OCR Provides New Guidance Regarding Mobile Devices and Electronic Media

October 8, 2018


The OCR’s August 2018 Cyber Security Newsletter (the “Guidance”) highlights the importance of adopting specific policies regarding the effective management of mobile devices (e.g., cell phones, laptops) and electronic media (e.g., USB drives and CDs) containing PHI (collectively, “Electronic Devices”).  Historically, the OCR has repeatedly advised that Electronic Devices are particularly vulnerable to intrusion and unauthorized access.  Indeed, many of the OCR settlements, some involving millions of dollars, have stemmed from breaches caused by inadequate security of Electronic Devices.

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If you have any questions or would like assistance in updating or creating policies, please contact the Garfunkel Wild attorney with whom you usually work.