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HIPAA Compliance

Hosted~FTP~ Health Insurance Portability and Accountability Act (HIPAA) compliance program overview

“As per The Department of Health and Human Services (DHHS), the organization that manages and is responsible for enforcing the Health Insurance Portability and Accountability Act (HIPAA), there is no entity entrusted to certify corporations as “HIPAA Certified” or companies or products getting “official HIPAA certification”. The evaluation standard § 164.308(a)(8) requires covered entities to perform a periodic technical and nontechnical evaluation that establishes the extent to which an entity’s security policies and procedures meet the security requirements. The evaluation can be performed internally by the covered entity or by an external organization that provide evaluations or “certification” services”.ref http://www.hipaacertification.net/

The Hosted~FTP~ HIPPA compliance program evaluation process includes:

  • a re-assessment of current threat, vulnerability and risk assessments when there is a significant environment change
  • tracking of known industry security issues and evaluation of evolving risk levels.
  • ongoing risk analyses, as required by the standard § 164.308(a)(8), to ensure our services meet changing security requirements

Hosted~FTP~ builds all of our application systems solely on top of the AWS cloud infrastructure and therefore shares the compliance responsibilities with AWS.

Hosted~FTP~ data location

When you subscribe to the Hosted~FTP~ services all data will then reside in the US at Amazon Web Services West Virginia location.

Hosted~FTP~ PHI data protection

The Hosted~FTP~ SaaS application has been designed to ensure that all protected health information (PHI) can be transmitted securely and stored in the Amazon Web Services securely. The data is 256 bit AES encrypted in transit, on arrival and at rest:

In transit

a) For transfers by web browsers, our website is secured by HTTPS with AES 256 b it encryption (certified by the US government for top secret information)

b) For transfers by FTP (i.e. FTP client programs, scripts, etc.) we support FTPS (FTP over TLS/SSL) with AES 256 bit encryption and  SFTP

On Arrival

Hosted~FTP~ encrypts the data as soon as it arrives at the Hosted~FTP~ Amazon cloud location and before any processing takes place to ensure that the data is never unprotected. This includes all data, credentials and file-names and folder names; a process that is unique to Hosted~FTP~.

At rest

Your files are encrypted with 256 bit AES encryption before they are saved to any disk. From there files are securely uploaded by HTTPS to Amazon S3 cloud storage, where Amazon encrypts the files a second time before they are stored.

Server Port lock-down & File integrity

Port lock-down

All Hosted~FTP~ servers are locked down completely except for the ports required to serve HTTP, HTTPS, FTP, and FTPS

File Integrity (chain of custody)

All files are fingerprinted with an MD5 hash that is stored with reference to the file. When the file(data) is retrieved the MD5 hash is recreated and compared against the original to establish proof that there has been no tampering.

Privacy and Intrusion protection

All Hosted~FTP~ accounts are only accessible by username and password; the account administrator grants sharing and login privileges to the users, contacts, folders and files in the account.

Multi-Factor Authentication

Hosted~FTP~ has implemented 2-step verification using the Google Authenticator app on your mobile phone. This feature requires the user to present a valid 6-digit authentication code provided by their MFA mobile device app, in addition to their username and password, before they can sign in. For Hosted~FTP~ the 6 digit code is added after the username/email field on the login prompt i.e. username/email: ftp@hostedftp.com 162839 Password: password123

Restricted SaaS service

Hosted~FTP~ does not allow any user programs to execute at all; our clients can only use our service to upload, retrieve and provide email notifications by our secure email server.

Full audit trail of all activities

We provide logs of all user login activity and also upload/download activity for purposes of audit and tracking in each user account in the form of daily Excel and/or .CSV files stored in each account.

Backup and recovery

We are 100% cloud, meaning that all of our infrastructure is hosted in the Amazon Cloud. “Amazon S3 provides a highly durable storage infrastructure designed for mission-critical and primary data storage. ” see this link for further details. Amazon has many processes and certifications to guarantee the safety and reliability of the files stored in S3. We adhere to all Amazon’s security best practices. Amazon redundantly stores files on multiple devices across multiple facilities in an Amazon S3 Region before we provide a SUCCESS to the user.

Hosted~FTP~ maintenance and AWS SLA standards

Hosted~FTP inherits the AWS infrastructure SLA with a commitment as noted below. Please see the links for further info.:

“AWS will use commercially reasonable efforts to make Amazon S3, EC2 and Amazon EBS each available with a Monthly Up-time Percentage (defined below) of at least (see below) in each case during any monthly billing cycle (the “Service Commitment�?)

http://aws.amazon.com/ec2/sla/  SLA is 99.95 %

http://aws.amazon.com/s3/sla/   SLA is 99.9%

Hosted~FTP~ has a reserved maintenance window on Saturday from 10 am to 12 PM.  The scheduled maintenance releases are typically infrequent and of short duration.

Amazon Web Services compliance & security standards

The AWS infrastructure is HIPPA complaint. The AWS cloud infrastructure has been designed and managed in alignment with regulations, standards, and best-practices. Please review the following links

AWS Component SLA standards

  •  Amazon S3 is designed for 99.99% availability and 99.999999999% durability (see this link)
  • Amazon EBS volume data is replicated across multiple servers in an Availability Zone to prevent the loss of data from the failure of any single component. HFTP configures multi-availability zones for transparent recovery from any failures. (see this link)
  • Amazon RDS Multi-AZ deployments provide enhanced availability and durability for Database (DB) Instances, as configured by HostedFTP (HFTP) (see this link).
  • Amazon EC2 Service Level Agreement commitment is 99.95% availability for each Amazon EC2 Region. (see this link)

Reference links