programs should treat visual/printer leakage as in-scope even when full TEMPEST is not required.

Do privacy screens alone satisfy PE-19?

They help for visual risks; combine with placement, lock, and print controls — and technical emanation limits only where risk analysis demands.

Are speakerphones disclosing PHI a PE-19 issue?

Acoustic leakage is a privacy safeguard concern; address under workstation use/privacy policies alongside PE-19 visual controls.

References & Resources

  • NIST SP 800-53 Rev. 5 — PE-19
  • Related controls: AC-11, AC-4, PE-5, MP-2, SC-4

Need Help Implementing PE-19?

Our auditors map NIST SP 800-53 controls to your HIPAA Security Rule program — policies, technical evidence, and audit readiness.